On 5 April 2018, European Chemicals Agency (ECHA) released a screening assessment on chlorinated flame retardants (TCEP, TCPP, TDCP) used in polyurethane (PUR) foam. This evaluation identified the risks of children exposure to these substances in childcare articles and residential upholstered furniture. Hence, ECHA recommended a restriction proposal under REACH should be prepared.
Back in December 2017, the ECHA held a call for evidence to collect comments from various stakeholders, suggesting the risks of these flame retardants should be properly addressed by an EU wide restriction measure.
This assessment identified a carcinogenicity risk for babies exposed to these flame retardants. TCEP, TCPP, TDCP belong to a group of chlorinated flame retardants with similar properties. Both TCPP and TDCP are used in flexible PUR foam in child care articles and residential upholstered furniture. While TCEP is not used anymore as a flame retardant for flexible PUR foam in the EU but it may be found in imported articles. The use of flame retardants is intentional, and some Member States impose fire safety regulations on upholstered furniture (e.g. United Kingdom, Ireland).
Four types of child care articles were selected as reference articles including baby mattresses, safety seats, baby slings and sofas. These flame retardants are not chemically bonded with polymer materials. Migration is feasible via skin or dermal contact. Out of the four types of reference articles, baby mattresses have the highest risk level because of large contact surface area and prolonged contact with infants. This report suggested a limit value of 0.1% by weight would be appropriate to prevent the intentional use of these three flame retardants.
Table A shows a general overview of TCEP, TCPP and TDCP requirements on articles in the EU, USA and Canada.
Table A - Summary of EU, USA and Canada requirements of TCEP, TCPP and TDCP in articles
Country / Region
REACH candidate list
TCEP: 0.1% by weight
Toys intended for children under 36 months and in toys intended to be put in the mouth
Toy Directive 2009/48/EC
TCEP, TCPP and TDCP: 5mg/kg (each)
Children's product and residential upholstered furniture
Various US states law e.g. Washington, Vermont, Maine, etc.
TCEP, TCPP and TDCP: 0.1% by weight (each)
Products containing PUR foam for children under the age of 3
Schedule 2 of the Canada Consumer Product Safety Act