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.
DBDPE is used for components and enclosers in Electrical and Electronic products to provide essential fire safety requirements.
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?
If DBDPE were no longer available, the impact on almost every electrical and electronic household product would be significant. There are no practical alternatives at this time and adverse consequences would include decreased safety and quality, public safety risks with increased development and production costs.
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 proposed standard will inevitably result in unintended consequences and substitutions are likely to result in increased waste, carbon dioxide emissions plus increased fire and safety risks that adversely affect the environment.
In many countries, end-of-life Electrical and Electronic Equipment is collected and disassembled, and valuable materials including plastics are recovered and recycled. While plastic recycling processes are advancing, the separation of polymer matrices from legacy additives such as flame retardants is not yet perfect. As a result, trace amounts of these substances can remain in the recycled plastic (recyclate).
When this recyclate is used in the manufacture of new EEE products, these trace elements may persist. Therefore, we strongly encourage Australian policymakers to consider setting realistic threshold limit values for these substances. If the thresholds are set too stringently, there is a significant risk of unintentionally discouraging the use of recycled plastics an outcome that would hinder both environmental and circular economy objectives.
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).
CESA members advise that the proposed implementation dates are unachievable in the Electrical and Electronic sector and the proposed regulation of DBDPE is anticipated to have significant and unreasonable implications for industry operations, as well as for public safety and regulatory compliance. DBDPE is a critical flame retardant used across a wide range of electrical and electronic components, including plastic housings, circuit parts, cables, and connectors in home appliances. Its widespread application makes replacement highly complex and impractical.
Identifying and transitioning to a substitute material requires extensive verification to ensure equivalent performance in key areas such as flame retardancy, electrical insulation, mechanical stability, and long-term durability. This verification process, along with the required regulatory approvals, product testing, and certifications, will impose substantial time and cost burdens on manufacturers. These administrative and technical hurdles are likely to disrupt production timelines and pose risks to global supply chain continuity.
The industry is currently expected to complete the transition to a DBDPE substitute by 2033. However, full replacement by this deadline may not be feasible, particularly if regulations are applied inconsistently across countries, complicating global manufacturing and product alignment. Developing and implementing a new material that meets the safety and performance standards of DBDPE is a long-term undertaking that will require significant R&D investment and operational adjustments.
In light of these challenges, CESA urges regulators to consider the practical limitations of current alternatives, align timelines with technological readiness, and adopt a harmonised, globally coordinated approach to avoid disproportionate economic and safety impacts.
Is the chemical clearly identified in the proposed standard?
Would you like to provide further comment on this proposed standard?
Would you like to upload a supporting document?
