Fire Retardant Technologies: safe products with ... - Oakdene Hollins

41. There was general support for inclusion of a flammability criterion in the EU Ecolabel.Are the Current EU Ecolabel Criteria Fit For Purpose?The existing EU Ecolabel criteria for the products considered here are too restrictive and arenot consistently based on the risk phrase approach to environmental performance.Meaningful and balanced Ecolabel criteria are likely to be based on:1. Encouragement to use non-chemical FR technologies such as product design andinherent FR materials. For GPP this would also require it being achieved atreasonable cost.2. Exclusion of any chemical FRs that are known to be hazardous through appropriaterisk-phrase hazard assessment and, where appropriate, risk assessment. It is notappropriate to exclude all classes of brominated FRs due to the poor environmentalperformance of some classes.3. Inclusion of chlorinated FRs that meet ecolabel hazard criteria.4. Inclusion of both additive and reactive chemical FR types, as currently defined, butsubject to other ecolabel hazard criteria. It is proposed that the use of exclusioncriteria based on “reactive” and “additive” terminology cease, and the use of suchterminology in the setting of criteria should be avoided.5. Alignment of criteria setting with REACH and CLP in Europe; this should includeconsideration of the effect of FRs being chemically and physically bound intomaterials rather than based on free molecule hazard assessments.6. Regular review of the criteria to keep pace with hazard and risk informationdevelopments under REACH and CLP. FR chemicals should not be used in ecolabelproducts unless they have adequate toxicity data to ensure that no classification isrequired in respect of the specific risk phrases listed in the ecolabel. Absence of dataand absence of classification should not mean that an FR is acceptable.7. A fire retardancy criterion to ensure the fire performance of products is notcompromised.4 Methods and approachThis final report is constructed from four technical reports that each have their ownmethodologies. These are available as Annexes to the Technical Report and include:1: Legislative Landscape2: Risk Assessment3: FR Technology Survey4: Ecolabel Market SurveyP a g e 26 |