TCO Development and Ecolabeling Sweden support the concept of a “chemical tax” as a financial tool to influence a shift away from hazardous chemicals in consumer products. However we do not believe the current proposal of tax breaks will be effective in reaching the goal of phasing out the use of the most hazardous substances.
The health and environmental effects of various flame retardants containing bromine, chlorine or phosphates vary widely. It is widely known that halogenated flame retardants containing bromine and chlorine are problematic. These substances emit toxic dioxins and furans when products containing them, such as electronics, are incinerated at too low temperatures at their end of life. This happens all too frequently today.
While not problem-free, phosphate-based flame retardants do not emit dioxins. In the case of electronics, it’s clearly the bromines and chlorines that have been identified as the greater risk to human health and the environment. All flame retardants cannot be treated equally.
Similar knowledge around phosphate-based substances is lacking, meaning they require case-by-case assessment. This lack of knowledge makes monitoring of product content more difficult.
We fully agree that it’s time to phase-out the use of halogenated flame retardants; they are widespread and problematic, particularly in end of life handling phase. However, by also including all phosphate-based flame retardants, the current proposal does not achieve its desired goal. We believe the current proposal raises the risk that industry will not bother to substitute halogenated substances with safer alternatives if the tax incentives are too low or if the substitution process is too difficult. Manufacturers would be more likely to stay with the flame retardants they already use and the tax would not have the desired effect.
It is important to consider the environmental and health effects of electronics throughout the product life cycle, At the same time, these devices are sold in large volumes around the world, so it’s unlikely, and possibly not even desirable, that they would be designed specifically for the Swedish market.
We therefore advocate an approach whereby the initial goal is to phase out halogenated substances, followed by the introduction of economic consequences of their continued use. This can be done by eliminating the tax on phosphate-based flame retardants. A logical next step could be to develop a method for assessing which non-halogenated flame retardants should be phased-out in the next update of the chemical tax.
In addition, we ask for further clarification on the role of eco-labels as outlined in chapter 10.11 – Eco-Labels. The chapter should offer an explanation that eco-labels are a positive tool that consumers and professional buyers have used for many years to help them identify and avoid products that contain the most hazardous substances. Portraying eco-labels as ineffective does not help advance the cause of reducing the use of hazardous substances in consumer products and lowering our exposure to these toxic chemicals. It is our opinion that both initiatives – a chemical tax as well as constructive consumer guidance – can contribute to this goal.
/ TCO Development and Ecolabelling Sweden.