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BSEF - The International Bromine Council

BSEF

BSEF is the voice of the bromine technology industry globally.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

BSEF the International Bromine Council, welcomes the opportunity to provide written comments on the ongoing work around the EU Circular Economy Act (CEA). BSEF has been actively involved in responding to and engaging with the EU Green Deal and in particular the Circular Economy Action Plan and Chemicals Strategy for Sustainability. We would like to raise the points in our attachment which should be considered by the European Commission when developing the Act.
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Meeting with Bernd Lange (Member of the European Parliament, Committee chair)

17 Sept 2024 · General Exchange of View

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

2 Jul 2024

Dear Members of the European Commission, BSEF notes the decisions of the Conference of the Parties of the Basel Convention to include all electrical and electronic waste under the control mechanisms of the Convention (Decision BC 15/18), as well as the European Commissions efforts to implement such a decision within the EU. We thank the European Commission for the opportunity to provide feedback and would like to share our comments to the modifications as outlined in the draft delegated act. 1. Impact on Notification and Treatment Process: The distinction between hazardous (A1181) and non-hazardous notifiable WEEE does not alter the notification or treatment processes. Regardless of whether the WEEE is deemed hazardous or non-hazardous, the notification and treatment process remain the same. Thus, within the EU context, distinguishing between Y49 (all e-waste) and A1181 (hazardous e-waste) classifications will not bring practical value. Conversely, it will likely complicate operations for many treatment companies, which are not permitted to process hazardous waste under A1181, despite their capability to handle notifiable WEEE under Y49. 2. Misclassification of Brominated Flame Retardants (BFRs): The current wording in the draft delegated act inaccurately implies that all BFRs in WEEE plastics are restricted and/or prohibited. In reality, the majority of the BFRs used and found in WEEE are not only permitted but also highly efficient additives used for fire safety. Only a small fraction (0.2%) of BFRs in WEEE plastics are restricted, as compared to 3.5% in all WEEE plastics (see also the BSEF/DSS+ study https://www.bsef.com/wp-content/uploads/2023/09/Brominated-Flame-Retardants-and-the-Circular-Economy-of-WEEE-Plastics-online-final.pdf). Therefore, the blanket classification of all BFRs as hazardous is inaccurate and needs correction. This oversight could unjustifiably lead to a classification of a significant volume of WEEE plastics as hazardous. 3. Guidance Document WSR 12 Compliance: The EUs guidance document (WSR 12) for cross-border shipments of plastics stipulates that plastic waste containing Persistent Organic Pollutants (POPs), such as POP-BDEs, should be classified under entry Y48 or EU48, avoiding their classification as hazardous waste. This approach recognizes that restricted BFRs, when embedded in plastic, do not pose a hazard. The proposed delegated acts broader classification contradicts this guidance and would disrupt the established practices and compliance mechanisms, bringing inconsistency to existing legislation. Recommendations: BSEF asks the European Commission to reconsider the proposed classification under A1181, specifically by: Limiting the classification within the EU to Y49, thus maintaining the current practical and effective handling of notifiable WEEE plastics with BFRs. Correcting the misrepresentation of BFRs to accurately reflect their actual safety standards and regulatory status in WEEE plastics.
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean) and Albemarle Europe

17 Apr 2024 · Value of BFRs in the context of European mobility

Meeting with Adam Jarubas (Member of the European Parliament) and European Chemical Industry Council and

15 Nov 2023 · EFSW2023: Taking stock of progress on fire safety – what should the Commission and Parliament do to improve fire safety in Europe?

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Dear colleagues, Please see the BSEF feedback attached. In short; - Fire safety should be specifically identified as a sustainability criteria for E&E and Building & Construction sectors. - Due to reasons highlighted within the attached, and lack of any justification offered in the annexes, we request that sections 2.6.5 & 2.6.7 of Annex II to Environmental Delegated Act be removed/deleted. We remain available to discuss in further detail. Many thanks in advance for your consideration. Best regards, Patrick
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Meeting with Jens Gieseke (Member of the European Parliament)

10 Jan 2023 · Austausch zur EU-Politik

Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

2 Nov 2022

BSEF, The International Bromine Council, thanks the European Commission for this opportunity to provide feedback to the call for evidence for the evaluation of the WEEE Directive. BSEF supports statements in the document that the evaluation should pay particular attention to challenges linked to proper collection and treatment of WEEE. These aspects are key for a successful and effective implementation of the WEEE Directive. BSEF commissioned SOFIES sustainability consultants (now DSS+) to examine WEEE plastics flows and recycling efforts in Europe, with a particular focus on Brominated Flame Retardants (BFRs). The report is available at the link offered in the attached, and we believe offers some useful insights when considering the EU rules on WEEE. We thank the Commission in advance for consideration of our attached position. best regards, Patrick Head of Advocacy & Public Affairs, BSEF
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Response to Safety requirements to be met by European standards for certain children products (excluding toys)

2 Sept 2022

Importance of Fire Safety for Children Today Children’s products are becoming increasingly more sophisticated, getting smarter, using batteries etc. Fire safety is a growing dimension of many of these products and the main concern is stopping a fire or a possible burn scenario. The fire challenge is critical because these product failures can ignite something else like a couch leading to bigger fire events. Data shows children are a vulnerable risk group and are far more likely to be harmed in a fire than adults since they don’t always run for the door. Please see the full BSEF position and comments attached. Best regards, Patrick
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Response to Review of the Construction Products Regulation

12 Jul 2022

Dear colleagues, Please see attached the full BSEF Position Paper on Commission Proposal for a Revision of the Construction Products Regulation (CPR) The BSEF Key messages: • The Revision of the CPR needs to continue to consider fire safety of construction materials, given; 1) The move towards Green Energy and EVs, and required energy storage applications in homes 2) The increased use of plastics and flammable materials 3) The proliferation of electronics • Risks from electric failure resulting in ignition and fires should be added to inherent product safety risks to Annex I, Part C 1.1. • Brominated flame retardants play a key role in contributing to the fire safety in buildings Many thanks in advance for taking our position into account in your review. Kind regards, Patrick Fox Head of Public Affairs & Advocacy, BSEF, The International Bromine Council
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Response to Sustainable Products Initiative

20 Jun 2022

BSEF, The International Bromine Council, attaches the enclosed position paper on the EU Regulation on Eco-design for Sustainable Products. A summary of the key messages are as follows; • Develop a new methodology for the ESPR • Put in place a representative Eco-design Forum • Avoid duplication of existing chemical regulation for substances • Promote scientific-based Green Public Procurement criteria Thank you in advance for your consideration of the attached paper. Best regards, Patrick Head of Public Affairs and Advocacy, BSEF.
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Response to Review: Restriction of the use of hazardous substances in electronics

10 Mar 2022

BSEF input to ‘Call for Evidence’ on the ‘Review: Restriction of the use of hazardous substances in electronics’ BSEF – the International Bromine Council welcomes the opportunity to contribute to the call for evidence on the RoHS review. As pointed out at previous occasions, we think that double-regulation should be avoided and that RoHS should follow the principle “one substance one assessment”. BSEF strongly supports ensuring alignment with related EU legislation covering restriction of substances. Substances which are being addressed and assessed under REACH should not be facing proposals for possible restriction under RoHS (e.g. TBBPA). As the guiding principle there should be a clear delineation between EU Chemical legislation and product legislation. If a substance were to be mentioned in product regulation, the assessment has necessarily to be corresponding to the assessment in REACH. The concept of authorising or restricting of chemical substances in product legislation would otherwise be unfounded, would create overlap, inconsistency and lack of legal certainty for producers, users and value chains. With respect to legal certainty and workability, it is key for BSEF members and the value chain that rules are consistently applicable with the European Union and European Economic Area. BSEF are of the opinion that both the 1) transformation of RoHS into a Regulation with clear definition of criteria, timelines and procedures for inclusion of substances, restriction and exemptions and 2) restricting the use of substances in Electronic and Electrical Equipment via REACH restrictions as proposed by DG Environment, could contribute to achieve this objective. In this respect, BSEF would welcome the development of a guidance document, as proposed by DG Environment, which would ensure clarity, transparency, coherency and legal certainty as well as prevent overlap and therefore unnecessary administrative burden. BSEF are of the opinion that no matter the path chosen the goal of one substance, one assessment and risk based methodologies covering the lifecycle the substance in the product should be realised. Furthermore we note that ECHA have the experience, skills, process (including consistent risk based methodologies) and rigour to support this objective. Michael Hack, Secretary General BSEF Brussels, 10 March 2022 About BSEF BSEF – the International Bromine Council, is the global representative body for bromine producers and producers of bromine technologies. Originally founded in 1997, BSEF works to foster knowledge on the societal benefits of bromine and its applications. The members of BSEF are Albemarle Corporation, ICL Industrial Products, Lanxess and Tosoh. Visit www.bsef.org to learn more and follow BSEF on Twitter @BromineInfo for the latest news and information.
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Response to Ecodesign and energy labelling working plan 2020-2024

31 May 2021

BSEF, The International Bromine Council, thanks the European Commission for the opportunity to comment on the Roadmap of the Ecodesign and Energy Labelling Working Plan 2020-2024. The BSEF position can be found in the attached document.
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Response to Ecodesign omnibus amendment of 2019 regulations

2 Nov 2020

The International Bromine Council have the attached comments on the Updated EU rules on ecodesign and energy labelling. Thank you in advance for taking these into consideration. Kind regards, BSEF
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Response to Update of concentration limit values of persistent organic pollutants in waste

5 Aug 2020

Please find attached BSEF’s feedback on the Inception Impact Assessment - Update of concentration limit values of persistent organic pollutants in waste
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Rud Pedersen Public Affairs Brussels

5 Jun 2020 · European Green Deal and chemicals

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and EUMEPS and

22 Oct 2018 · discussion on the implementation of the Plastics Strategy