Environmental Project No. 1317, 2010

Inclusion of HBCDD, DEHP, BBP, DBP and additive use of TBBPA in annex IV of the Commission's recast proposal of the RoHS Directive


In relation to the European Commission's proposal for a recast of the RoHS Directive on restrictions of certain hazardous chemical in electrical and electronic equipment (EEE), Denmark finds it relevant to consider the proposal of the inclusion of the following five substances under the proposed Directive's Annex IV, rendering their respective use in EEE restricted in the European Union:

  • Hexabromocyclododecane (HBCDD)
  • Bis (2-ethylhexyl) phthalate (DEHP)
  • Butyl benzyl phthalate (BBP)
  • Dibutyl phthalate (DBP)
  • Additive use of tetrabromo bisphenol A (TBBPA)

This study supplements the existing assessments with an assessment of socioeconomic impacts of the inclusion of these substances. The assessment compares:

  • The net costs to the society - expressed in terms of increased raw material cost, R&D and investment in new tools and techniques and increased costs of RoHS compliance


  • The benefits to human health and the environment of substitution - expressed in terms of differences in key environmental and health effects of the alternatives compared to the five substances.
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