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.
Used in idustrial trucks as a flame retardant in many materials and parts, most commonly in electric wires.
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?
Industrial trucks will not be able to be manufactured because they will no longer be able to meet the flame retardancy required for automotive parts. This will have a significant impact on the social economy.
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.
Since there is not sufficient evidence to support a environmental emissions from articles such as auto parts, regulating these is not an appropriate environmental risk management.
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).
As mentioned above, automobiles will not be able to be manufactured because they will no longer be able to meet the flame retardancy required for automotive parts.
Is the chemical clearly identified in the proposed standard?
Please provide details of any changes you would recommend.
Only CAS number 84852-53-9, which indicates the DBDPE itself, should be covered.
Would you like to provide further comment on this proposed standard?
Upload a document.
May 9 2025
Australia’s Department of Climate Change, The Environment, Energy and Water (DCCEEW)
response to proposed regulations prohibiting the DBDPE,
proposed restrictions under its Industrial Chemicals Environmental Management Standard,
including a ban on the importation of articles
(goods) containing the brominated flame retardant
Introduction
Comments on proposed regulation prohibiting the DBDPE
hereby express gratitude to Australia’s Department of
Climate Change, The Environment, Energy and Water (DCCEEW) for years of efforts and leading- edge activities to ensure a clean, safe and sustainable environment for present and future generations.
With regard to the "consultations on proposed restrictions under its Industrial Chemicals
Environmental Management Standard, including a ban on the importation of articles (goods) containing the brominated flame retardant decabromodiphenyl ethane (DBDPE) from 1 January 2027”, we submit our specific comments as shown the next paragraph, due to the large volume of DBDPE and DBDPE-using materials and products distributed globally, we believe that in order for the industry to realize the phase-out of DBDPE in terms of production and supply as well as socioeconomics, a review of grace periods in addition to exempted applications/products are We believe it is essential.
Expansion of the exempted application and review of grace period
Due to the following reasons, it is currently difficult to replace products in industrial applications related
to automotive parts that use DBDPE.
(1) There are supply-related issues since DBDPE is widely used, and many suppliers have not
explored feasible alternative options. This is largely because DBDPE is not regulated in other
jurisdictions.
(2) Suppliers state that no other flame retardant provides the same level of flame retardancy,
processing, and qualities that DBDPE provides.
(3) Asides from DBDPE, it is difficult to achieve both flame retardancy and other characteristics
(such as withstand voltage characteristics, rated temperature, and capacitance).
(4) Since DBDPE is highly flame-retardant, the base material can function with a small amount of use.
If a flame retardant other than DBDPE were to be used, more of that flame retardant is required
to reach the same level of flame retardancy. At the same time, the other qualities (such as voltage
and frequency characteristics, capacitance, and physical characteristics (bending and tensile
strength) etc.) become negatively impacted, so that it is difficult to use in automotive parts for
industrial trucks.
(5) Alternatives may lower the high-speed transmission characteristics and qualities (compared to
DBDPE).
Due to this situation, we would like to make the following request regarding the applications to be exempted and the grace period for such exemptions.
1) Expansion of exempted application/product
The proposed regulations provide exemptions for certain parts of electrical and electronic equipment and automotive and transport applications, the products on which they are contained, and replacement parts, but the same exemptions need for construction/agricultural equipment and industrial trucks such as forklift trucks, and outboard motors because they use many of the same technologies and parts as those used in automobiles.
However, it is unclear whether or not these applications fall under the "Vehicle" exemption. We are very concerned that if these applications are not exempted, there will result in significant disruptions to the supply of products and manufactured items in industrial applications related to automotive parts in Australia, that will ultimately inconvenience Australian consumers.
For this reason, we propose that these applications be included in the exemptions and that the regulations clearly state that they are exempt. We believe that this is in line with one of the objectives of the review of this regulation, which is to "improve the ease of understanding of the regulatory content for stakeholders".
2) Review of grace period for exempted application/product
In addition to the exempted application, it is difficult to address the grace period, which is currently set at 6 years for automotive and transport applications.
As mentioned earlier, changing DBDPE, which has high flame retardancy, to other flame retardants requires measures such as increasing the amount of additives, which will adversely affect performance and quality other than flame retardancy.
For example, more than half of the applications of DBDPE in products are for wires and cables, and there are many cases in which high heat resistance as well as bendability and routability are required in wires and cables. For example, if the flame retardant were to be changed to an inorganic flame retardant, the bendability and routability of the wires and cables would decrease as the amount of flame retardant added increases, making it difficult to use in products related to automotive parts.
As electrification advances in the future, wires and cables will be subject to higher currents, and the need to distribute thicker wires in smaller spaces will increase, making it even more necessary to achieve both high heat resistance and bendability and routability.
Similarly, for other applications, it is necessary not only to replace the material in terms of flame retardance, but also to combine it with other performance required for each application.
Due to this situation, at least the following periods are required to promote alternative. However, since this is an estimation based on a situation where no alternative plan is in sight at this time, it is possible that more time may be required.
- Survey of alternatives for each application and selection of candidate alternatives：5 years
- Material development and evaluation, component development and evaluation, and customer
evaluation and approval：10 years
We request that 15 years exemption period after the enactment of the regulations.
Concerning replacement parts, our understanding is that a "30-year grace period from the end of the grace period for mass-produced products" is required. We also request that “a grace period of "30 years following publication of the proposed restrictions has been established for replacement parts for exempted products”.
Review System Introduction
We would like to request the introduction of a system to review regulations after they are issued.
However, due to the very widespread use of DBDPE, it is difficult to conduct a global survey in a short period of time. Therefore, it is expected that it will take a lot of time for the parties concerned to understand the difficulty of alternative, prepare the information necessary for review system introduction.
The following industries associations and industries share common concerns and opinions with us.
Conclusion
recognizes that DBDPE is widely used in many industries due to its unique and stable performance, which ensures the safety of each product.
Therefore, we assume that regulating the DBDPE without a sufficient transition period that is in line with the actual situation will cause significant disruption to the supply of products and manufactured goods for industrial applications related to automotive parts in Australia and will have a significant impact on Australian society and industry as a whole.
believes that our concerns and suggestions will help the DCCEEW's activities to ensure a clean, safe and sustainable environment for present and future generations.
Sincerely yours,
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