In February, EU Members announced final conclusions of an eight-year risk assessment of TBBPA (Tetrabromobisphenol-A) on human health and the environment. EU experts concluded (again) that TBBPA poses no risk to people, and now confirm no risk to the environment when the chemical is used in the manufacture of PCB laminates and plastics like ABS used for electronic product housings.

This position is in line with the first EU human risk assessment, completed in May 2005 (with finding published in 2006), which reported the common laminate and plastic bromine flame-retardant (BFR) poses no human risk. The testing and data needed to reach the risk assessment’s conclusions took more than eight years and millions of dollars to compile.

This latest announcement from the EU comes on the heels of a two-day symposium cosponsored by Intel and IPC that focused on current halogen-free initiatives. There are quite a few programs including individual OEM driven programs, IPC task groups, HDPUG initiatives and iNEMI projects. The symposium covered topics from limiting halogens found in laminate materials to halogen management throughout the supply chain.

Unlike PBB and some PBDEs (polybrominated biphenyls or polybrominated diphenyl ethers), TBBPA is not banned under RoHS. TBBPA had a worldwide consumption of about 200,000 tons in 2002, over half going to PCB laminates. It is the primary flame retardant in over 95% of all FR-4 based materials. There is more data available on the impact of TBBPA on human health and the environment than many potential substitutes, and there is certainly a longer history and significant reliability data on its performance as a flame retardant in laminate.

So, one might ask, why should the industry continue activity to limit halogens in laminate materials if TBBPA is acceptable from both a health and environmental perspective?

At this point, market momentum seems to be creating self-sustaining energy. Companies like Apple, Dell, HP, Intel, Lenovo and Sony have committed to go halogen-free as part of their environmental roadmaps. Dell currently prohibits the use of TBBPA in plastic parts and is working to eliminate the material from PCBs by 2009. Intel’s mobile device platforms will be halogen-free by the end of 2008. Apple began using bromine-free laminates in handheld products in 2007, and seeks complete elimination of BFR by year-end. Companies have committed to consumers that they will eliminate halogens as part of an environmentally responsible business strategy, regardless of the obvious science.

This market momentum has been further driven by Tier II suppliers (read: PCB fabricators) and ODM and EMS companies. Many have invested significantly in halogen-free as part of their RoHS programs. New laminates have been evaluated, and testing and qualification programs begun. Time and money has been spent with expectations of high returns for early adoption.

Hand-in-hand with market momentum is supplier investment. Laminate companies (and plastics suppliers) are investing million of dollars a year on new product R&D to meet halogen-free requirements. The resulting products are seen as an opportunity for differentiation, higher margins and bigger profits. Considering this initiative has been active for over 10 years, many companies have already hit a high level of financial commitment for halogen-free programs.

The iNEMI Halogen-Free Project identified 30 candidate laminate materials from 15 suppliers. From this number, eight were selected for testing. The selection process was based on available information on lead-free assembly survivability. Companies represented in this testing are well-known Asian laminate suppliers: Hitachi, Nan Ya, TUC, ITEQ, Panasonic and Shengyi. Once successfully tested, these companies will be in the driver’s seat.

Halogen-free, like lead-free, may be one of the most expensive overhead costs a company will incur. The long-term risks such as yield loss and product malfunction – again like lead-free – will take years to fully quantify.

In this case, for many of us the science is clear. TBBPA has been well studied and the results of these studies concur with the most recent EU finding. The regulations, however, are less clear. But unlike the industry situation with RoHS, there is a choice to be made. TBBPA can be used and laminates can continue to contain bromine from this source. They would not qualify as halogen-free, but perhaps that definition needs to be redefined to match the prevailing science.

Or it just may be a case where market forces and general perceptions have overtaken the science and are driving toward a different kind of “green.” Let’s hope we can find sharper acuity on this issue before we find ourselves counting our losses.