Published name
Which chemical or chemicals would you like to provide feedback on?
Have you read the proposed standard or standards for the chemical or chemicals selected?
Do you support the proposed standard or standards?
Would you like to provide further comment on the proposed standard or standards?
Do you or your organisation use Decabromodiphenyl ethane (DBDPE)?
Please specify what you use the chemical for.
Flame retardant within the materials used in automobiles
Is your use for any of the following purposes?
Are you aware of any substitutes for Decabromodiphenyl ethane (DBDPE) that are available for your use?
If Decabromodiphenyl ethane (DBDPE) was/were no longer available, what impact would it have on your business?
stop sales in Australia until alternatives can be developed
Does the proposed standard for Decabromodiphenyl ethane (DBDPE) manage the risk of the chemical being released into the environment?
Please provide details of why you think the proposed standard will not adequately address risks to the environment.
The automotive sector is not able to provide an opinion on this matter.
Do the activities required for a business to meet the proposed standards for Decabromodiphenyl ethane (DBDPE) impose an unreasonable burden on business?
What information can you provide that would support that view (e.g. information on estimated cost to implement or the technical feasibility of required measures).
Once an alternative is developed, a full redesign will likely be required for all components affected. Due to the significant amount of parts impacted and the anticipated change to material property performance for each application, each car manufacterer will need to fully evaluate their vehicles during new vehicle development. Also, cost impacts will be made more clearer once an alternative is made available
Is the chemical clearly identified in the proposed standard?
Would you like to provide further comment on this proposed standard?
Upload a document.
Public comments on IChEMS proposed standards
Decabromodiphenyl ethane (DBDPE)
ABOUT ACEA
The European Automobile Manufacturers’ Association is a professional association uniting 14 major mobility actors on the European market.
13.0 million Europeans work in the auto industry (directly and indirectly), accounting for 7% of all EU jobs.
11.5% of EU manufacturing jobs – some 3.4 million – are in the automotive sector.
Motor vehicles are responsible for €374.6 billion of tax revenue for governments across key European markets.
The automobile industry generates a trade surplus of €79.5 billion for the European Union
The turnover generated by the auto industry represents almost 8% of the EU’s GDP
Investing €58.8 billion in R&D per year, automotive is Europe's largest private contributor to innovation, accounting for 32% of the EU total.
ACEA welcomes the opportunity to provide input into Australia’s Department of Climate Change, The Environment, Energy and Water (DCCEEW) proposed restriction of DBDPE.
Introduction
Automobiles have stringent, mandated fire safety requirements that must be adhered to, and DBDPE plays a significant role in helping the industry meet these requirements.
DBDPE usage in the automotive industry is tracked on a part-by-part basis through reporting in the International Material Data System (IMDS), an industry leading solution for hazardous materials disclosure that enables our industry to have a better understanding of the impact of substance restrictions, compared to other industries. It has been mandatory to report DBDPE content in automotive materials since February 2017 and to date, automobile manufacturers have received:
30,000 unique material reports that contain DBDPE
Approximately 2 million unique automotive part applications that contain DBDPE
Due to the large number of part applications impacted, it is anticipated that a DBDPE restriction will have a significant impact on our industry.
DBDPE Applications.
Due to its cost, loading factor and material compatibility DBDPE is used extensively in electrical wiring harnesses and electrical components, as well as some textile materials in seat / Instrument panel and head lining applications.
The auto industry is required to meet flammability requirements mandated by a variety of governments around the world. It is common practice in the industry for the automobile manufacturer to specify the flammability requirements (Flammability rating or applicable burn rate), relying on the component and material suppliers to identify the most effective materials to meet the flammability efficacy and the technical performance of the material, within the required engineering budget.
The information that we are receiving from our suppliers is that there is no drop-in replacement currently available for this flame retardant. Alternative chemistries are likely to be either phosphorous based (which are also being considered for restriction around the world) or inorganic materials (which would likely increase the mass of components to meet part flammability performance – therefore negatively impacting carbon emissions of vehicles). Either solution would require a complete material reformulation, requiring a significant amount of time for the supply chain to strike the right balance of the variety of additives within each material in order to achieve all safety, durability, and performance standards required for each component.
Information received during the European Chemicals Agency (ECHA) investigation into Aromatic Brominated Flame Retardants identified that a vehicle could contain up to 600g of DBDPE per vehicle. This could equate to several hundred / thousand applications per vehicle.
Comments on the proposed Restriction.
The DCCEEW decision to prohibit the manufacturing and use of DBDPE in the Australian market, will encourage the development of alternative flame retardants for Australian industry. But we feel that an extension of this restriction to articles is premature.
Automotive vehicles and components are produced wholly outside of Australia, where there are no restrictions on the use of DBDPE and to restrict the use of DBDPE in a market that represents <1.5% of the automotive volume presents serious technical and financial challenges for automobile producers.
For the majority of commodities that contain DBDPE (wiring harnesses / connectors / small electrical components), automobile manufacturers will not be able to produce a unique DBDPE free vehicle for the Australian market, leaving 2 options to comply with the Australian restriction proposal:
Remove DBDPE from all vehicles and components by 2033. This is likely not possible for all applications and will have a significant cost to validate and introduce replacement flame retardants.
Stop selling vehicles into the Australian Market from 2033. If we are unable to eliminate DBDPE by 2033, we will need to prevent imports of non-compliant vehicles to Australia.
ACEA believes that there is not sufficient evidence to support a DBDPE restriction in articles at this time and would encourage that the currently existing global forums (e.g. The Stockholm Convention on Persistent Organic Pollutants) are used to evaluate the scientific evidence and to agree if a global restriction of DBDPE is warranted. Also, the definition and scope of the exemptions in the proposed regulation need to be clarified and aligned with already existing regulations, for industry to be able to provide more detailed and relevant feedback.
This would provide the necessary impetus for development and testing of alternative flame retardants, should substitution be deemed necessary.
Comments on the proposed volume reporting requirements
The volume tracking requirements proposed by the DCCEEW place an unnecessary burden on industry and do not appear to trigger any downstream activities.
The automotive industry is particularly burdened with this onerous requirement due to the nature of DBDPE usage in our components, with no two vehicles being the same specification and potentially hundreds / thousands of DBDPE applications per vehicle in wiring harnesses and small electronic components. Reporting individual amounts per vehicle would be extremely costly and time consuming for no added benefit.
ACEA would like to request that automotive vehicles and components are made exempt from the volume tracking requirements.
If DCCEEW insist that DBDPE reporting is required, we would request that is simplified to averaged industry data, or a simple “Is DBDPE present? – Yes/No”, to reduce the administrative burden on industry.
We thank you for the opportunity to provide input and we are happy to discuss the issues of the proposed restriction on ACEA members in more detail, if required.
Would you like to upload a supporting document?
