HEXABROMOCYCLODODECANE

DRAFT RISK MANAGEMENT EVALUATION

Prepared by the ad hoc working group on

HEXABROMOCYCLODODECANE

Persistent Organic Pollutants Review Committee

April 2011
Persistent Organic Pollutants Review Committee

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TABLE OF CONTENTS

Executive summary ..........................................................................................................................................................3

1. Introduction............................................................................................................................................................4

1.1 Chemical identity of the proposed substance................................................................................................4

1.2. Conclusions of the Review Committee regarding Annex E information .................................................6

1.3. Data sources.............................................................................................................................................6

1.4. Status of the chemical under international conventions...........................................................................8

1.5. Any national or regional control actions taken.........................................................................................8

2. Summary information relevant to the risk management evaluation.......................................................................9

2.1. Identification of possible control measures..............................................................................................9

2.2. Efficacy and efficiency of possible control measures in meeting risk reduction goals..........................10

2.3. Information on alternatives (products and processes) where relevant....................................................11

2.3.1 Production of high impact polystyrene (HIPS) plastic..................................................................13

2.3.2 Production of flame retarded textile back-coating ........................................................................13

2.3.3 Production of flame retarded expanded and extruded polystyrene (EPS/XPS) .......................13

2.4. Summary of information on impacts on society of implementing possible control measures...............15

2.4.1. Health, including public, environmental and occupational health ...........................................15

2.4.2 Biota (biodiversity)..................................................................................................................16

2.4.3 Economic aspects, including costs and benefits for producers and consumers and the distribution 

of costs and benefits...............................................................................................................................16

2.5. Other considerations...............................................................................................................................18

3. Synthesis of information ......................................................................................................................................18

3.1 Summary of risk profile information ..........................................................................................................18

3.2 Summary of risk management evaluation information ...............................................................................19

3.3 Suggested risk management measures........................................................................................................19

4. Concluding statement...........................................................................................................................................20

References ......................................................................................................................................................................21
Persistent Organic Pollutants Review Committee

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Executive summary

1. Hexabromocyclododecane (HBCD; also HBCDD) was proposed as a POPs candidate by Norway in 2008. In 

2010, the 6

th meeting of the POPs Review Committee decided that HBCD is likely, as a result of its long-range 

environmental transport, to lead to significant adverse human health and environmental effects, such that global action 

is warranted.

2. HBCD was considered by the Executive Body of the UNECE Convention on Long-Range Trans-boundary Air 

Pollution (LRTAP) to meet the criteria for POPs as defined under the POPs protocol. HBCD is included as part of the 

brominated flame retardants group in the List of Substances for Priority Action of The Convention for the Protection of 

the Marine Environment of the North-East Atlantic (the OSPAR Convention). Also the Helsinki Commission 

(HELCOM) has included HBCD in the list of priority hazardous substances.

3. HBCD is produced in China, Europe, Japan, and the USA. The current known annual production is 

approximately 23,000 tonnes per year (9,000 to 10,000 tonnes in China, 13,426 tonnes in Europe and the US). The 

main share of the market volume is used in Europe. 

4. HBCD has been on the world market since the 1960s. It is used as a flame retardant additive, with the intent of 

delaying ignition and slowing subsequent fire growth during the service life of vehicles, buildings or articles, as well as 

while materials are stored. The main uses of HBCD are in flame-retarded expanded (EPS) and extruded (XPS) 

polystyrene foam insulation, with smaller scale use in textile applications and electric and electronic appliances (high 

impact polystyrene/HIPS). In textiles HBCD is used in back-coatings for upholstery and other interior textiles, 

including automotive applications. The volumes of HBCD flame retarded articles imported and exported globally is 

generally unknown.

5. Release of HBCD into the environment may occur during all stages of its life cycle; production and 

manufacturing, processing, transportation, use, handling, storage or containment, point-source discharges, migratory 

releases from manufactured product usage and from disposal of the substance or products containing the substance. The 

European industry has since 2008 taken actions to substantially reduce HBCD emissions from HBCD production and 

first line use. 

6. Emissions of HBCD can be reduced in production of HBCD, in processes where HBCD or articles containing 

HBCD are used, and during the waste management phase. Emission control techniques at the production sites alone 

will not be efficient in solving the problem HBCD is posing for the environment and health, since there are diffuse 

emissions and releases to the water reserves and sewage systems from products containing HBCD. Wastes containing 

HBCD represent a large source of releases and increasing amounts of HBCD-containing wastes in landfills and other 

locations could be a long-term source of HBCD emissions. Wastes containing HBCD include production wastes, 

insulation boards, building and renovation wastes, and from other less-commonly used applications such as electrical 

and electronic products and textiles. The process of remodelling and demolition of buildings suggests that HBCD

emissions are likely to continue in the future from the installed amount of materials containing HBCD.

7. A number of alternative fire retardants are available to replace HBCD in high-impact polystyrene (HIPS) and 

textile back-coating. However, there appear to be no drop-in chemical alternatives for flame-retarded EPS/XPS 

products in all regions. In the USA an alternative chemical flame retardant is used in the production of EPS, but not in 

Europe.

8. Many countries have set standards for building materials with regards to their contribution to fire. Consequently, 

inherently flammable materials must be treated with a flame retardant to meet certain fire performance criteria, which 

are required in the country regulations for a specific use. In some countries HBCD has effectively already been phased 

out. In those countries the fire safety regulations do not require the treatment with a flame retardant. The same level of 

fire safety is achieved by alternative means that are technically feasible and also commercially available. HBCD phaseout could include flame retardant substitution, resin/material substitution and product redesign. 

9. HBCD is an intentionally produced industrial chemical. Under the Convention, the most adequate control 

measure is listing in Annex A. To allow for certain time-limited critical uses of HBCD a specific exemption for use of 

HBCD, could be given together with detailed conditions for HBCD production and uses. Stockpiles and waste 

containing HBCD would be subject to the waste provisions in Article 6.
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1. Introduction

10. On June 18th 2008, Norway, as a Party to the Stockholm Convention, submitted a proposal to list the 

brominated flame retardant hexabromocyclododecane (HBCD; also HBCDD) as a possible Persistent Organic Pollutant 

(POP) under Annex A of the Convention (UNEP/POPS/POPRC.5/INF/16). 

1.1 Chemical identity of the proposed substance

11. Commercial HBCD is a white solid substance. Producers and importers have provided information on this 

substance under two different names; hexabromocyclododecane (EC Number 247-148-4, CAS number 25637-99-4) 

and 1,2,5,6,9,10-hexabromocyclododecane (EC Number 221-695-9, CAS number 3194-55-6). The structural formula 

of HBCD is a cyclic ring structure with Br-atoms attached (Table 1). The molecular formula of the compound is 

C12H18Br6 and its molecular weight is 641 g/mol. Depending on the manufacturer and the production method used, 

technical HBCD consists of 70-95 % γ-HBCD and 3-30 % of α- and β-HBCD (European Commission 2008; Nordic 

Council of Ministers (NCM) 2008). Each of these stereoisomers has its own specific CAS number i.e. α-HBCD, CAS 

No: 134237-50-6; β-HBCD, CAS No: 134237-51-7; γ-HBCD, CAS No: 134237-52-8. Two other stereoisomers, δHBCD and ε–HBCD have also been found in technical HBCD in low concentrations. Further information pertaining to 

the chemical identity of HBCD is listed in Table 2 and may be found in the supplementary information to the Risk 

Profile on HBCD (UNEP/POPS/POPRC.6/INF/25). 

Table 1. Information pertaining to the chemical identity of HBCD 

Chemical structure

Structural formula of HBCD1:

1

Structural formula for 1,2,5,6,9,10-

HBCD, i.e., CAS no 3194-55-6.

Note that CAS no 25637-99-4 is 

also used for this substance, 

although not correct from a 

chemical point of view as this 

number does not specify the 

positions of the bromine atoms. As 

additional information, the 

structures and CAS numbers for the 

diastereomers making up 

1,2,5,6,9,10-HBCD are given 

below, although these 

diastereomers always occur as 

mixtures in the technical product.

Chiral components of 

commercial HBCD:

Br

Br

Br

Br

Br

Br

alpha-HBCD

CAS No: 134237-50-6

Br

Br

Br

Br

Br

Br

beta-HBCD 

CAS No: 134237-51-7

gamma-HBCD 

CAS No: 134237-52-8

Br

Br

Br

Br

Br

Br
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Table 2. Chemical identity

Chemical identity

Chemical Name: Hexabromocyclododecane and 1,2,5,6,9,10 -hexabromocyclododecane 

EC Number: 247-148-4; 221-695-9

CAS Number: 25637-99-4; 3194-55-6

IUPAC Name: Hexabromocyclododecane

Molecular Formula: C12H18Br6

Molecular Weight: 641.7

Trade names/ other 

synonyms:

Cyclododecane, hexabromo; HBCD; Bromkal 73-6CD; Nikkafainon CG 1; Pyroguard F 800; 

Pyroguard SR 103; Pyroguard SR 103A; Pyrovatex 3887; Great Lakes CD-75PTM; Great 

Lakes CD-75; Great Lakes CD75XF; Great Lakes CD75PC (compacted); Dead Sea Bromine 

Group Ground FR 1206 I-LM; Dead Sea Bromine Group Standard FR 1206 I-LM; Dead Sea 

Bromine Group Compacted FR 1206 I-CM.

Stereoisomers and 

purity of commercial 

products: 

Depending on the producer, technical grade HBCD consists of approximately 70-95% γHBCD and 3-30 % of α- and β-HBCD due to its production method (European Commission, 

2008). Each of these has specific CAS numbers. Two other stereoisomers, δ-HBCD and ε–

HBCD have also been found by Heeb et al. (2005) in commercial HBCD in concentrations of 

0.5 % and 0.3 %, respectively. These impurities are regarded as achiral at present. According 

to the same authors, 1,2,5,6,9,10-HBCD has six stereogenic centers and therefore, in theory, 

16 stereoisomers could be formed. 

12. HBCD has been on the world market since the 1960s. Production has been reported in China, Europe, Japan, and 

the USA. The current known annual production is approximately 23,000 tonnes per year (9,000 to 10,000 tonnes in 

China, 13,426 tonnes by the BSEF member companies in Europe and the US). Japanese production data is not 

available. No information on production in other countries or by non-BSEF member companies was received.

13. Based on responses from Parties and Observers, it appears that the main consumption and use of HBCD takes 

place in Europe. According to the global demand reported by the industry in 2001, more than half of the market volume 

(9,500 of 16,500 tonnes) was used in Europe. Total global demand for HBCD increased over 28% by 2002 to 21,447 

tonnes, and rose again slightly in 2003 to 21,951 tonnes (BSEF 2006). In the US the sum of manufactured and imported 

HBCD is reported to lie between 4,540 to 22,900 tons in 2005 (US EPA 2008). The total volume of HBCD used in the 

EU was estimated to be about 11,580 tonnes in 2006. The demand of HBCD within the EU is bigger than the 

production there and the net import to the EU was expected to have been around 6,000 tonnes in 2006 (ECHA 2008a). 

The authorities in Japan have reported the sum of domestic production and import of HBCD to be 2,844 tonnes in 2008

and 2,613 tonnes in 2009. Several other national authorities report an import of HBCD as a pure compound or in 

products; Canada (100-1,000 tonnes), Australia (<100 tonnes), Poland (500 tonnes imported from China annually), 

Romania (185 tonnes), and Ukraine (BSEF 2011, UNEP/POPS/POPRC.6/13/Add.2). Available information suggests

that use of HBCD may be rising (ECHA 2008a). There is also evidence that HBCD may be replacing some 

polybrominated diphenyl ether (PBDE) flame retardants (notably the commercial decabromodiphenyl ether 

formulation) (Environment Canada 2010a).

14. HBCD is used as an additive flame retardant, with the intent of delaying ignition and slowing subsequent fire 

growth during the service life of vehicles, buildings or articles, as well as while materials are stored (BSEF 2010, see 

UNEP/POPS/POPRC.6/13/Add.2 for overview). The main uses of HBCD globally are in flame-retarded expanded 

(EPS)1and extruded (XPS)2polystyrene foam insulation (more than 95% in Europe), while the use in textile 

applications3and electric and electronic appliances (high impact polystyrene/HIPS)4is of a smaller scale (BSEF 2011, 

 

1

0.5-0.7 % HBCD w/w

2

0.8-2% HBCD w/w

3

10-15% HBCD w/w

4

1-7 % HBCD w/w
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UNEP/POPS/POPRC.6/13/Add.2 and references therein e.g. ECHA 2008a, US EPA report, OECD 2007, INESEMARNAT 2004, Lowell Center For Sustainable Production (LCSP 2006), BSEF 2010). The use of HBCD in 

insulation boards started in the 1980s. HBCD is used in textile back-coating in upholstery furniture and other interior 

textiles, including automotive applications (Japan 2011, LCSP 2006). Some other minor uses have also been reported 

by KEMI (2006).

15. Based on the responses from the Parties and Observers and ECHA (2009), the volumes of import and export of 

HBCD in flame retarded articles is generally unknown. Polystyrene foams and textiles are usually tailor made for the 

local market, and the main share of the production is for local consumption, and not exported (SWEREA 2010, BSEF 

2011).

1.2. Conclusions of the Review Committee regarding Annex E information 

16. At its sixth meeting in October 2010, the POPs Review Committee evaluated the draft risk profile for HBCD in 

accordance with Annex E (UNEP/POPS/POPRC.6/13) and adopted this (UNEP/POPS/POPRC.6/13/Add.2). The 

POPRC decided that, “in accordance with paragraph 7 (a) of Article 8 of the Convention, hexabromocyclododecane is 

likely, as a result of its long range environmental transport, to lead to significant adverse human health and 

environmental effects such that global action is warranted”. The Committee also decided to establish an ad hoc working 

group to prepare a risk management evaluation that includes an analysis of possible control measures for 

hexabromocyclododecane in accordance with Annex F to the Convention for consideration at its next meeting. 

1.3. Data sources

17. This risk management evaluation was developed using Annex F information submitted by Parties and observers,

including the industry using and producing HBCD. 

18. Sixteen Parties and country Observers submitted information (Brazil, Burundi, Canada, China, Costa Rica, 

Czech Republic, Ecuador, Finland, Germany, Japan, Nigeria, Norway, Mauritius, Romania, and Sweden). Five nongovernmental Observers submitted information – Bromine Science and Environmental Forum (BSEF), 

PlasticsEurope/Exiba, Instituto do Meio Ambiente (IMA) Brazil, Extruded Polystyrene Foam Association (XPSA) and 

Canadian Plastics Industry Association (CPIA) as well as the International POPs Elimination Network (IPEN). All 

submissions are available on the Convention web site.

19. Brazil reported it does not produce HBCD, and noted the lack of information on emissions and use. In general 

HBCD is used in electronic equipment, automotive and textiles production. Brazil also provided extensive information 

on alternatives to HBCD and HBCD containing products. 

20. Burundi reported it does not produce HBCD. Burundi highlighted the lacking of capacity for monitoring and 

control of chemicals and waste, and noted the need for capacity-building in emergency services, environmentally sound 

destruction and recycling technologies.

21. Ecuador reported that HBCD is imported into the country only in articles, not as a substance. 

22. Canada reported that HBCD is used in flame-retarded PS foams and textiles. In Canada HBCD is used in PS 

foams in lower concentrations (0.5-1%) than in Europe. Canada also noted the potential for brominated dioxin and 

furan emissions related to uncontrolled burning of HBCD containing articles. HBCD has been monitored across Canada 

in landfill leachate since 2009, with varying detection frequency. HBCD has also been monitored in surface water, 

sediment, air, aquatic biota and wildlife, since 2008. HBCD has been detected in human blood, breast milk, dust and 

ambient air.

23. China provided information on production of HBCD in the country and supported emission control, improved 

waste management and HBCD substitution as potential control measures. China also noted that the risks of alternatives

to the environment and human health were not yet addressed.

24. Costa Rica and Mauritius reported no production. Costa Rica also noted the lack of information on HBCD use in 

the country impeding the identification of alternative products.

25. The Czech Republic reported on its ambient air monitoring activities. HBCD isomers were released in the air 

during storage, manipulation of the mixture and during the PS production process in 2010. The concentrations inside 

and outside the production facility were hundreds of ng/m3. HBCD was not found in human milk, but in 10% of the 

liposuction samples. Czech Republic also pointed out that there is no information on import and export of HBCD in the 

EU.

26. Finland submitted information on emissions and emission control measure effectiveness at a recently closed EPS 

production facility. The results confirm the need to address production waste (HBCD packages) and emissions to air, 
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sediment and waste water (from polystyrene beads). 11 % of the EPS produced in the country is flame retarded with 

HBCD. Fire safety regulations do not require use of flame retardant in insulation boards.

27. Germany noted that the use of EPS/XPS insulation boards without flame-retardant is not allowed according to 

the German fire safety regulations and that there is currently no drop-in chemical substitute for HBCD in this use. 

Germany expressed the need for a time limited exemption for HBCD use in EPS/XPS production. They also noted the 

presence of alternative insulation materials to EPS/XPS and that product redesign is technically feasible.

28. Japan reported use of HBCD in XPS, EPS, automotive textiles, and curtain/blind production. In new car-models 

HBCD fabrics are not used anymore, but the demand for fabric used in older models will continue for some time. XPS, 

as well as curtain and blinds producers are working towards reducing or eliminating HBCD use, but no available 

chemical alternatives have been identified. In Japan, EPS waste is collected and recycled as fuel, i.e. RPF (Refuse Paper 

and Plastic Fuel), and other products in effective recycling systems. 

29. Nigeria reported no production, but use of HBCD in EPS, XPS, HIPS and polypropylene fibre. Nigeria provided 

information on alternatives to HBCD in certain uses and supported substitution of HBCD with sustainable flame 

retardants, use of product stewardship programs to minimize emissions, and introduction of regulations to promote 

search for the alternatives. Nigeria also stressed the importance of ensuring the safety of the alternative chemicals and 

building laboratory capacity for chemical measurements. 

30. Norway has prepared a risk management exploration proposal to the UNECE CLRTAP POPs Task Force on 

HBCD (Exploration of management options for Hexabromocyclododecane (HBCD). Fire regulations allow use of 

EPS/XPS insulation boards without flame retardants in Norway if thermal barriers are used. The Norwegian producers 

provide EPS without flame retardants to the Norwegian market. The imported HBCD, approximately 22 t per year, is 

exported to the EU in EPS. There are no other registered uses of HBCD in Norway. Alternatives other than HBCD are 

used for textiles and furniture. There is no information on amounts of HBCD in imported products and articles. Norway 

stressed the importance of releases from waste, especially insulation materials. HBCD has been found in the 

environment both close to EPS production sites and in the remote regions in the Norwegian Arctic. 

31. Romania reported use of HBCD in EPS and XPS production. The annual use from 2009 was 134 tonnes for EPS 

and 50 tonnes for XPS production. With regards to the waste management implications, Romania noted milling and 

recycling of polystyrene waste.

32. Sweden expressed the need to achieve fire safety without flame retardants by use of alternative materials and 

product designs, due to the inherent hazardous properties of many flame retardants, and highlighted that alternative 

solutions are also available. HBCD use in insulation materials is very small in Sweden as fire safety standards do not 

require EPX/XPS to be flame retarded. HBCD is being monitored by Swedish contaminant monitoring programmes in 

marine biota, human milk and ambient air. Due to negligible domestic use, the Swedish environmental levels are 

heavily dependent on HBCD control measures in other countries.

33. Bromine Science and Environmental Forum (BSEF) submitted information on production and uses of HBCD, 

noting that the only production facility in Europe had reduced its total HBCD emissions to the environment to less than 

2 kg a year. BSEF was also concerned over the effects of potential HBCD restrictions on the market and producers, and 

expressed the industry commitment to continue research to find a chemical alternative to HBCD. 

34. Plastics Europe/Exiba, representing the HBCD users in the PS industry, reported that HBCD is used in 0.7% 

content in EPS and an average of 2% in XPS. Plastics Europe/Exiba also highlighted the successful emission reductions 

programmes (VECAP/SECURE) in 2006-2009, where potential emissions from first line users were reduced by 85 %. 

To ensure smooth transition once an alternative is available, the industry intends to apply for REACH authorization for 

the use of HBCD in polystyrene in Europe, before the EU chemicals policy ban takes effect in 2015 (see para 40).

35. IPEN highlighted the need to ban HBCD to reduce the levels in the environment and noted the availability of 

alternative materials to replace EPS/XPS. Elimination of flame retardant use in applications where no fire hazard exists 

could be a starting point (underground applications, non-combustible surfaces, thermal barriers). IPEN also noted the 

wide availability of chemical and non-chemical alternative flame retardants for use in insulation noting that the 

chemical substitutes also may have hazardous properties. Special attention should be paid to waste containing HBCD 

and emissions from burning HBCD containing materials.

36. The North American XPS Industry (XPSA and CPIA) noted that the U.S. and Canadian building codes contain 

provisions to limit ignition and burning and that insulation is important to reduce CO2 emissions. The use of a flameretardant such as HBCD was reported necessary for XPS to meet the U.S. requirements of ASTM C-578 and achieve 

the International Building Code and International Residential Code class A designation for flame spread and smoke 

development per ASTM E-84. Use of a flame-retardant such as HBCD also enables XPS to meet the requirements of 

CAN/ULC S701 and CAN/ULC S102.2, of the 2005 National Building Code of Canada for foamed plastics in noncombustible construction. The HBCD concentration in XPS produced in the US and Canada is lower than in Europe, on 
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average 0.8% by weight. XPSA and CPIA noted that in production of flame retarded XPS, HBCD releases are possible 

during transfer from the original packaging to the feeder at the start of the process, in disposal of packaging materials, 

and during process upsets.

1.4. Status of the chemical under international conventions 

37. HBCD is included as part of the brominated flame retardants group in the List of Substances for Priority Action 

of The Convention for the Protection of the Marine Environment of the North-East Atlantic (the OSPAR Convention). 

The OSPAR Convention is made up of representatives of the Governments of 15 Contracting Parties and the European 

Commission. Also the Helsinki Commission (HELCOM) has included HBCD in the list of priority hazardous 

substances.

38. In December 2009, HBCD was considered by the Executive Body of the UNECE Convention on Long-Range 

Trans-boundary Air Pollution (LRTAP) based on a technical review (ECE/EB.AIR/WG.5/2009/7) to meet the criteria 

for POPs as defined under the POPs protocol. In 2010 the possible management options for HBCD were assessed to 

give a basis for later negotiations. The negotiations are expected to be initiated in December 2011. 

1.5. Any national or regional control actions taken

39. Many countries have set standards for building materials with regards to their contribution to fire. Consequently, 

inherently flammable materials must be treated with a flame retardant to meet certain fire performance criteria, which is 

required in the country regulations for a specific use. Fire protection requirements for certain articles are laid down in 

acts, ordinances and regulations as well as in standards. In the legislation, the requirements are normally specified in 

general terms. To demonstrate that the requirements are met, there are prescribed verifiable criteria, which 

standardisation bodies such as ISO, CEN and UL often have helped to develop (KEMI 2006).

40. In Europe fire test methods have been harmonised and classification of reaction to fire performance for 

construction products, excluding floorings, are based on four fire test methods: the non-combustibility test EN ISO 

1182, the gross calorific potential test EN ISO 1716, the single burning item (SBI) test EN 13823, and the ignitability 

test EN ISO 11925-2. Building products are divided into seven classes on the basis of their reaction-to-fire properties. 

(SWEREA 2010). In the U.S. there are numerous regulations and standards that apply to insulation used for the 

building industry. These regulations and standards may exist at the national, state, county, or municipal level (LSCP 

2006).

41. There are requirements in some countries regarding the use of flame retardants in PS foam for insulation. Fire 

safety regulations require that flame retardant must be used in Canada, Austria, Czech Republic, Germany, Hungary, 

Netherlands, Slovakia, Slovenia, and Switzerland in all building applications, irrespective of the use. Moreover, flame 

retardants are used to reduce fire risk for warehouses containing EPS before use in buildings/packaging. Fire 

regulations and international standards govern the fire safety of polymer applications, but they do not require the use of 

a certain flame retardant. In Denmark and Iceland flame retarded EPS is required for use in buildings. In Italy, Portugal 

and UK flame retarded PS foams are generally used according to the industry. Flame-retarded PS foam may be used in 

some building applications in Finland, Norway, and Sweden, although it is not required. In Sweden, the industry has 

voluntarily withdrawn HBCD containing products from the market, which is possible because alternative construction 

techniques can be used, even with EPS applications.

42. The EU’s Directive on Waste Electrical and Electronic Equipment (WEEE) (2002/96/EC) requires the removal 

of plastics containing brominated flame retardants and of printed circuit boards from electrical and electronic

equipment prior to recovery and recycling.

43. HBCD has been identified by the EU as a Substance of Very High Concern (SVHC), meeting the criteria of a 

PBT (persistent, bioaccumulative and toxic) substance pursuant to Article 57(d) in the REACH regulation (ECHA 

2008b). In February 2011 HBCD was included in the European Chemicals Agency (ECHA) list of substances subject to 

authorisation under REACH. Taking effect in 2015, HBCD can no longer be used without authorisation. A proposal on 

classification and labelling of HBCD as a possible reproductive toxic substance was made within the EU (Proposal for 

Harmonised Classification and Labelling, Based on the CLP Regulation (EC) No 1272/2008, Annex VI, Part 2 

Substance Name: Hexabromocyclododecane Version 2, Sep. 2009) (KEMI 2009). The EU risk assessment committee 

(RAC) is of the opinion that HBCD should be classified as suspected to damage fertility or the unborn child (Repr.2 

HR361), and may cause harm to breast-fed children (Lact. H362) (RAC 2010).

44. In Ukraine HBCD is registered on the hazardous chemical list based on health effects. 

45. In Japan HBCD has been designated as a Monitoring Chemical Substance because of its persistence and high 

bio-accumulation under the Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. 

(commonly referred to as the Chemical Substances Control Law "CSCL"). In September 2010, Japanese Ministers of 

Health, Labour and Welfare, and of Economy, Trade and Industry and of the Environment instructed persons operating 
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the business of manufacturing or importing HBCD to conduct an Avian Reproduction Test (OECD Test Guideline 206) 

and to report the results thereof by the end of March 2014 under CSCL.

46. In the USA, the EPA anticipates proposing a significant new use rule (SNUR) under section 5(a)(2) of the Toxic 

Substances Control Act (TSCA) for the use of HBCD in consumer textiles. Such a proposal would indicate that EPA 

believes such use would constitute a significant new use. The SNUR would require persons who intend to 

manufacture, import, or process HBCD for the designated significant new use to notify EPA at least 90 days before 

commencing such use. The required notification would provide the EPA with the opportunity to evaluate the intended 

use and, if necessary, to prohibit or limit that activity before it occurs.

47. A proposal for a national ban of HBCD is currently under consideration by the Norwegian Ministry of the 

Environment (Norway 2011). Canada is currently undertaking a risk assessment of HBCD and will be considering 

control measures when that assessment has been completed, which is expected in 2011.

2. Summary information relevant to the risk management evaluation

48. HBCD may be released to air, water, soil and sediment. Release of HBCD into the environment may occur 

during production and manufacturing, processing, transportation, use, handling, storage or containment, point-source 

discharges, migratory releases from manufactured product usage and from disposal of the substance or products 

containing the substance. In Canada, HBCD has been known to be discharged into various tributaries, watersheds, 

rivers and lakes resulting in increased levels in sediments, surrounding soils and biota (Environment Canada 2010b).

49. Releases of HBCD to the environment from HBCD production have been considered small in the EU, with only 

one production facility. In the EU it was estimated that about 3 kg a year are released from the workplace plus a further 

2 kg to air and 0.1 kg to waste water. The estimated releases of HBCD to the environment during the manufacture and 

formulation of HBCD containing products were 41 kg to air, 60 kg to waste water and 35 kg to surface water per year 

in the EU RAR (ECHA 2008a). The release of HBCD from products during end use is small. Some dust containing 

HBCD will be released during the installation of EPS or XPS insulation and ultimately during the refurbishment or 

demolition of buildings containing these products. The estimated annual release to the environment was 530 kg to air, 

1,140 kg to waste water and 560 kg to surface water. According to the EU RAR, the end use releases to waste water 

and surface water are dominated by textile coatings. The use of HBCD in textiles is believed to have fallen substantially 

in recent years. The quantities of waste products sent for disposal are uncertain and it was also noted that estimated 

releases of HBCD during the consumer use of products are highly uncertain (ECHA 2008a). 

50. Releases from waste disposal are difficult to estimate because of the long lifetime of XPS and EPS once 

installed in buildings (potentially up to 100 years) combined with an increasing trend towards the recycling of electrical 

equipment. Solid waste containing HBCD may be scrap materials generated during processing operations, particulates 

released through aging and wear of end products, and disposal of products at the end of service life. Products and 

materials in landfill sites will be subject to weathering, releasing HBCD particulates primarily to soil, and to a lesser 

extent, to water and air (Environment Canada 2010b).

51. HBCD phase-out could include flame retardant substitution, resin/material substitution and product redesign 

(LCSP 2006). In addition, re-evaluating fire-safety requirements e.g. in applications where fire hazard is absent (such as 

underground applications) or otherwise eliminated would reduce the need for flame-retarded insulation materials. 

Emissions of HBCD can be reduced in processes where HBCD or articles containing HBCD are used, and during the 

waste management phase. In Sweden, the industry has voluntarily withdrawn HBCD containing products from the 

market, which is possible because alternative construction techniques can be used.

2.1. Identification of possible control measures

52. The objective of the Stockholm Convention (Article 1) is to protect human health and the environment from 

persistent organic pollutants. Under the Convention this may be achieved by listing HBCD in Annex A, with or without 

specific exemptions, possibly accompanied with detailed actions for production and certain uses of HBCD. 

53. In the Annex F process, a number of HBCD uses have been identified by Parties and Observers. For many of the 

uses alternatives are already available and currently used in many countries. These uses include production of high 

impact polystyrene (HIPS) plastic and production of flame retarded textile back-coating. Alternative flame retardants to 

HBCD in production of flame retarded expanded polystyrene are being developed and used in some regions, but they 

are not suitable for all production processes. Also, their health, safety, and environmental properties may not be well 

known. However, alternative insulation materials and technical solutions to EPS/XPS are already widely used as well 

as alternative construction methods. These uses and the potential substitutes will be further described in section 2.3. 

below.
Persistent Organic Pollutants Review Committee

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54. Emission reduction measures and use of best practices would be required in the production and manufacture for 

potential specific exemptions and exempted uses in order to reduce HBCD releases to the environment from these 

exempted uses. Significant reduction in estimated total emissions from production and first line users has been reported 

by the industry in Europe following voluntary measures.

55. In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS, XPS, HIPS, textiles) should be 

managed in an environmentally sound manner and disposed of in such a way that their POPs content is destroyed. This 

will require separation of HBCD containing articles from others upon becoming waste, and the prevention of

inappropriate waste management practices leading to recycling of the POP content. 

2.2. Efficacy and efficiency of possible control measures in meeting risk reduction goals

56. Listing HBCD in Annex A of the Convention without exemptions would effectively reduce the releases of 

HBCD. This would require either introducing alternative building techniques or insulation material to achieve fire 

safety in construction, or the industry phasing in an alternative to HBCD. 

57. Based on the submissions from Parties and Observers, there is currently a need for flame retarded insulation 

materials due to country-specific fire safety requirements in some countries. However, the safety requirements do not 

identify any specific flame retardant substances or groups of flame retardant substances that have to be used. Some 

countries have already phased out HBCD in the absence of a substitute chemical flame retardant indicating that there 

are alternative materials and techniques available on the market already. However, no viable replacement to HBCD is 

yet available commercially for flame retarded EPS and XPS production.

58. Emission control techniques at the production sites alone will not be sufficient to solve the problem HBCD is 

posing to the environment and to health, since the diffuse emissions and releases to the water reserves and sewage 

systems from the use and machining of products containing HBCD, as well as releases when becoming waste also is of 

significant concern.

59. In addition to listing HBCD in Annex A, waste management measures for materials in use should be introduced 

to ensure environmentally sound management of HBCD containing insulation materials, plastics, and textiles at the 

end-of-life stage. This would require identifying materials in which HBCD has been added when buildings are 

renovated or dismantled to facilitate destruction of the POP content in the waste and to prevent inappropriate 

management practices leading to recycling or landfilling the POP content. Recycling of HBCD can be significant. 

According to the Swiss substance-flow analysis, the proportion of HBCD recycled is higher than for material 

containing other brominated flame retardants, and the recycling percentage of HBCD used in EPS insulation was 

expected to rise from 30% in 2005 to 60% in 2010 (Geopartner 2007). In the EU in 2007, the share of EPS with flame 

retardant was 60% of the total EPS demand, and the share of XPS with flame retardant 92% of the total XPS demand 

(PlasticsEurope/Exiba 2011). In two Swiss studies on electronic and electrical appliances, vehicles and building 

materials, HBCD was found in 2% and 6% of the studied plastic component samples (BUWAL 2004, BFR 2010 - 486 

and 214 samples respectively). Another recent Swiss WEEE study, however, did not find HBCD in any of the 53 

samples analysed (EMPA 2010). 

60. Recycled products containing HBCD, including EPS and XPS boards, are potential sources of emissions in the 

same way as virgin products. Recycling operations for recovery of metals or plastics in electronic products and vehicles 

are potential sources as well. In controlled waste streams parts containing HBCD could be sorted out, but this will not 

always be technically feasible in the waste stream. Use of labelling of products or parts of products could be a valuable 

help in the process (KEMI 2006).

61. EPS has an estimated service life of approximately 30-100 years and collecting and recycling used EPS may be 

hindered due to difficulties in separating EPS containing HBCD from others. Some EPS can be recycled and used for 

the manufacture of bricks where the polystyrene is gasified and leaves a cavity in the center of the brick. In this process 

HBCD is destroyed. However, it is difficult to separate the HBCD treated PS and HIPS from their HBCD-free 

counterparts. This greatly complicates the separation of recyclable materials. 

62. Controlled incineration is one way to dispose of PS foam containing HBCD (CEFIC 2011, ECHA 2008a). The 

flame retardant decomposes in the incineration plant process. In a co-combustion study in a high temperature pilot 

facility (>900°C), the foam added substantially to the Br content in the incinerator, but did not appear to add 

significantly to the overall hazard of raw gas or emissions (APME). Experimental evidence confirms that under some 

conditions HBCD and products containing HBCD form and may release polybrominated dibenzo-p-dioxins (PBDD) 

and dibenzofurans (PBDF) during burning, even in state of the art municipal solid waste incineration facilities (APME, 

NCM 2004). However, PBDDs and PBDFs formed from HBCD waste will likely be destroyed by the very high 

operating temperatures and controlled operating conditions employed in state of the art incinerators. The incineration 

efficiency and the operating conditions of the flue gas treatment systems are of great importance to the resulting 
Persistent Organic Pollutants Review Committee

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emissions of dioxins (NCM 2004). Hence, there is potential for the release of these substances from uncontrolled burns 

and accidental fires, pyrolysis/gasification plants, recycling processes, and from incinerators that are not functioning 

well (Weber and Kuch 2003). Desmet et al. (2005) also documented the formation of bromophenols, known precursors 

of polybrominated dibenzodioxins and dibenzofurans, during combustion of flame-retarded extruded polystyrene

containing HBCD. Bromophenol formation seemed to be inherent to the flame retardant mechanism of HBCD. The 

study did not investigate the formation of brominated dioxins and furans but noted that it was highly probable that 

various brominated dioxin isomers would be formed from bromophenols.

63. State of art incineration with energy recovery is expected to be more widely available in the coming years, hence 

diverting HBCD containing materials from landfill. However, currently in many countries landfilling is the most 

common way of waste disposal, leading to HBCD containing waste accumulating in the landfills.

2.3. Information on alternatives (products and processes) where relevant

64. The POPRC has agreed that HBCD is a POP due to its long-range environmental transport and significant 

adverse human health and environmental effects such that global action is warranted

(UNEP/POPS/POPRC.6/13/Add.2). The target or aim of any risk reduction strategy for HBCD should be to reduce and

eliminate emissions and releases taking into consideration the indicative list in Annex F including technical feasibility 

of possible control measures and alternatives, the risk and benefits of the substances and their continued production and 

use. In considering any strategy for a reduction in such risks, it is important to consider the availability of substitutes in 

the sectors of concern. In this regard, the replacement of HBCD by another chemical or non-chemical alternative needs 

to take account of factors such as: 

 technical feasibility (practicability of applying an alternative technology that currently exists or is expected to

be developed in the foreseeable future)

 costs, including environmental and health costs

 risk (safety of the alternatives)

 availability and accessibility 

65. A discussion of the availability and suitability of substitutes of HBCD is provided below. 

66. There are technically feasible and commercially available alternatives to different uses of HBCD on the market, 

although not for EPS production in Europe. They include flame retardant substitution, resin/material substitution and 

product redesign. Several of them are halogen-free and are therefore considered to be better alternatives for the 

environment and health in the evaluations done (ECHA 2009, SWEREA 2010, KLIF 2010) (Table 3). However, their 

other risks may not have been fully studied.
Persistent Organic Pollutants Review Committee

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Table 3. Summary table of technically feasible and commercially available halogen-free alternatives to the use of 

HBCD (based on SWEREA 2010). 

Polymer 

materials

Applications Alternative chemicals Alternative material and 

product redesign

HIPS Housings of 

electronic 

products

Wiring parts

Arylphosphates such as:

Resorcinol bis (biphenyl 

phosphate)

Bis phenol A bis (biphenyl 

phosphate)

Polymeric biphenyl phosphate

Diphenyl cresyl phosphate

Triphenyl phosphate

Alloys of PPE/HIPS5treated 

with halogen free flame 

retardant alternatives

EPS

&

XPS

Insulation of 

foundation, walls 

and ceilings

Ground deck,

parking deck etc.

No halogen free ‘drop in’

replacement chemicals 

commercially available at 

present for all production 

processes and regions

EPS and XPS without FRs, 

using thermal barriers

Phenolic foams

Blankets (fiber batts or rolls) 

that may contain rock wool, 

fiber glass, cellulose or 

polyurethane foam

Polyester batts

Loose fills that may contain 

rock wool, fiber glass, 

cellulose or polyurethane 

foam

Textile back 

coatings

Protective 

clothing

Carpets

Curtains

Upholstered 

fabrics

Tents

Interior in public 

transportation

Other technical 

textiles

Intumescent systems6that 

contain:

a dehydrating component, 

such as 

ammoniumpolyphosphate 

(APP)

a charring component, such as 

pentaerythritol (PER)

a gas source, often a nitrogen 

component such as melamine

 

5

PPE/HIPS: alloy of polyphenylene ether and high impact polystyrene

6 Economical viability has been questioned (BSEF 2011).
Persistent Organic Pollutants Review Committee

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2.3.1 Production of high impact polystyrene (HIPS) plastic 

67. A number of alternative fire retardants are available to replace HBCD in HIPS (Table 3). They are all required to 

be used at considerably higher loadings (ECHA 2009). Deca-BDE has been widely used in HIPS and also in electronic 

wire insulation but may not be suitable for use as a substitute for HBCD due to concerns about its impact on human 

health and the environment as well as debromination to components of PentaBDE and OctaBDE. In the EU, the 

introduction of the RoHS Directive phased out the use of Deca-BDE. In the US the industry is voluntarily withdrawing 

Deca-BDE from most uses by 2013. Other chemicals that can be used as alternatives to HBCD in HIPS include both 

halogenated flame retardants used in conjunction with antimony trioxide (ATO) and halogen-free organic aryl 

phosphorus compounds. Halogenated flame retardants may also increase the toxicity of the emissions from fire (Dioxin

2010). Nevertheless, since HBCD is not widely used in HIPS, it may be reasonable to assume that the alternative flame 

retardants on the market are technically and economically feasible. 

68. In electrical products HIPS can be replaced by various alternative materials, including blends of polycarbonate / 

acrylonitrile butadiene styrene (PC/ABS), polystyrene / polyphenylene ether (PS/PPE) and polyphenylene ether / high 

impact polystyrene (PPE/HIPS) without flame retardants or with the use of non-halogenated flame retardants (Brazil 

2011, DEPA 2010) . These co-polymer blends have higher impact strength and are more resistant to burning because 

they form an insulating char foam surface when heated (DEPA 2010). 

2.3.2 Production of flame retarded textile back-coating

69. The typical concentration of HBCD in textile applications is high compared to other applications, 6 to 15% in a 

polymer (CEFIC/EFRA 2006). Several chemicals may be used as drop-in alternatives for HBCD in textile applications. 

For textile backing, alternatives to HBCD include deca-BDE, chlorinated paraffins and ammonium polyphosphates 

(ECHA 2009). Deca-BDE is not readily biodegradable, and has low bioaccumulation potential in the environment. 

Long chain chloroparaffins are reproductive toxicants to humans, show chronic toxicity with effects on liver and 

kidneys, and are potential carcinogens (ECHA 2009).

70. It is important to note, that flame-retardant use in textiles can be avoided if the material is non flammable, such 

as wool. It can also be used as barrier materials in furniture (Norway 2011). 

71. According to the submission from Japan HBCD has been replaced in fabrics used in new car models. However, 

the demand for fabrics that contain HBCD will continue for some time as such fabrics continue to be used in older 

models (Japan 2010).

2.3.3 Production of flame retarded expanded and extruded polystyrene (EPS/XPS)

72. According to the European industry there are currently no commercially or technically viable drop-in chemical 

alternatives to HBCD as a flame retardant in polystyrene foam. This is because alternative chemical flame retardants 

impair the structure and properties of the foam, making it unsuitable for use (ECHA 2009, BSEF 2011). However, 

alternative halogenated flame retardants are commercially available in the USA for EPS, where the production process 

used is different. The polystyrene industry is in the process of finding an alternative to HBCD jointly with flameretardant producers. In April 2011 Great Lakes Solutions announced investing in a facility to produce a brominated 

polymeric flame retardant suitable for EPS and XPS. Little is known about the environmental and health properties of 

these substances.

73. The HBCD industry has highlighted the main challenges in the search for alternative flame retardants as the 

following (BSEF 2011): 

a. Fire performance of the products with the flame retardant over the complete service life, which needs 

to meet existing stringent regulations in the relevant countries

b. Fit to produce foams without undermining the foam properties. In addition, once found and approved 

for fire safety and other regulatory requirements, an alternative will have to be transitioned 

throughout the complex PS insulation foam market

c. Consumer safety for the end product, which needs to be similar to HBCD in PS foams 

d. Environmental profile, which needs to be superior to HBCD. Fit to produce foams without increasing 

safety risks for workers.

74. There are also alternative insulation materials available on the market that meet the fire-safety requirements in 

many countries facilitating HBCD phase-out for this application. Alternative insulation materials to EPS/ XPS are 

available for all uses, with the exception of some demanding XPS use in moist or freeze/thaw sensitive applications in 

North America (XPSA/CPIA 2011). These alternative insulation systems have different characteristics to XPS and EPS 
Persistent Organic Pollutants Review Committee

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and may be less appropriate for some specific use scenarios or may incorporate different environmental issues such as 

increased energy costs during transportation (ECHA 2009).

Alternatives to HBCD

75. Brominated chemicals other than HBCD are commercially available as flame retardants for use in EPS 

applications in North America. These are tetrabromocyclooctane and dibromoethyldibromo-cyclohexane (LSCP 2006, 

BSEF 2011). There are also concerns about the environmental or health properties of these substances:

 Tetrabromocyclooctane is structurally related to tetrabromocyclohexane which was identified in modelling

studies as structurally similar to known Arctic contaminants and/or have partitioning properties that suggest 

that it is a potential Arctic contaminant. 

 Dibromoethyldibromo-cyclohexane is found in beluga whales in the Arctic; modelling studies identify it as 

likely to be persistent and bioaccumulative; and it was found to be a strong androgen agonist and mutagenic to 

mammalian cells in vitro.

76. The Japanese EPS industry is aiming at replacing HBCD in the production processes by the end of 2012 and also 

the industry producing XPS is working towards reduction in HBCD use by reconsidering HBCD content but also the 

need for HBCD in the product (Japan 2011). Interestingly, the European industry appears to use higher amounts of 

HBCD than North American producers to meet the fire safety requirements.

77. The first consideration would be to eliminate use of HBCD and other flame retardants in cases where no fire 

hazard exists. These uses include placement of insulation between two non-combustible wall surfaces such as stone or 

concrete and uses where insulation is placed between building foundations and soil. These design changes could be 

implemented by the end-product manufacturer (LCSP 2006). 

78. Another strategy would be to apply the flame retardancy function through the use of fire resistant coverings or 

coatings that act as thermal barriers. Thermal barriers are fire resistant coverings or coatings that separate the insulation

material from the building interior. These include: gypsum board, gypsum or cement plasters, perlite board, sprayapplied cellulose, mineral fiber, or gypsum coatings, and selected types of plywood. All these materials are currently in 

common use in domestic and commercial building construction (LCSP 2006, SWEREA 2010). Thermal barriers are 

subject to country-specific building code requirements (SWEREA 2010). 

79. By using thermal barriers it is possible to fulfil fire safety requirements in most of the uses in construction and 

buildings with EPS and XPS without a fire retardant. This has been reported to be an available alternative on the market 

by Finland, Norway, Sweden and Spain. The national fire safety requirements are achieved by the building codes 

specifying the different uses of insulation products in buildings and construction, through the use of thermal barriers

and hence the use of flame retardant is not required to achieve fire safety even when using EPS/XPS. 

Alternatives to EPS/XPS

80. Flame retarded expanded and extruded polystyrene foam (EPS and XPS) used for building insulation can also be 

replaced by alternative materials. This is a more complex approach than simple flame retardant substitution because it 

has a greater effect on overall product cost and performance. This change could be implemented by the polymer 

processor/compounder or the end-product manufacturer (LCSP 2006).

81. Types of alternative insulating materials include polyisocyanurate foams, and phenolic foams:

a. Polyisocyanurate foams include modified urethane foams that utilize chemical flame retardants such 

as tris monochloropropyl phosphate (TCMPP) and tris chloroethyl phosphate (TCEP). TCMPP is 

poorly characterized toxicologically but in the TCEP manufacturing process ethylene oxide (a 

carcinogen) is used, it appears to be a reproductive toxicant, is found in the Arctic indicating longrange transport, and is considered a carcinogen by the California Office of Environmental Health 

Hazard Assessment. Due to the chlorinated and brominated flame retardants used in the manufacture 

of polyisocyanurate insulation products, these cannot be considered to be preferable alternatives 

because of their health effects (LCSP 2006).

b. Phenolic foams are in use in roofing, cavity board, external wall board, and floor insulation. They are 

mostly used to bind glass fiber to make insulation products. One concern over their use is that 

formaldehyde, a human carcinogen, is used for making phenolic resins monomer. Formaldehyde is 

listed by the International Agency for Research on Cancer (IARC) as a known human carcinogen 

(Morose 2006). This has to be considered at the production sites, using available emission control 

techniques and safety restrictions securing the workers.
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c. Blanket insulation is as much a technical alternative as an alternative material. It is usually made of 

fiber glass or rock wool and can be fitted between studs, joists, and beams. It is available in widths 

suited to standard spacings between wall studs or floor joists. Continuous rolls can be hand cut and 

trimmed to fit various spaces. The blankets are available with or without vapour retardant facings. 

Batts with special flame resistant facing are available where the insulation will be left exposed. 

d. Fiberglass is a synthetic vitreous fiber. Loose-fill insulation is typically blown into place or sprayapplied by special equipment. It can be used to fill existing wall cavities and for irregularly shaped 

areas.

e. Reflective insulation systems include foils, films, or papers that are fitted between studs, joists, and 

beams and commonly used to prevent downward heat flow in roof applications. Common materials 

include foil-faced paper, foil-faced polyethylene bubbles, foil-faced plastic film, and foil-faced 

cardboard.

f. Other commonly used insulation materials include polyester batts and sheep wool which can be fitted 

between studs, joists, and beams.

82. Technical alternatives to HBCD containing EPS/ XPS include: blown-in or spray-applied insulation materials 

such as rock wool, fiber glass, cellulose, or polyurethane foam. Loose-fill cellulose insulation is commonly 

manufactured from recycled newsprint, cardboard, or other forms of waste paper. The blown-in loose-fill insulation can 

provide additional resistance to air infiltration if the insulation is sufficiently dense. Loose-fill insulation can also be 

poured in place by using materials such as vermiculite or perlite. These materials are produced by expanding naturally 

occurring minerals in a furnace (LCSP 2006).

83. When alternative building insulation materials or EPS and XPS without flame retardants are used the necessary 

flame protection can be provided by use of a thermal barrier. Thermal barriers are fire resistant coverings or coatings 

that separate the insulation material from the building interior. Thermal barriers can be used to increase the fire 

retardant performance for various types of insulation. Thermal barriers are subject to current building code 

requirements. Commonly used thermal barriers include: gypsum board, gypsum or cement plasters, perlite board,

spray-applied cellulose, mineral fiber, or gypsum coatings, and select plywood’s. By using thermal barriers it is 

possible to fulfil fire safety requirements in most of the uses in construction and building applications using EPS and 

XPS without a flame retardant. This has been reported to be an available alternative on the market by Norway, Sweden 

and Spain (SWEREA 2010).

84. Fiberglass, glass wool, and mineral wool are considered synthetic vitreous fibers. They also may have 

occupational health effects. When these fibers are suspended in air they can cause irritation of the eyes, nose, throat, 

and parts of the lung. Animal studies show that repeatedly breathing air containing synthetic vitreous fibers can lead to 

inflammation and fibrosis of the lung. (ATSDR 2004). Protective clothing and equipment (face masks, goggles, gloves

etc.) is available and used by construction workers to avoid irritations from contact and breathing in the fibres. This will 

only be of importance in the working environment, since the fibrous material is built inside the wall, foundation and 

ceilings in the buildings and constructions.

2.4. Summary of information on impacts on society of implementing possible control measures

85. As the persistent, bioaccumulative and toxic properties of HBCD as well as its potential for long-range 

transboundary transport were shown in the risk profile agreed by the POPRC of the Stockholm Convention, a positive 

impact on globally sustainable development from an elimination of HBCD is to be expected. If production and use of 

HBCD with persistent, bioaccumulative and toxic properties is not managed, and were to continue or increase, then 

levels in the environment including in humans and animals will likely continue to rise, even in locations distant from 

production and use.

2.4.1. Health, including public, environmental and occupational health

86. A positive impact on human health and on the environment can be expected from reduction or elimination 

control measures on HBCD on a global scale, especially in relation to blood levels. In humans HBCD is found in blood, 

plasma and adipose tissue. The main sources of exposure presently known are contaminated food and dust. Imposing 

control measures would likely ensure that the levels of HBCD in agricultural products like farmed (and wild) fish, 

milk/milk products and various meat products level off. In the short term, the most positive effect would be anticipated 

to be on the indoor environment; with HBCD levels in dust being completely eliminated or dramatically reduced as a 

consequence of a ban. A positive outcome of this would be reduced exposure to humans, particularly children, who 

have been shown to ingest more dust than adults (UNEP/POPS/POPRC.6/13/Add.2). 

87. Though information on the human toxicity of HBCD is to a great extent lacking, embryos and infants have been 

identified as vulnerable groups that could be at risk (UNEP/POPS/POPRC.6/13/Add.2, RAC 2010), particularly due to 
Persistent Organic Pollutants Review Committee

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the observed neuroendocrine and developmental toxicity of HBCD observed in animal studies. Phase-out or elimination 

of HBCD would also be particularly beneficial to Arctic indigenous peoples who depend on traditional native foods and 

therefore are at much greater risk of exposure than other communities. The particular risks posed by POPs to Arctic 

ecosystems and indigenous communities are acknowledged in the preamble to the Convention. 

88. In developing countries, electrical and electronic appliances containing HBCD and other toxic substances are 

often recycled under conditions which result in a relatively high release of HBCD to the environment and 

contamination of the sites (Zhang et al., 2009), and exposure of workers (Tue et al., 2010). Open burning and dump 

sites are common destinations for HBCD-containing articles and electronic wastes (Malarvannan et al., 2009, Polder et 

al., 2008).

89. HBCD and other brominated flame retardants (BFRs) may also increase fire toxicity and lower survival by 

augmenting the release of carbon monoxide and soot and production of halogenated dibenzodioxins and dibenzofurans 

(see Dioxin (2010). The prevalence of certain kinds of cancer in fire fighters may be linked to an elevated exposure to 

brominated and chlorinated dioxins and furans and this warrants further attention. The overall fire safety benefit of 

regulations requiring flame retardants has been questioned since they can increase the release of toxic gases and soot 

which are the cause of most fire deaths and injuries (DiGangi et al 2010, Stec & Hull 2010). Combustion of materials 

containing HBCD or other halogenated flame retardants during accidental fires and burning flame-retarded waste 

increases the toxicity of fire effluents by increasing the release of carbon monoxide, acid gases such as hydrogen 

bromide, and brominated and chlorinated dioxins and furans (Shaw et al 2010). An overall reduction of flame-retarded 

materials may therefore lead to a smaller risk of health problems for the general public and fire fighters, if fire safety 

can be achieved by other means. 

2.4.2 Biota (biodiversity)

90. A positive impact on biota from a ban of HBCD can be expected. The scientific literature has identified that 

HBCD is very toxic to aquatic organisms. In avian species, data from recent studies report effects such as reduced 

eggshell thickness, growth and survival. Further indications for concern come from recent preliminary data obtained 

with captive American kestrels which suggest a risk for reproductive and developmental effects also in wild birds in 

remote regions (UNEP/POPS/POPRC.6/13/Add.2).

2.4.3 Economic aspects, including costs and benefits for producers and consumers and the distribution of costs 

and benefits 

91. The cost for developing countries of a phase out of HBCD uses should be limited, as the majority of the HBCD 

use takes place in Europe. According to BSEF, a ban of HBCD in the absence of a drop-in alternative would severely 

harm the EPS and XPS industry in Europe and drastically impact the economics also for non-HBCD containing PS 

foam. In addition, specialized waste management and disposal related to HBCD (buildings and articles) could be costly 

for both developed and developing countries. According to information from XPSA and CPIA a ban of HBCD would 

prevent the use of XPS products containing the substance, end the current practices of the XPS industry in the US and 

Canada, and cause difficulties since for many applications XPS is the only product recommended and accepted by 

current building codes. The recent progress in finding a polymeric chemical alternative, although brominated, may 

alleviate these concerns.

92. Emission reduction measures and use of best practices would be required in the production for potential specific 

exemptions and use therein to reduce HBCD releases to the environment from these uses. European HBCD and 

polystyrene manufacturers have in 2006 initiated emission reduction programmes, which are targeted at eliminating 

emissions from first line users of HBCD (Self-Enforced Control of Use to Reduce Emissions (SECURE) and Voluntary 

Emissions Control Action Programme (VECAP)). Most of the European PS foam industry implements those risk 

reduction measures (EBFRIP 2009a). Implementing best practices in handling reduced the total potential releases from 

2,017 kg/year in 2008 to 309 kg/year in 2009 in the survey. The costs of emission reduction programmes initiated by 

European HBCD and polystyrene manufacturers are highly dependent on the company operations (BSEF 2011). Also 

the Japanese curtain and blind industry has developed a coagulation-sedimentation method in the dyeing process to 

reduce HBCD emissions to water (Japan 2011).

93. In accordance with Article 6(1)(d)(ii), HBCD containing products (EPS, XPS, HIPS, textiles) should be 

managed in an environmentally sound manner and disposed of in such a way that their POPs content is destroyed or 

irreversibly transformed so that they do not exhibit the characteristics of POPs. This will require separation of HBCD 

containing articles from others upon becoming waste and the prevention of inappropriate waste management practices 

leading to recycling of the POP content.

94. For drop-in chemical substitutes, two main types of costs have to be considered concerning the switch from one

flame retardant to another (SWEREA 2010);
Persistent Organic Pollutants Review Committee

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a. The switching cost, which is the cost of reformulation, in other words the cost of the development 

work or equipment change. Manufacturing and processing facilities may need to invest in new 

equipment in order to shift to alternative flame retardants. This cost is difficult to estimate, and 

usually contains the cost of those research and development endeavours which did not succeed in 

finding an efficient flame retardant alternative. This is a cost which is generated at the beginning of a 

product life cycle.

b. The operating cost which reflects the price of the flame retardant (raw) material cost. In addition, 

daily operation costs may be different for the new process steps required to manufacture other flame 

retardant chemicals. To ensure economic viability, flame retardants must be easy to process and costeffective for what most of the time high-volume manufacturing conditions are necessary. The costs of 

manufacturing are heavily dependent on the costs of raw materials, but the degree of this dependency 

varies among the flame retardants. 

95. Following this, the PS foam industry must adapt to the new flame retardant alternatives. In spite of those costs 

mentioned above, movement to alternatives already exists implying that the costs are acceptable and not critical, 

although not yet fully known.

96. A ban on HBCD can have consequences for EPS and XPS producers in relation to the workforce in this sector 

(Plastics Europe/Exiba 2011, XPSA/CPIA 2011). In 2003 the EPS sector group and the European XPS producers in 

Europe initiated projects to find alternatives to HBCD for use in EPS and XPS and to share the costs connected with the 

development of new alternatives with the flame retardant producers (HBCD industry working group 2009). At this time 

HBCD was undergoing risk assessment under the Existing Substance Regulation (EC) 793/93 in the EU, and the 

manufacturers of EPS and XPS were highly concerned about the outcome of the environmental profiling, the future 

regulatory situation and the resulting impact on producers and users (HBCD Industry Working Group 2009). The 

HBCD industry working group reported to the UNECE/CLRTAP process in 2010 that current estimations from the two 

projects underway were that an alternative would be available on the market in 5-10 years. This included the 

registration of the alternatives under REACH in the EU.

97. In North America the major brominated flame retardant manufacturers (Albemarle, Chemtura Corporation and 

ICL-IP) have formed alliances with other companies (forming the North American Flame Retardant Alliance (NAFRA) 

under the umbrella of ACC) to promote and defend a broad range of flame retardants. The three companies have 

inorganic phosphor based flame retardants in their portfolio in addition to the brominated flame retardants. Other 

brominated flame retardants for use in EPS are already on the United States market as alternatives to HBCD (LCSP 

2006). They are however not applicable to the European industry which uses different processes for manufacture of 

EPS and XPS. However, there is a recent announcement by Great Lakes Solutions on preparations to start production of 

a directly applicable alternative to HBCD.

98. EPS and XPS insulation boards are most often covered by other materials in buildings and constructions. Using 

thermal barriers will not represent an extra cost, since thermal barriers used are common materials and relatively cheap. 

EPS and XPS without flame retardants are commercially and technically feasible alternatives today and do not 

represent a higher cost to the manufacturer. The market in Scandinavia is dominated by polystyrene boards without 

flame retardants. This is accomplished by fire safety regulations not requiring treatment with a flame retardant, 

acquiring the same level of protection through other means and relies to a lesser extent on flame retardants (SWEREA 

2010). In this region, only producers manufacturing EPS and XPS for export, like in Norway, will be affected by a ban 

on HBCD.

99. Consequences for the elimination of HBCD through legislation will influence markets with a substantial 

production and use of HBCD flame retarded EPS insulation boards (Europe), but to a lesser extent markets that are less 

dependent on HBCD due to use of other processes of EPS manufacture using other brominated flame retardants (the 

US). As there are currently no known chemical alternatives for XPS, HBCD elimination will affect production of flame 

retarded XPS in all regions, unless a suitable alternative can be phased in in a timely manner. The ongoing initiatives in 

the polystyrene foam sector to find alternatives for use of HBCD (North America and Europe) are accomplished by 

sharing the costs and investments in voluntary projects between the flame retardant producers and the polystyrene foam 

manufacturers (HBCD Industry working group 2009). For regions where HBCD is largely phased out (Scandinavia) the 

cost will be low. Conclusively, the cost implications for producers are considered to be low to moderate, and a switch to 

other flame retardants will stimulate some producers (KLIF 2010). 

100. Increase in cost for manufacturers of HIPS and textile coatings is expected to be low since substitutes are 

already in use. For the EU, the total incremental costs at the production level of replacing the HBCD in HIPS in all EEE 

have been estimated in the range of 1-10 million €/year if HBCD is replaced with other brominated flame retardants

and 5-25 million €/year if the HIPS/HBCD is replaced by copolymers with non-halogenated flame retardants. The costs 

may decrease over the years as a result of a larger market for the alternatives (DEPA 2010).
Persistent Organic Pollutants Review Committee

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101. In controlled burning of waste, the control measures and application of BAT/BEP to address other by-products 

from incineration reduce by-product emissions of HBCD and brominated dioxins and furans. There are no extra costs 

involved for the industry.

102. Flame-retardants that are either more expensive per kg or require more flame retardant per unit polymer mass (or 

volume) to meet the fire safety standards will increase the raw material costs. Large differences between flame 

retardant chemicals’ prices do not necessarily have any impact on relatively expensive end products (SWEREA 2010). 

When used as an additive in PS foams, HBCD total content by weight varies between 0.5% (EPS) and 2.0% (XPS) 

(XPSA/CPIA 2011, CEFIC 2011). 

103. In several countries in the EU the fire safety requirements are performance based. HBCD or any other flame 

retardant are not required to fulfil the fire safety regulations, but if non-flame retarded EPS/XPS boards are used the 

fire-safety requirements call for structural applications where the fire-safety is achieved with non-combustible barrier 

material. In some countries lining of walls and roofs needs flame retarded polystyrene foam if used. Usually other 

insulation materials are used for this purpose. In a few European countries only special applications require polystyrene 

foam to be treated with a high performance flame retardant. In other countries retarded EPS and XPS is used due to 

storage and insurance reasons and not due to the fire safety regulations. Several countries have stringent fire safety 

requirements on the insulation boards themselves used in buildings and constructions and in those countries EPS and 

XPS have to be treated with a flame retardant such as HBCD. 

104. For several countries the use of EPS and XPS without flame retardants will require an adjustment of policies and 

a change in the way of implementation of fire safety standards. This will take time, and costs are considered to be 

moderate. In the EU there are already initiatives to harmonize the fire safety regulation standards, and HBCD is on the 

indicative list of hazardous substances that should be avoided for use for fire protection in buildings and constructions. 

This would also be an important drive to change the fire regulations, from classifying the building materials as 

components of the construction elements, to classifying the construction elements themselves. (KLIF 2010).

2.5. Other considerations

105. For more information about industry innovations regarding HBCD alternatives please see the following 

websites:

http://chemtura.investorhq.businesswire.com/press-release/company-news/chemtura-corporation-first-sign-licenseagreement-dow-chemical-company-po

106. The industry voluntary actions to reduce emissions of HBCD in Europe are described at:

 http://www.bsef.com/our-substances/hbcd/voluntary-emissions-reduction-programme-vecap-and-secure

 http://www.vecap.info/

107. More information about product redesign and fire safety is available at:

www.sp.se/en/index/services/greenflame. The Green Flame is a voluntary system for simultaneously assessing 

products, in relation to environment and health quality, when involved in fires. It is open for all kinds of different 

products and will create incentives for manufacturers who design products that perform better than the standards 

applicable to them. The intention is that the Green Flame system will provide competitive advantages to the 

companies that possess the competence and determination to develop consumer products that represent a major 

improvement in fire safety and environmental quality. 

108. HBCD monitoring information is available from Europe, North America and Asia. To follow the effectiveness 

of the potential actions, HBCD should be added to the existing POP monitoring activities.

3. Synthesis of information

3.1 Summary of risk profile information

109. The commercially available brominated flame retardant hexabromocyclododecane (HBCD) is lipophilic, has a 

high affinity to particulate matter and low water solubility. Depending on the manufacturer and the production method 

used, technical HBCD consists of 70-95% γ-HBCD and 3-30 % of α- and β-HBCD. HBCD is used as a flame retardant 

additive in polystyrene and textile products. Its main use is in the production of expanded and extruded polystyrene 

(EPS and XPS). It is also used in the production of high impact polystyrene (HIPS) and as a textile coating. HBCD is 

reported to be produced in the United States of America, Europe, and Asia. Approximately half of the market volume is 

used in Europe. 

110. In biota, HBCD has been found to bioconcentrate, bioaccumulate and to biomagnify at higher trophic levels. 

High concentrations have been identified in Europe and Japan and in coastal waters of south China, near production 
Persistent Organic Pollutants Review Committee

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sites of HBCD, manufacturing sites of products containing HBCD and waste disposal sites including those whose 

processes include either recycling, landfilling or incineration. 

111. HBCD is persistent in the air and is subject to long-range transport. HBCD is found to be widespread in remote 

regions such as the Arctic, where concentrations in the atmosphere and top predators are elevated.

112. HBCD is very toxic to aquatic organisms. In mammals, studies have shown reproductive, developmental and 

behavioural effects. Recent advances in the knowledge of HBCD-induced toxicity includes a better understanding of 

the potential of HBCD to interfere with the hypothalamic-pituitary-thyroid (HPT) axis, its potential ability to disrupt 

normal development, and to affect the central nervous system. 

113. In humans HBCD is found in blood, plasma and adipose tissue. Human breast milk data from the 1970s to 2000 

show that HBCD levels have increased since HBCD was commercially introduced as a brominated flame retardant in 

the 1980s. 

3.2 Summary of risk management evaluation information

114. HBCD is produced in China, Europe, Japan, and the USA. The known current annual production is 

approximately 23,000 tonnes per year (9,000 to 10,000 tonnes in China, 13,426 tonnes by the BSEF companies in 

Europe and the US, Japan not known). The main share of the market volume is used in Europe. HBCD has been on the 

world market since the 1960s. It is used as a flame retardant additive, with the intent of delaying ignition and slowing 

subsequent fire growth during the service life of vehicles, buildings or articles, as well as while materials are stored. 

The main uses of HBCD globally are in flame-retarded expanded (EPS) and extruded (XPS) polystyrene foam 

insulation, while the use in textile applications and electric and electronic appliances (HIPS) is of a smaller scale. The 

use of HBCD in insulation boards started in the 1980s. In textiles HBCD is used in back-coating used for upholstery 

furniture and other interior textiles, including automotive applications.

115. A number of alternative fire retardants are available to replace HBCD in HIPS and textile back-coating. 

However, there are no drop-in chemical alternatives for certain flame-retarded EPS/XPS production. In some countries 

there is a need for flame retarded insulation materials due to the country-specific fire safety requirements. In some

countries HBCD has effectively already been phased out. In those countries the fire safety regulations do not require 

treatment with a flame retardant, and the same level of fire safety is achieved by other alternatives, that are technically 

feasible and also commercially available. HBCD phase-out could include flame retardant substitution, resin/material 

substitution and product redesign. Emissions of HBCD can be reduced in the processes where HBCD or articles 

containing HBCD are used, and during the waste management phase.

116. HBCD may be released to air, water, soil and sediment during all stages of its life cycle; production and 

manufacturing, processing, transportation, use, handling, storage or containment, point-source discharges, migratory 

releases from manufactured product usage and from disposal of the substance or products containing the substance.

European producers and manufacturers have successfully taken measures to reduce emissions from production and first 

line use. Emission control techniques at the production sites will not prevent HBCD emissions, since there are diffuse 

emissions and releases to the water reserves and sewage systems from products containing HBCD during use or upon 

becoming waste.

117. HBCD is an intentionally produced industrial chemical. Under the Convention, the most adequate control 

measure is listing in Annex A. To allow for certain time-limited critical uses of HBCD, a specific exemption for use of 

HBCD could be given together with a description of the conditions for production and these uses. Wastes containing 

HBCD are a concern because they will represent a large source of releases and because increasing amounts of HBCDcontaining wastes in landfills and other locations could be a long-term source of HBCD emissions. Wastes containing 

HBCD include production wastes, insulation boards, building and renovation wastes, and from other less-commonly 

used applications such as electrical and electronic products and textiles. The process of remodelling and demolition of 

buildings leads to concerns that installed building materials containing HBCD will continue emissions in the future, 

unless properly managed by future generations. Stockpiles and waste containing HBCD would be subject to the 

provisions in Article 6.

3.3 Suggested risk management measures

118. Listing HBCD in Annex A of the Convention would prohibit the manufacture, use, import and export of HBCD 

(except as allowed under the Convention for environmentally sound disposal) and could be linked with specific 

exemptions that specify deadlines for the eventual elimination of remaining HBCD manufacturing and use. Such listing 

could also be coupled to other decisions that would describe in more detail such uses of HBCD and appropriate 

conditions for their manufacturing and use. When assessing whether specific exemptions would be appropriate, among 

other considerations identified in Annex F to the Convention, factors such as exposure; production volume; and societal 

costs and the ubiquitous contamination of humans, the environment and possible impact on future generations should 

be considered.
Persistent Organic Pollutants Review Committee

20

119. The suggested control measure is that HBCD be listed in Annex A, with or without specific exemptions, and if 

with exemptions accompanied with detailed conditions for HBCD uses.

120. Listing of HBCD in Annex A would be consistent with the POPs properties of this intentionally produced 

substance. Such a listing would send a clear signal that production and use of HBCD must be phased out. Such a listing 

may have implications for countries in light of ongoing uses where alternative substances or alternative methods need 

to be phased in. Stockpiles and waste containing HBCD would be subject to the provisions in Article 6.

4. Concluding statement

121. Having decided that hexabromocyclododecane (HBCD) is likely, as a result of long-range environmental 

transport, to lead to significant adverse effects on human health and/or the environment such that global action is 

warranted;

122. Having prepared a risk management evaluation and considered the management options;

123. The Persistent Organic Pollutants Review Committee recommends, in accordance with paragraph 9 of Article 8 

of the Convention, the Conference of the Parties to the Stockholm Convention to consider listing and specifying the 

related control measures of hexabromocyclododecane and 1,2,5,6,9,10 -hexabromocyclododecane in Annex A as 

described above.
Persistent Organic Pollutants Review Committee

21

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Persistent Organic Pollutants Review Committee

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