Despite its effectiveness as a flame retardant, HBCD exhibits characteristics that make it extremely concerning for environmental and human health: it persists in the environment for extended periods, accumulates in living organisms, and can travel long distances through air, water, and migratory species. Studies have shown HBCD has endocrine-disrupting potential and can affect neurological development, particularly in vulnerable populations such as infants and pregnant women.
Due to these hazardous properties, HBCD was added to Annex A of the Stockholm Convention on Persistent Organic Pollutants in May 2013, with specific exemptions for its use in expanded polystyrene and extruded polystyrene in buildings. The Convention requires parties to eliminate the production and use of HBCD, though time-limited exemptions were granted for critical applications. The last production of HBCD stopped in November 2021 in China, marking the end of global HBCD manufacturing.
National Implementation Plans and HBCD Inventories
Under Article 7 of the Stockholm Convention, signatory countries are required to develop and periodically update National Implementation Plans (NIPs) that outline how they will fulfill their obligations under the Convention. A critical component of NIPs is the POPs inventory, which compiles information on past and present production and uses of listed chemicals in the country.
For HBCD, inventories must address several key areas: production and import/export of HBCD and HBCD-containing products, presence of HBCD in buildings and consumer products, waste management practices, and potentially contaminated sites. Since many products containing HBCD have long service lives—particularly building insulation with lifespans of 25 to 100 years—comprehensive inventories must estimate amounts throughout the entire product lifecycle.
The inventory process typically follows a tiered approach, with “Tier I” focusing on initial assessment through desktop research and import/export data analysis, while more comprehensive tiers involve stakeholder engagement, site visits, and detailed sampling. For countries that never produced HBCD domestically, the focus naturally centers on imported products and their eventual fate as waste.
Country-Specific HBCD Inventories
Georgia: Tracing the Chemical Through Import Patterns
Georgia's HBCD story is one of geographic dependency and timing. With no domestic production of HBCD or the polystyrene foams that contain it, the country has relied entirely on imports for its construction materials.
The analysis revealed a fascinating pattern tied to global HBCD phase-outs. Georgia's three largest suppliers—Turkey, Russia, and China—each followed different timelines for eliminating the chemical. Turkey, responding to the Stockholm Convention, actively phased out HBCD starting in 2019, switching to alternative flame retardants like brominated polymeric compounds and phosphorus-based options. China followed with its comprehensive ban in December 2021. This means that insulation materials imported from these countries likely contained HBCD only until these phase-out dates.
Russia presents a different story entirely. Without a nationwide ban, the country continues to produce materials that may contain HBCD, leaving a high probability that current Russian imports still carry the chemical into Georgia. This geographic patchwork of regulations creates an ongoing management challenge.
Georgia estimated that between 2015 and 2023, 244 to 1,222 tons of HBCD were imported into the country through insulation materials. In the case of textiles—specifically flame-retardant workwear with an estimated HBCD content of 2.2–4.3%—an additional 11.66 to 22.80 tons of HBCD were estimated. Although the textile sector represents a smaller source of HBCD compared to construction materials, it poses a more direct human exposure risk, as these garments are worn directly against the skin for several hours each day. The total amount of HBCD in Georgia is therefore estimated to range from a minimum of 256 tons to a maximum of 1,245 tons, representing a significant quantity that requires prioritization in future POPs management initiatives.
Particularly concerning is the extent of the legacy burden. The insulation materials imported over less than a decade contain substantial amounts of HBCD that will remain in buildings for the next fifty years or more. Georgian authorities have therefore designated HBCD monitoring and control as a priority for future initiatives related to persistent organic pollutants (POPs).
Bosnia and Herzegovina: Living with a Chemical Legacy
Bosnia and Herzegovina's HBCD inventory tells a story of what happens when a hazardous chemical enters a country's building stock and then seemingly disappears from view but not from existence. The country ratified the Stockholm Convention in 2010, yet HBCD wasn't even included in the first National Implementation Plan submitted in 2016. It was as if the chemical existed in a blind spot, present in thousands of buildings but absent from official recognition.
When researchers finally turned their attention to HBCD, they discovered a clear dividing line: 2014, the year alternatives became available and HBCD use in Bosnia and Herzegovina effectively stopped. Contacts with expanded polystyrene manufacturers revealed that HBCD stocks had been depleted and no company was using it anymore.
But the situation is more complex. The construction sector holds an estimated 59,000 tons of expanded polystyrene materials, a portion of which contains HBCD that will persist for decades. These materials are literally built into the walls of homes, schools, offices, and hospitals across the country. They're doing exactly what they were designed to do: insulating buildings and reducing fire risk. But eventually, those buildings will be renovated or demolished, and then what happens with HBCD?
The current answer is troubling. Bosnia and Herzegovina has no sound end-of-life management system for HBCD-containing materials. Construction waste follows one of two paths: disposal at local landfills or use as embankment fill in construction projects. Neither option is designed to contain hazardous chemicals. The regional landfill Smiljevići explicitly refuses to accept styrofoam construction materials according to its environmental permit—a decision that protects that particular facility but pushes the waste toward less controlled disposal sites.
Environmental testing at two landfills found no HBCD pollution in leachate or sediment, which might seem reassuring. However, researchers noted that the risk of contamination is highest during the initial stages of landfill waste degradation. The chemical time bomb hasn't gone off yet, but the materials are accumulating.
The situation exposes a gap in Bosnia and Herzegovina's regulatory framework. The Law on Chemicals was adopted in 2020 in the Federation of Bosnia and Herzegovina, but the adoption of necessary bylaws hasn't followed. The Brčko District hasn't even adopted laws controlling imports and exports. Without these regulatory tools, the country lacks the legal infrastructure to properly manage HBCD throughout its lifecycle. Guidance documents from the Stockholm Convention Secretariat on alternatives to HBCD and Best Available Techniques remain untranslated, inaccessible to the very industries that need them most.
North Macedonia: A Country Learning What It Doesn't Know
Macedonia's HBCD inventory, conducted for the first time in 2024-2025, reveals how much can be hidden in plain sight. The country has been importing products for decades, yet companies along the supply chain often have no idea whether those products contain hazardous chemicals.
The inventory process itself became an education campaign. Researchers organized meetings with the Chamber of Commerce, workshops with businesses, and consultations with government institutions from customs to health ministries. They sent questionnaires to companies across the chemical, construction, textile, and waste management sectors. The responses—or lack thereof—were telling. Out of 28 construction companies contacted, only one responded. Of 42 textile companies, just one replied. These businesses simply don't track HBCD in their supply chains.
What the inventory team discovered was reassuring in some ways and concerning in others. Local expanded polystyrene/extruded polystyrene manufacturers reported they haven't used HBCD in their products. This suggests Macedonia's construction sector may have largely avoided the chemical—but this finding comes with caveats. Imported finished products remain a question mark, and companies importing impregnated textiles stated they weren't aware of any HBCD content, which is very different from confirming the chemical isn't there.
Another dimension concerns the vehicle sector. Between 2012 and 2022, North Macedonia imported over 400,000 passenger vehicles, including Japanese models that historically contained higher levels of HBCD in interior materials such as seats, flooring, and door panels. These were everyday cars in which people come into direct contact with HBCD on a daily basis.
The inventory provides an important baseline, but it also highlights how strongly countries depend on information from manufacturers—information that is often unavailable.
Kazakhstan: From Soviet Legacy to Modern Challenge
Kazakhstan's HBCD story begins with an abandoned factory in Aktau, a reminder that hazardous chemicals don't disappear just because economic systems collapse. During the Soviet era, the AKPO polystyrene plant operated in this Caspian Sea city. When the Soviet Union fell apart, the plant couldn't secure raw materials from newly independent republics and eventually declared bankruptcy. Left behind in the ruins: 10 tonnes of hexabromocyclododecane, sitting as "historical pollution" until it was transferred to Zhasyl Damu JSC for eventual disposal.
Kazakhstan's first inventory (conducted in 2024-2025) revealed the challenge of being a large, import-dependent country. Products potentially containing HBCD arrived from all directions: carpets from Turkey, textile materials from China, motor vehicles from Japan, construction materials from Russia. The inventory team compiled import statistics showing hundreds of thousands of tons of goods that could contain HBCD, from the carpets in homes to the insulation in buildings to the upholstery in vehicles.
But Kazakhstan's real HBCD challenge isn't what's being imported today—it's what was imported yesterday and is being thrown away tomorrow. The country has identified 3,292 solid waste disposal sites, but only 18.2% meet environmental and sanitary standards. In some regions, the situation is dire: West Kazakhstan has just 0.96% of landfills meeting standards. Products containing HBCD—such as old carpets, packaging materials, and worn vehicle parts—end up in these landfills without adequate protection, meaning that every major municipal landfill is potentially contaminated with HBCD. The chemical slowly leaches out and accumulates in the environment.
The inventory process also revealed how little support exists for managing these chemicals. The Ministry of Ecology and Natural Resources handles legislative aspects, Zhasyl Damu organizes meetings and coordinates with local authorities, and independent experts collect data—but resources are limited. The list of persistent organic pollutants in Kazakhstan's environmental regulations still only includes the original 12 POPs from when the Convention was first ratified. HBCD and other chemicals added after 2009 exist in a regulatory gray zone, covered in principle but not specifically named in law.
Montenegro: Watching a Problem Grow
Montenegro offers a rare opportunity to see HBCD trends in real-time because the country has now completed inventories for two periods: 2007-2016 and 2017-2023. The results aren't encouraging—the problem is getting worse, not better.
During the earlier period, Montenegro was importing an average of about 40 tons per year of expanded polystyrene granules for insulation production. By the recent period, that figure had jumped to 58 tons per year. Finished polystyrene products saw an even sharper increase: from 1,882 tons annually to 3,454 tons. This dramatic growth reflects Montenegro's construction boom, particularly in coastal areas attractive to tourists and foreign investment.
The team found that only 12.5% of imported granules had HBCD explicitly listed in their safety data sheets, while the remaining 87.5% were unspecified. Interviews with ten construction companies revealed that all of them use only polystyrene-based products and do not consider alternative materials.
Waste management reflects broader regional challenges: while some construction materials end up at designated sites, polystyrene insulation is often mixed with municipal waste. Insulation accounts for about 1% of total construction waste, a seemingly small figure, but given the overall waste volume, it represents a significant amount of HBCD.
A comparison of the two periods shows a rising trend: although global HBCD production ended in 2021, both imports and estimated HBCD content in Montenegro actually increased. This paradox likely reflects a time lag between production phase-out and depletion of stockpiles, as well as the continued availability of products from Russia, where no ban has been implemented. The global phase-out is working, but not everywhere at the same pace, and Montenegro lies somewhere in the middle.
The trend points to a growing challenge: each year, more HBCD accumulates in buildings, creating a long-term legacy that will last for decades. Analysis of construction waste generated between 2011 and 2023 shows a sharp increase in 2021 and 2022, when post-pandemic recovery boosted building projects and overall construction activity. Economic growth and infrastructure development are therefore deepening the HBCD burden in the country.
Conclusion
The HBCD inventories from Georgia, Bosnia and Herzegovina, North Macedonia, Kazakhstan, and Montenegro reveal both common patterns and country-specific challenges in managing this persistent organic pollutant. Several key findings emerge from these assessments:
Legacy Burden: None of these countries produced HBCD domestically, yet all face substantial legacy burdens from imported products, particularly building insulation materials with service lives extending 50-100 years. Bosnia and Herzegovina's estimated 290-590 tons and Georgia's 256-1,245 tons of HBCD in existing buildings represent long-term management challenges that will persist for decades.
Import Timing Matters: The phasing out of HBCD production globally, particularly China's 2021 ban and Turkey's 2019 phase-out, directly affected import patterns. Countries that relied heavily on these suppliers for construction materials saw significant reductions in new HBCD inputs after these dates, though Russian imports continue to pose concerns due to the absence of domestic HBCD restrictions.
Waste Management Gaps: A critical weakness identified across all countries is inadequate end-of-life management for HBCD-containing materials. Construction waste typically ends up in municipal landfills or uncontrolled dumpsites without separation of hazardous materials, creating potential environmental contamination through leachate. The lack of specialized treatment facilities and clear disposal protocols for HBCD-containing waste represents an urgent need.
Regulatory and Institutional Challenges: While all countries have ratified the Stockholm Convention, implementation faces obstacles including incomplete chemical management legislation (particularly in Brčko District of Bosnia and Herzegovina), lack of accredited laboratories for HBCD testing, absence of Best Available Techniques (BAT) implementation in industry, and limited awareness among manufacturers and users about HBCD risks and alternatives.
Data Limitations: The inventories relied heavily on import statistics and estimation methods due to limited tracking of HBCD through product lifecycles. Stakeholder engagement revealed that many companies are unaware of HBCD content in their products, and customs data often lacks sufficient detail to definitively identify HBCD-containing goods.
Moving forward, these countries need comprehensive action plans addressing several priorities:
- establishing legal frameworks for proper disposal of HBCD-containing materials
- developing or designating facilities for environmentally sound waste treatment
- implementing monitoring programs for HBCD in environmental media
- raising awareness among construction and textile industries about alternatives
- translating Stockholm Convention guidance documents into local languages
- strengthening institutional capacity for POPs management
The estimated quantities—ranging from tens to hundreds of tons per country—may seem modest compared to global HBCD production figures, but they represent significant environmental and health risks in these regions. As buildings constructed during the peak HBCD use period (1980s-2014) reach end-of-life in coming decades, the challenge of managing HBCD waste will intensify.
The inventories compiled by these countries provide essential baselines for addressing this emerging waste stream and protecting both environmental and human health from this persistent organic pollutant.
