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Insulation materials made of polystyrene (Styrofoam) with more than 1000 ppm HBCD have been considered hazardous waste in Germany since September 30, 2016 according to the POP Ordinance and Waste Catalog Ordinance, AVV.


What are HBCD

With HBCD, or HBCDD (hexabromocyclododecane, C.12H18Br6) is a flame retardant which, in addition to its use in textiles and upholstered furniture, was mainly used in materials for thermal insulation such as extruded (XPS) or expanded polystyrene rigid foams (EPS).

Harmfulness of HBCD to the environment

HBCD is harmful to the environment because it is long-lived (persistent), accumulates in organisms (bioaccumulating) and has reproductive properties (toxic). It is one of the persistent organic pollutants, "POPs", (English: persistant Organic pollutants).

Because of these properties, the EU added HBCD to the list of substances of very high concern back in 2008. The EU chemicals regulation REACH requires an authorization for these substances. In 2013, the substance was also classified worldwide as a Persistent Organic Pollutant (POP) under the Stockholm Convention. A production and use ban has been in effect worldwide since November 2014.

Waste classification of HBCD

According to the POP Regulation ((EC) No. 850/2004) Art. 7, waste containing persistent organic pollutants must be recycled or disposed of as follows: "that the persistent organic pollutants contained therein are destroyed or irreversibly converted“.

Insulation materials are considered "POP-containing" if their POP content is greater than or equal to a certain limit value concentration in Appendix IV of the POP Ordinance or the German Ordinance on the European List of Waste (AVV). The limit value of 1000 mg / kg specified for HBCD became legally effective on September 30, 2016.


Old polystyrene insulation materials typically show HDCD contents between 0.7% and 1.5% HBCD and are thus well above the limit of 1000 ppm (0.1%).

Since September 30, 2016, they have been considered dangerous and require proof and may only be treated in waste incineration plants that have the appropriate approval.

According to the Waste Catalog Ordinance, HBCD-containing insulation waste will therefore be assigned the waste code number "17 06 03 * other insulation material which consists of or contains dangerous substances"Assigned.

Testing of insulation materials for HBCD

The Federal Environment Agency describes on its website a quick test based on X-ray fluorescence analysis, which was developed by the Fraunhofer Institute IVV and BASF SE.

In this test, HBCD is extracted from the insulation material with an organic solvent and its content in the solution / in the insulation material is determined with high precision using a handheld XRF.