TBPH banned by the EU: what plastic and textile manufacturers must do

Key data

Manufacturers and importers of plastics, textiles and products with flame retardants have a clear regulatory signal: TBPH is on the way out. Council Decision (EU) 2026/878, adopted on 30 March 2026, authorizes the European Union to submit to the Stockholm Convention a formal proposal to include bis(2-ethylhexyl) tetrabromophthalate (TBPH) in Annex A of that international convention.

This is not a restriction in force today, but it is the direct precursor to a global ban. Companies that wait for the regulation to become final before acting risk running out of supply alternatives and sufficient time to reformulate their products.

What does this regulation establish?

The EU Council has authorized the European Union to submit, on its behalf, a proposal to include TBPH in the Annex A of the Stockholm Convention on Persistent Organic Pollutants. This convention is an international treaty that obliges signatory countries to act on substances included in its annexes.

Annex A is the most restrictive: it requires the elimination of the substance, which means prohibiting its production, use and commercialization. This is not a limited use restriction or gradual reduction: the goal is total elimination.

The decision adopted does not directly prohibit TBPH in the EU today, but it establishes the official European position and clearly anticipates the restrictions that will come, both at EU level and internationally.

Economic and operational impact

The impact for companies is not immediate in terms of sanctions, but it is in terms of planning. Companies using TBPH in their processes or products face three types of operational costs:

• Reformulation costs: Identifying and replacing TBPH with alternative flame retardants that meet the same technical fire safety requirements, without compromising material properties.
• Supply chain costs: Reviewing contracts with suppliers, auditing purchased raw materials and components, and renegotiating terms with new suppliers of alternatives.
• Certification and testing costs: Reformulated products may require new conformity tests, especially in sectors such as electronics and construction materials, where fire retardancy requirements are regulated.

The sooner the substitution process begins, the lower the cost. Companies that wait for the formal ban will have less time, fewer supplier options and greater pressure on alternative prices.

Who does it affect?

This regulation directly affects companies that manufacture or import products containing TBPH as a flame retardant. The identified sectors are:

• Textile sector: Manufacturers of technical fabrics, upholstery, protective clothing and textiles for industrial or domestic use that incorporate brominated flame retardants.
• Electronics sector: Manufacturers and importers of electronic and electrical equipment whose plastic components contain TBPH to meet fire safety requirements.
• Construction materials sector: Manufacturers of foams, panels, coatings and other materials that use flame retardants in their composition.
• Importers of finished products: Companies that import from third countries products that may contain TBPH, as the ban will also affect commercialization.

Practical example

A Spanish technical upholstery manufacturer for the automotive industry that uses TBPH as a flame retardant in its fabrics faces the following situation:

Today, its product complies with current regulations. However, with the EU's proposal to include TBPH in Annex A of the Stockholm Convention, the prohibition of production, use and commercialization is the foreseeable regulatory scenario in the medium term.

If this manufacturer waits for the ban to become formal before acting, it will have to reformulate its product under time pressure, compete for alternative suppliers with the rest of the sector (which will also be seeking substitutes at the same time) and possibly interrupt its production or lose customer homologations that already require TBPH-free products.

If it acts now, it can identify alternative flame retardants calmly, conduct performance tests without urgency, negotiate supply prices under normal conditions and anticipate the demands of its automotive sector customers, who typically impose their own substance restrictions before regulation does.

What should companies do now?

1. Audit the product catalog: Identify which own or imported products contain TBPH or brominated flame retardants in their composition. Request technical datasheets and substance declarations from suppliers if this information is not available.
2. Map the supply chain: Determine at what point in the chain TBPH is incorporated: whether in raw materials, in a purchased semi-finished product or in the imported finished product. This defines who must act and on what timeline.
3. Identify technical alternatives: Work with the technical department or specialized suppliers to identify substitute flame retardants that meet the same safety requirements without containing TBPH or other restricted substances.
4. Initiate the reformulation or supplier change process: Do not wait for the formal ban. Begin product testing with alternative materials, validate performance and regulatory compliance, and update technical datasheets and conformity declarations.
5. Monitor progress of the Stockholm Convention: Follow the approval process of the proposal submitted by the EU to anticipate final compliance timelines and adjust internal transition schedules.
6. Communicate with customers if appropriate: In sectors such as automotive or electronics, end customers may have their own restricted substance lists. Anticipating communication about the substitution process can be a competitive advantage.