Official guidance cites fire safety as an Essential Use. This concerns harmful chemicals, so PIN FRs are not targetted . The European Commission Communication on Guiding Criteria and Principles for the Essential Use Concept in EU Legislation dealing with Chemicals includes (table 2) “ensure the safety of products, equipment and tools, such as … fire resistance in products anticipated to be heated to a temperature where ignition could occur”. This is exactly the purpose of PIN FRs which are used to increase fire resistance (reduce risk of ignition, inhibit burning) of products potentially subject to heat sources (accidental exposure to flames or cigarettes, electrical overheating, arcing or sparks, friction heat …). pinfa has not engaged with the European Commission concerning FRs and Essential Use because this concept, in EU chemicals legislation, concerns only the “most harmful” chemicals (defined in table 1* of this Communication). Essential Use allows exceptional and temporary continuing use of such chemicals in specified (“Essential”) uses, until an acceptable alternative is available. Members of pinfa share the common vision of continuously improving the environmental and health profile of their flame retardant products and demonstrating their safety (see pinfa Mission).
This Communication follows publication in February of an ECHA (European Chemical Agency) – EEA (European Environment Agency) joint report which proposes an indicator framework for monitoring progress to safe and sustainable chemicals and summarises current trends. This underlines that hazardous chemicals, not compliant with REACH/CLP are found in 30% of consumer goods tested under enforcement checks, with the proportion increasing in imports. The problem of hazardous chemicals in recycling is also emphasised. Overall, this report suggests that progress is being made in some areas and that overall use of the most harmful chemicals (in particular CMR) is growing more slowly than the overall chemicals market.
“Commission defines principles on limiting most harmful chemicals to essential uses”, European Commission press release 22nd April 2024 https://ec.europa.eu/commission/presscorner/detail/en/IP_24_2151 and Commission Communication “Guiding criteria and principles for the essential use concept in EU legislation dealing with chemicals” (C/2024/2894) 26th April 2024 https://environment.ec.europa.eu/publications/communication-essential-uses-chemicals_en
* (simplified) “Most harmful” chemicals are defined as those with the following hazards: Carcinogen – Mutagen or Reprotox 1A 1B, Endocrine disruptor Cat. 1 (health or environment), Respiratory Sensitisorn Cat. 1, Specific Target Organ Toxicity Repeated Exposure (STOT-RE) Cat. 1, Persistent Bioaccumulative and Toxic (PBT), Very Persistent and Very Bioaccumulative (vPvB), Persistent, Mobile and Toxic (PMT), Very Persistent and Mobile (vPvM), Ozone Depletor Cat1.
“EU indicator framework for chemicals”, ECHA – EEA 02/2024 https://www.eea.europa.eu/publications/eu-indicator-framework-for-chemicals/