Letter to Customers Concerning TBBA

Recently there are more and more rumours concerning “TBBA” causing more confusion than clarification in the market. Unfortunately there are some base material suppliers who try to abuse this situation to push alternative products to front. Therefore, Isola wants to make use of the following information to bring clarity and to make a contribution to the avoidance of unnecessary and very cost-intensive material qualifications.

What is TBBA?
TBBA (Tetrabromo-bisphenol A) is a flame retardant which can be used as an additive or as a reactive component.

In the epoxy resin types FR-4 or FR-5 it is solely used as a reactive component, which means it becomes an inseparable element of the polymer.

TBBA does not belong to the group of the polybrominated biphenyls (PBB) or to the polybrominated biphenyl ethers (PBBE), which usage is prohibited by RoHS since 2007.

A formation of highly toxic dioxins or dibenzofuranes is not possible with reacted in TBBA in contrast to the additives PBB/PBBE. Corresponding examination results are available.

Have risk evaluations concerning TBBA been made?
For years numerous “risk assessments” have been carried out. All assessments reached the conclusion that there is no risk from reacted in TBBA.

Thereto some examples:

  • “Drafting of basis of valuation to substitute environmentally relevant flame retardant”, Federal Environment Agency Berlin, December 2000, carried out by Öko-Institute Freiburg → No Risk!
  • European Human Health Risk Assessment, February 2005 → No Risk!
  • European Environmental Risk Assessment, June 2007 → No Risk!
  • European Commission Scientific Committee SCHER, January 2008 → Complies with the EU Risk Assessment Report!
  • REACH → TBBA does not meet any of the criteria for questionable substances!
  • There are approximately 200 further studies arriving at the same conclusion.

Why is TBBA still in discussion?
Some time ago the European Commission mandated the Öko-Institute to check the guideline 2002/95/EG (RoHS) regarding whether there are further substances which should be added to the banned substances.

The Öko-Institute recommended beside other compounds to add TBBA, but not as reacted in TBBA, but as an additive. Unfortunately this proposal has been worked out without the participation of the concerned industry and the concerned associations. The industry meets this with a lack of understanding, especially as the electronic industry has proven in the past that it supported in an active and responsible way justified environmental issues. As an example WEEE, RoHS, and REACH should be mentioned.

How did the European Commission react to this proposal?
The European Commission published the results of their own risk assessment and decided that TBBA can be continued to use without any restriction.

Are the associations active?
To avoid such prematurely proposals like the one of the Öko-Institute working groups have been built as well in the ZVEI/VdL as in the IPC. They carried together facts to be able to create appropriate position papers which should be made available to the relevant authorities in Brussels and Berlin, but also to the Öko-Institute.

Isola is actively supporting both associations.

Summing up we want to state:

  • There are no well-grounded conclusions which could justify a ban of TBBA.
  • Based on long lasting examinations the European Commission gave the go-ahead for the unlimited usage of TBBA.
  • We are supporting our associations in their effort to inform the corresponding authorities in an objective way.

16 July 2008

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