Evaluation of small brominated alkyl alcohols for a possible RoHS restriction

Hazardous substances in EEE are regulated by the RoHS Directive 2011/65/EU (RoHS 2). According to article 6(1) it is possible for member states to submit a proposal for adding new substances to the list of restricted substances of the directive. Article 6(1) and 6(2) describe the criteria and requirements for proposals for restrictions respectively. In 2014, the Danish EPA performed a survey on brominated flame retardants (BFRs). On the basis of its results, the Danish Technical University (DTU Food) investigated possibilities of grouping BFRs. One of the groupings; the small linear and branched brominated alkyl alcohols, including 2,3-dibromo-1-propanol (2,3-DBPA) and 2,2-bis(bromomethyl)-1,3-propanediol (DBNPG) and 2,2-bis-(bromomethyl)-3-bromo-1-propanol (TBNPA), was chosen for further investigation and the grouping was extended to include also theoretical compounds. The category, defined as having 3-5 carbons, 2-3 bromine atoms and 1-2 alcohol groups, comprised 61 members. The Danish EPA thus commissioned a project to collect, assess and present scientific data to support a proposal for restriction of small brominated alkyl alcohol in the RoHS Directive, if the data proved to be adequate. Data should be collected based on publicly available data and on correspondence with relevant stakeholders. A draft dossier should be prepared and subjected to an online stakeholder consultation as a means for collecting further data and confirming assessments made in the course of the evaluation. Following this stage, the dossier should be finalized and recommendations should be made as to the possible restriction of this BFR group under the RoHS Directive.