PROPOSAL FOR A COUNCIL DIRECTIVE AMENDING DIRECTIVE 76/769/EEC ON THE APPROXIMATION OF THE LAWS, REGULATIONS AND ADMINISTRATIVE PROVISIONS OF THE MEMBER STATES RELATING TO RESTRICTIONS ON THE MARKETING AND USE OF CERTAIN DANGEROUS SUBSTANCES AND PREPARATIONS
Date: 1991-01-28
Institutions: European Commission
Subjects: approximation of laws, chemical product, health risk, plastics, toxic substance

COMMISSION  OF  THE  EUROPEAN  COMMUNITIES 

C0M(91)  7  f i n al  -  SYN  325 

Brussels,  28  January  1991 

Proposal  for  a 

COUNCIL  DIRECTIVE 

amending  Directive  76/769/EEC on the approximation of the 

laws, regulations and administrative provisions of the 

Member  States  relating  to restrictions on the 

marketing and use of certain  dangerous 

substances and  preparations 

(presented by the  Commission) 

-  1  -

EXPLANATORY  MEMORANDUM 

1.  INTRODUCTION 

In  May  1989  the  German  authorities  communicated  to  the  Commission 
their  concern  about  dangers  posed  to  human  health  and  the 
environment  by  a  family  of  chemicals  known  as  poIybromobIphenyI 
ethers  (PBBE'S)  which  are  used  as  flame  retardants  In  certain 
p l a s t i c s.  They  further  Invited  the  Commission  to  take  the 
Initiative  at  Community  level  and  propose  a  way  to  solve  the 
problems  posed  by  PBBE'S.  The  Commission  studied  the  rationale 
provided  by  the  German  authorities  and  subsequently  announced  Its 
Intention  to  propose  Community  measures  covering  the  PBBE  family. 

The  Commission,  having  taken  Into  account  the  available 
Information,  Is  now  proposing  to  Introduce  Community  measures 
restricting  the  marketing  and  use  of  PBBE'S  by  -sans  of  a 
modification  to  Directive  7 6 / 7 6 9 / E E C. 

The  Commission  considers  that  this  proposal  Is  consistent  with 
the  high  level  of  protection  required  under  the  Treaty.  The 
rationale  underlying  the  Commission's  proposal  Is  given  below. 

2.  HISTORICAL  BACKGROUND 

The  ever  Increasing  use  of  plastic  materials  presents  a  special 
challenge  to  the  control  of  fire.  This  challenge  has  been  met 
effectively  by  Incorporating  flame  retardant  formulations  In 
plastics  likely  to  be  so  exposed  (about  1  %  of  all  p l a s t i c s ): 

Various  types  of  flame  retardants  can  be  used  In  p l a s t i c s. 
Brominatea  organic  compounds  are  however  mo  muo..  »idciy  used ?.t 
present  and  within  this  group  the  PoIybromobIphényI  Ethers 
(PBBE'S)  have  In  recent  years  recorded  rapid  growth  In  most 
c o u n t r i e s.  The  PBBE'S  are  used  as  f I a m e r e t a rd a n ts  In  plastics 
finding  application  In  a  range  of  product  components  (e.g. 
housings,  electrical  c o n n e c t o r s)  and  final  products  (e.g. 
televisions,  computers,  a u t o m o b i l e s ). 

The  widespread  application  of  PBBE'S  has  occured  because  of  their 
special  p r o p e r t i e s.  The  fire  retardancy  action  of  PBBE 
formulations  Is  particularly  effective  as  it  Is  available  at  the 
optimum 
PBBE's  need  be  present  only  In  small  amounts  and  thus  Impair  to  a 
minimum  extent  the  original  properties  of  the  p l a s t i c. 

temperature  for  effective  fire  c o n t r o l.  In  addition 

-  2 -

Production  of  PBBE's  In  Western  Europe  amounted  to  several 
thousand  tonnes  In  1989,  having  fallen  slightly  from  1936  levels. 
By  contrast  Imports  of  PBBE's  Into  the  Community  have  risen 
significantly  since  1986  and  now  exceed  EC  production  by  a 
considerable  margin.  An  unknown,  but  certainly  very  large  amount 
of  PBBE  reaches  the  Community  through  imports  of  plastics  and  of 
goods  containing  plastics  e.g.  TV's,  cars,  a Ircraft .etc. 

The  recent  fall  In Community  production  Is  the  result  of  concerns 
about  the  dangers  to  health  posed  by  PBBE's. Most  worrying  Is  the 
Into  the  atmosphere  of  toxic  chemicals  known  as 
release 
poIybromodIbenzofurans 
plastics 
containing  PBBE'S  are  exposed  to  heat  (e.g.  In  plastics 
processing,  accidental  fires,  municipal  Incineration). 

(furans 

short) 

when 

for 

3.  INFORMATION  ON  THE  SUBSTANCES  COVERED  BY  THIS  PROPOSAL 

3.1.  Genera I. 

The  PBBE  family  Includes  the  following 
I.e. 

M 

«  « 
" 

DecabromobIphenyI  Ether 
Nona  « 
Octa  M 
Septa-
Hexa  M 
Penta" 
Tetra" 
T.  I 

II 

II 

M 

H 

H 

Q  I 

H 

N 

H 

II 

BromobIphenyI  Ether 

homologue 
CAS  1163-

s 
19-5) 
-56-1) 
-52-0) 
-80-3) 
-60-0) 
-81-9) 
-47-9) 
-94-0) 
47-7) 
5-3) 

"  63936 
M  32536 
"  689 2 8 
"  36483 
32534 
M  40088 
"  49690 
"  2050-
"  101-5 

Of  these,  only  the  penta,  octa  and  deca  varieties  are  used 
commercI a I 1 y. 
However,  while  no  commercial  use  Is  known  of  the  seven  other 
homologues  there  Is  at  present  no  legal  Impediment  to  their 
marketIng  and  use . 

Within  the  Community  several  companies  have  already  ceased  PBBE 
production  though  three  producers  remain.  The  PBBE'S  find 
application  In some  sixteen  distinct  types  of  resin  and 
polymer  : 

-  3 -

Res 1n/substrate  : 

Use  of 

Deca-BBE 

Octa-BBE 

Penta-BBE. 

Other  homo I. 

1.  ABS* 
2.  Epoxy  Resins 
3.  Pa Ints/Iacquers 
4.  PhenoI Ic Res Ins 
5.  PolyacryIon I tr I le 
6.  Polyamide 
7.  PBT** 
8.  Polyethylene 
9.  PET*** 
10.  Polypropylene 
11.  PoIystyrene 
12.  PVC 
13.  Polyurethane 
14.  Rubber 
15.  Text I les 
16.  Polyesters 

x 
X 
X 
X 
X 
X 
X 
X 
X 
X 
X 

X 
X 
X 

A c r y l o n l t r l l e - B u t a d l e n e - S t y r e ne 
P o l y b u t y l e ne  T e r e p h t ha I ate 

* 
** 
***  P o l y e t h y l e ne  TerephthaI ate 

X 

X 
X 

X 

X 
X 

X 
X 
X 

X 

The  deca  h o m o l o g ue  Is  produced  In  the  largest  v o l u m es  and  finds 
most  w i d e s p r e ad  a p p l i c a t i o n. 

3.2.  P r o p e r t i es  of  the  s u b s t a n c e s. 

T o x I c I t y. 

The  deca  h o m o l o g ue  a p p e a rs  to  have  no  u n d e s i r a b le  t o x l c o l o g l ca 
e f f e c t s. 
Acute  toxicity  tests  have  shown  that  octa  too  Is  n o n - t o x i c. 
However  a n i m a ls  subjected  to  long  term  e x p o s u re  to  very  high 
doses  of  octa  have  suffered  c o m p o u n d - r e l a t ed  liver  and  thyroid 
e f f e c t s. 

-  4  -

P e n ta  Is  a  s l i g ht  e ye  I r r i t a nt  and  h as  s i m i l ar  liver  and  t h y r o id 
e f f e c ts  to  o c t a. 
It  Is  c o n c l u d ed  that  t he  c o m m e r c i a l ly  I m p o r t a nt  P B B E 'S  p r e s e nt  a 
small  h a z a rd  In  t e r ms  of  t o x i c i t y . W h at  risk  that  e x i s ts  Is 
l a r g e ly  c o n f i n ed  to  t he  w o r k p l a ce  w h e re  P B B E 'S  a re  p r o d u c ed  and 
c o m p o u n d e d.  T h e re  Is,  a p p a r e n t l y,  no  d a n g er  to  t he  p u b l ic  In 
h a n d l i ng  p l a s t i cs  c o n t a i n i ng  P B B E ' S. 

E n v I r o n m e n t. 

D e ca  h as  no  u n d e s i r a b le  e n v i r o n m e n t al  e f f e c t s. 

M i n i m al  b i o c o n c e n t r a t i on  h as  b e en  r e c o r d ed  In  t he  c a se  of  o c t a. 

T r a c es  of  p e n ta  h a ve  b e en  I d e n t i f i ed  In  c e r t a in  r i v er  s e d i m e n ts 
and  In  s o me  m u s s el  and  cod  s a m p l e s. 

W h i le  t he  U n i t ed  S t a t es  E PA  h as  r e c o m m e n d ed  f u r t h er  t e s ts  on  the 
c h e m i c al  f a te  and  e n v i r o n m e n t al  e f f e c ts  of  t he  t h r ee  c o m m e r c i al 
P B BE  h o m o l o g u e s,  t h e re  Is  l i t t le  e v i d e n ce  at  p r e s e nt  of  d a n g e rs 
to  t he  e n v i r o n m e nt  t h r o u gh  a c c u m u l a t i on  of  P B B E ' S. 

E x p o s u re  to  the  h e a t. 

V e ry  h i gh  q u a n t i t i es  of  d l o x l ns  and  f u r a ns  h a ve  b e en  d e t e c t ed 
d u r i ng  p y r o l y se  In  t he  l a b o r a t o ry  of  t he  p u re  f l a me  r e t a r d a n t s, 
e s p e c i a l ly  t h o se  c o n t a i n i ng  p e n t a. 

S m a l l er  q u a n t i t i es  of  f u r a ns  I n c l u d i ng  m i n u te  t r a c es  of  the  very 
toxic  2,3,7,8  tgtràbrûiïiûuluoiù^iUi an  *<«.«  L » _ :. _" _':?*•-• ^  !n  the 
p r o d u c ts  of  c o m b u s t i on  w h en  p l a s t i cs  c o n t a i n i ng  P B BE  art»  b u r n a d. 
H o w e v er  t h e se  c o m b u s t i on  p r o d u c ts  g a ve  no  c l i n i c al  slrjnt-  of 
tox I c I ty  In  an I ma I s . 

M e a s u r m e n ts  at  the  w o r k p l a ce  h a v e,  h o w e v e r,  s h o wn  that  f u r an 
e m i s s i o ns  p o se  a  c e r t a in  r i s k.  E x p o s u re  s t u d i es  In  p l a s t ic 
p r o c e s s i ng  p l a n ts  h a ve  c o n f i r m ed  f u r an  c o n c e n t r a t i o ns  w h en 
p l a s t i cs  a re  w o r k ed  at  h i gh  t e m p e r a t u re  (at  t he  e x t r u d er  h e a d ). 
T he  e x i s t e n ce  of  risk  Is  c o n f i r m ed  by  t he  I n t e r im  r e s u l ts  of  o ne 
s e r i es  of  e p i d e m i o l o g i c al  s t u d i e s. 

-  5  -

R i s ks  a s s o c i a t ed  w i th  n o n-  p r o f e s s i o n al  e x p o s u re  w o u ld  s e em  to  be 
s l i g h t.  T e s ts  h a ve  I n d i c a t ed  that  t h e re  Is  no  r i sk  to  the  TV 
v i e w i ng  p u b l ic  a r i s i ng  f r om  f u r an  e m i s s i o ns  and  it  h as  yet  to  be 
e s t a b l i s h ed  w h e t h er  any  r i sk  is  p o s ed  by  the  p r o d u c ts  of 
a c c i d e n t al  f i r e s.  As  far  as  w a s te  d i s p o s al  by  I n c i n e r a t i on  Is 
c o n c e r n e d,  h a z a rd  a s s e s s m e nt  c a l c u l a t i o ns  h a ve  s h o wn  a  b !g 
p o t e n t i al  for  f u r an  r e l e a se  t h o u gh  t h is  h as  not  b e en  c o n f i r m ed  by 
a c t u al  e m i s s i on  m e a s u r e m e n t s. 
It  s t i ll  r e m a i ns  to  be  s h o wn  w h e t h er  b r o m o d I b e n z o f u r a ns  or 
b r o m o d l o x l ns  a re  p r e s e nt  In  the  e n v i r o n m e n t. 
It  d o es  s e em  f r om  the  a v a i l a b le  e v i d e n ce  that  p l a s t i cs  c o n t a i n i ng 
P B B E 'S  d o,  w h en  s u b j e c t ed  to  h e a t,  p o se  a  t h r e at  to  h u m an  h e a l t h. 

3 . 3.  E x i s t e n ce  of  a l t e r n a t i v e s. 

S u b s t i t u t es  for  P B B E 's  m u st  be  J u d g ed  In  t e r ms  of  v a r i o us 
c r i t e r i a.  F i r st  and  f o r e m o st  t h ey  m u st  a l l ow  c u r r e nt  f i re 
s t a n d a r ds  to  be  r e s p e c t e d.  T h ey  m u st  a l so  be  s a f er  t h an  P B B E 's  In 
t e r ms  of  p r o t e c t i on  of  h e a l th  and  the  e n v i r o n m e n t.  In  a d d i t i on 
t h e re  a re  m a ny  p r a c t i c al  c o n s t r a i n t s;  for  e x a m p l e,  t h ey  m u st 
impair  the  m a n u f a c t u re  and  p e r f o r m a n ce  of  p l a s t ic  g o o ds  nor 
s h o u ld  t h ey  be  e x c e s s i v e ly  e x p e n s i v e. 

not 

W h i le  s o me  c a n d i d a te  s u b s t i t u t es  h a ve  a l r e a dy  b e en  I den t I f 
h as  not  yet  b e en  s h o wn  c o n c l u s i v e ly  that  t h ey  are  p r e f e r ab 
P B B E ' s.  For  e x a m p le  T e t r a b r o m o b I s p h e n oI  A,  w h i ch  Is  a l r e ad 
e x t e n s i v e ly  In  G e r m a ny  and  J a p a n,  m ay  a l so  lead  to  r e l e a se 
f u r a ns  as  d e s c r i b ed  for  P B B E ' s,  t h o u gh  p r o b a b ly  in  s m a l l er 
a m o u n t s.  S u b s t i t u t es  of  the  I n o r g a n ic  t y pe  m ay  not  h a ve 
s u f f i c i e nt  f l a me  r e t a r d a n cy  In  p l a s t i cs  to  a l l ow  e x i s t i ng 
s t a n d a r ds  to  be  m e t.  C l e a r ly  d e t a i l ed  h a z a rd  a n a l y s es  m u st 
c o m p l e t ed  for  the  v a r i o us  p o s s i b le  s u b s t i t u t es  b e f o re  any 
I m p o s ed  on  t he  P B B E 's  c u r r e n t ly  In  u s e. 

led  It 
le  to 
y  u s ed 

of 

f I re 
be 

ban  I s 

3 . 4.  C o ne I us I o n. 

It  Is  c o n c l u d ed  that  P B B E 's  p o se  a  t h r e at  to  h u m an  h e a l th  and  the 
e n v i r o n m e nt  w h i ch  Is  u n a c c e p t a b le  In  the  long  t e r m.  T h is  d a n g er 
a r i s es  m a i n ly  f r om  the  r e l e a se  of  f u r a ns  to  the  a t m o s p h e re  !n 
t h e r m al  e x p o s u re  of  p l a s t i cs  c o n t a i n i ng  P B B E ' S.  P B B E 'S  s h o u ld 
t h e r e f o re  be  p h a s ed  out  o n ce  s a f er  s u b s t i t u t es  c an  be  f o u n d. 

-  6  -

The  best  strategy  to  adopt  towards  this  end  Is  a  stepwise 
withdrawal  of  PBBE'S  from  the  market.  This  would  take  the  form  of 
an  Immediate  ban  on  the  seven  PBBE  homologues  not  presently  In 
commercial  use  and  on  preparations  and  products  potentially 
containing  them  and  of  an  eventual  ban  five  years  later  on  the 
three  commercially  Important  homologues  and  their  preparations 
and  p r o d u c t s. 

4.  CONFORMITY  WITH  THE  TREATY. 

As  Is  clear  from  section  3  above,  this  proposal  Is  Intended  to 
afford  a  high  level  of  protection  for  both  persons  and  the  envi 
ronment  and  is  therefore  In  conformity  with  Article  100A(3)  of 
the  Treaty. 

The  proposal  does  not  call  for  any  special  provisions  of  the  kind 
referred  to  In  Article  8c  of  the  Treaty. 

5.  CONSULTATION  OF  THE  EUROPEAN  PARLIAMENT  AND  THE  ECONOMIC  AND 
SOCIAL  COMMITTEE. 

In  compliance  with  Article  100A  of  the  Treaty,  the  cooperation 
procedure  with  the  European  Parliament  is  a p p l i c a b l e.  The 
Economic  and  Social  Committee  has  to  be  consulted. 

-  7 -

Proposal  for a 
COUNCIL  DIRECTIVE 
amending  Directive 76/769/EEC on  the approximation of the 
laws, regulations  and  administrative provisions of the 
Member  States  relating  to restrictions on the 
marketing  and use of certain  dangerous 
substances  and  preparations 

THE COUNCIL  OF THE  EUROPEAN COMMUNITIES, 

Having  regard  to  the  Treaty  establishing  the  European 
Economic  Community, and  in particular  Article  100 A thereof, 

Having  regard  to the proposal  from  the Commission,1 

In cooperation  with  the European  Parliament,2 

Having  regard  to  the  opinion  of  the  Economic  and  Social 
Commlttee,3 

Whereas  measures  should  be  adopted  for  the  progressive 
establishment  of  the  internal  market  by  31  December  1992; 
whereas  the  internal  market  is  an  area  without  internal 
frontiers  in which  the  free  circulation  of  goods, persons, 
services  and  capital  is guaranteed; 

1 0J No 
2 0J No 
3 OJ No 

-  8  -

Whereas  poIybromobipheny I  ether  used  as  fire  retardant  in 

certain  plastic  polymers  and  in  certain  plastic  products 

may,  under  the  uncontrolled  condition  of  a  fire,  during 

plastics  m a n u f a c t u r e,  during  plastics  processing  and  during 

waste  disposal  by  incineration  lead  to  the  emission  of 

poIyhalogenated  dibenzo  furans  and  poIyhalogenated  dibenzo 

dioxins  which  are  dangerous  to  man  and  to  the  e n v i r o n m e n t; 

Whereas  the  restrictions  on  the  use  of  p o I y b r o m o b i p h e ny I 

ethers  laid  down  by  this  Directive  take  into  account  the 

current  state  of  knowledge  and  techniques  regarding  safer 

subst i tutes ; 

Whereas  restrictions  planned  by  certain  Member  States  on  use 

and  marketing  of  po I ybromobiphenyI  ethers  or  p r e p a r a t i o ns  or 

products  containing  them  would  have  a  direct  effect  on  the 

establishment 

and 

functioning 

of 

the 

internal 

market; 

whereas  it  is  therefore  necessary  to  approximate  the  laws  of 

the  Member  States  in  this  field  and  thus  to  amend  Annex  I  to 

Council  Directive  7 6 / 7 6 9 / E E C4,  as  last  amended  by  Directive 

/ 

/ E E C5; 

Whereas 

present 

Community 

legislation 

concerning 

the 

possible 

adoption 

by  Member 

States  of 

more 

stringent 

restrictions  on  the  use  of  the  substances  and  preparations 

in  question 

at 

the 

workplace 

is  unaffected 

by 

this 

D i rect i ve , 

HAS  ADOPTED  THIS  DIRECTIVE 

4  OJ  No  L  2 6 2,  2 7 . 9 . 1 9 7 6,  p.  2 0 1. 

5  OJ  No  L 

-  9  -

Article  1 

Annex  I  to  Directive  76/769/EEC  is  hereby  amended  as  set  out 

in  the  Annex  hereto. 

Article  2 

Member 

States 

shall 

bring 

into 

force 

the 

laws, 

regulations  and  administrative  provisions  necessary  to 

comply  with  this  Directive  no  later  than  18  months 

after  the  date  of  its  adoption  and  shall 

forthwith 

inform  the  Commission  thereof. 

When  Member  States  adopt  these  p r o v i s i o n s,  these  shall 

contain  a  reference  to  this  Directive  or  shall  be 

accompanied  by  such  reference  at  the  time  of  their 

official  p u b l i c a t i o n.  The  procedure  for  such  reference 

shall  be  adopted  by  Member  S t a t e s. 

Member  States  shall  communicate  to  the  Commission  no 

later  than  18  months  afer  the  date  of  its  adoption  the 

text  of  the  basic  provisions  of  national  law  which  they 

adopt  in  the  field  covered  by  this  D i r e c t i v e. 

Article  3 

This  Directive  is  addressed  to  the  Member  States 

Done  at  B r u s s e l s, 

For  the  Counc i I 

The  Près i dent 

10 

ANNEX 

The  following  point  is  hereby  added  to  Annex  1 of  Directive 
76/769/EEC 

28.  PoIybromobIphenyI  Ethers 

28.1  The  placing  on  the  market  of 

NonabromobiphenyI  Ether  (CAS  63936-56-1) 
HeptabromobiphenyI  Ether  (CAS  68928-80-3) 
HexabromobiphenyI  Ether  (CAS  36483-60-0) 
TetrabromobiphenyI  Ether  (CAS  40088-47-9) 
(CAS  49690-94-0) 
TribromobiphenyI  Ether 
(CAS  2050-47-7) 
DibromobiphenyI  Ether 
(CAS  101-55-3) 
BromobIphenyI  Ether 

in  concentrations  by  mass  equal  to  or  greater  than 
.1%  is  prohibited  in  substances,  preparations  and 
products 

28.2  The  placing  on  the  market  of 

DecabromobIphenyI  Ether  (CAS  1163-19-5) 
OctabromobiphenyI  Ether  (CAS  32536-52-0) 
PentabromobIphenyI  Ether  (CAS  32534-81-9) 

in  concentrations  by  mass  equal  to  or  greater  than 
.  1%  shall  be  prohibited  from  ../../....  (five 
years 
in 
of 
substances,  preparations  and  products." 

Directive) 

adoption 

this 

from 

-11 -

Draft  proposal  for  a  Council  Directive  modifying  for  a 
twelvth  time  Council  Directive  7 6 / 7 6 9 / E EC  on  the 
approximation  of  the  laws,  regulations  and 
administrative  provisions  of  the  Member  States 
relating  to  restrictions  on  the  marketing  and  use  of 
certain  dangerous  substances  and  p r e p a r a t i o ns 

C O M P E T I T I V E N E SS  AND  EMPLOYMENT  IMPACT  ASSESSMENT 

I. 

The  current 
concerns  restrictions  on  the 
m a r k e t i ng  and  use  of  a  family  of  chemicals  known  as 
poIybromob I phenyI  ethers  ( P B B E ' s ). 

proposal 

Only  three  of  the  10  PBBE's  are  commercially  produced 
namely, 
and 
decabromobIphenyI  and  these  find  applications  In  flame 
retardant  formulations  mainly  for  use  In  p l a s t i c s. 

p e n t a b r o m o b I p h e n y I, 

octabromobIphenyI 

It  has  been  concluded  that  the  PBBE's  constitute  a 
potential  risk  to  man  and  the  environment  and  that  they 
should  be  prohibited  once  safer  substitutes  have  been 
proven. 
it  has  been  decided,  therefore,  that  the  PBBE's  should 
be  banned  In  stages,  starting  with  the  seven  non 
commercial  products  which  are  prohibited  as  from  the 
date  of  Implementation  of  the  D i r e c t i v e. 

II.  Features  of  the  Business  in  question. 

important 

PBBE 
The  commercially 
F r a n c e,  Netherlands  and  the  U.K. 
concerned  produce  about  one  third 
and 
Imported 
CommmunIt y. 
PBBE's  are  also  contained  In  a  wide 
goods  imported  Into  the  Community. 

balance 

the 

Is 

In 
s  are  produced 
The  three-  companies 
of  E.C.  requirements 
the 

outside 

from 

range  of  plastic 

III.  What  Direct 

O b l i g a t i o ns  does  the  measure  Impose  on 

Industry. 

and  use  of  penta,  octa 

The  marketing 
bromob I pheny I  ethers  lr  prohlb't**  fr.-.-t  s  years  of 
Implementation 
prohibition 
applies  not  only  to  the  three  PBBE's  as  such  but  to 
plastic  goods  or  any  other  goods  containing  them. 
The  industry  concerned  will  have  to  adopt  alternative 
systems  or  Introduce  substitute  p r o d u c t s. 

Directive. 

deca 

The 

and 

the 

of 

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IV.  What  Indirect  Obligations  are  local  Authorities  likely 

to  Impose  on  business  7 

None 

V. 

Are  there  any  special  measures  In  respect  of  PME's  7 

No. 

VI.  What  Is  the  likely  effect  on  : 
competitiveness  of 
employment. 

(a) 
(b) 

Industry ; 

(a) 

for 

retardants 

The  PBBE's  are  the  cheapest  and  most  effective 
Their 
flame 
prohibition  will  add  slightly  to  user  Industry 
costs.  The  effect  of  this  harmonised  measure  will 
be  to  equalise  the  conditions  of  competition 
within  the  Community  though  It  may  adversely 
affect  In  a  small  way  the  competitiveness  of 
companies  exporting  from  the  Community. 

plastics. 

most 

(b) 

It  Is  unlikely  that  the  measure  will  have 
significant  Impact  on  employment  as  the  producers 
and  users  of  PBBE's  will  move  to  substitutes 
products  once  these  are  available. 

- 1 3-

ÏSSN 0254-1475 

COM(91)7final 

EN 

06 

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ISBN 92-77-68927-7 

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