Småhus, flerbostadshus och förskolebyggnader - Svanen

Nordisk Miljømerking
Hus, leiligheter og barnehager 089/versjon 2
Høringssammenstilling, oppdatert 10. august 2010
TCPP is a halogenated (but not brominated) flame retardant used in a number of building
products. The EU risk assessment6 concluded that there is no risk for any of the
downstream users (insulation material manufacturers, builders, users). Taking this into
account, the Member State Competent Authority meeting decided
in May 2009 that no classification is required for TCPP in the framework of REACH
Annex XV (Classification & Labelling).
The eco-label cannot be more ambitious than “no risk”.
TCPP is practically not emitted7 during the lifetime of the construction product and will
be destroyed at the end of the product life through energy recovery.
On the other hand, in its use phase, the flame retardant will help protect the health of
users. It will also allow the use of the most efficient insulation materials commonly
available on the market, which will significantly improve the overall energy and material
balance of the building (see examples above).
_ CPIF calls on the Nordic Ecolabel to achieve consistency between the Background
report and the draft ecolabelling text, to remove the ban of halogenated flame retardants
or limit it to brominated flame retardants or, at least, allow the use of those flame
retardants for which the EU risk assessment has concluded that the substance is not
hazardous and hence no classification and labelling is required.
BING, Europe
The case of halogenated flame retardants (O17, O22)
The lacking scientific basis is even more striking in the case of the proposed generalised
ban of halogenated flame retardants. This ban covers also substances that do not require
any labelling as they are not considered dangerous or harmful. It would be illogical to
refer to the precautionary principle in this case, as detailed risk assessments are available.
BING firmly believes that the (supposed) negative impacts must be compared with the
potential benefits. If the benefits largely outweigh the risks, the substance should not be
simply banned. In any case, the Ecolabel should underpin the proposed bans with
scientific evidence. It is also astonishing that the Background report (appendix 8, page 3)
only refers to brominated flame retardants, whereas the requirements O17 and O22 ban
all halogenated flame retardants.
Example:
TCPP is a halogenated (but not brominated) flame retardant used in a number of building
products. The EU risk assessment7 concluded that there is no risk for any of the
downstream users (insulation material manufacturers, builders, users). Taking this into
account, the Member State Competent Authority meeting decided in May 2009 that no
classification is required for TCPP in the framework of REACH Annex XV
(Classification & Labelling). The eco‐label cannot be more ambitious than “no risk”.
TCPP is practically not emitted8 during the lifetime of the construction product and will
be destroyed at the end of the product life through energy recovery.
On the other hand, in its use phase, the flame retardant will help protect the health of
users. It will also allow the use of the most efficient insulation materials commonly
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