The European Commission has effectively short-circuited the decaBDE debate by issuing a letter discussing the scope of its exemption.
The letter points out that the commercial grades of decaBDE used in plastics within the electronics industry “contain around three per cent impurities of [banned] nonaBDE”, and that, in the amounts used, the nonaBDE will exceed the 0.1 per cent RoHS threshold.
It takes the example of a polymer with 10 per cent of decaBDE. This would by default include 0.3 per cent of banned nonaBDE.
The commission states that this is not legally-binding guidance, and the European bromine lobby argues against it. The exemption is already the subject of legal proceedings.
You would be wise to check if any of this affects your product as part of your due diligence.
Polybrominated diphenyl ethers (PBDEs) are one of the two classes of bromine-based fire retardants banned by RoHS. DecaBDE was
exempted
by the Commission, seemingly against the will of the European Parliament.