What is the regulatory status of hexabromocyclododecane (HBCDD) in the EU, the US and China?

Summary: HBCDD is effectively banned in the EU and China as a Stockholm Convention persistent organic pollutant (POP). In the US it isn't banned: EPA has found unreasonable risk, but I found no final risk-management rule.

How I searched: I searched by name, "HBCDD"/"HBCD" and CAS 25637-99-4 / 3194-55-6. EU sources were the ECHA Candidate List, Annex XIV and authorisation decisions, Annex XVII, CLP Annex VI, the EU POPs Regulation list and the EU PIC (export/import) register. For the US I used the TSCA Inventory, Significant New Use Rules (SNURs), EPA's TSCA risk evaluations and the 2024 Chemical Data Reporting (CDR) cycle. For China I used the Ministry of Ecology and Environment (MEE) lists listed below. Two gaps (the US rule and China's "new pollutants" list) were checked on epa.gov, federalregister.gov and mee.gov.cn; those points rest on search snippets only.

EU: banned under the POPs Regulation

• POPs Regulation (EU) 2019/1021: listed in Annex I Part A and Annex IV since 01-Mar-2016. That means it's prohibited, and waste concentration limits apply ^[1][2].
• REACH Candidate List: added 28-Oct-2008 as PBT (Art. 57(d)). The group entry covers the 25637-99-4 substance and the individual isomers ^[3][4].
• Annex XIV (authorisation list): entry 03, sunset date 21-Aug-2015 ^[5]. The one authorisation (C(2015) 9812, held by EPS/polystyrene producers) has expired ^[6].
• Annex XVII: no HBCDD entry found.
• CLP Annex VI (index 602-109-00-4): classified Repr. 2 (H361) and Lact. (H362), signal word Warning, applied since 01-Dec-2013 (ATP03) ^[7][8].
• PIC Regulation 649/2012: in Annex I Part 3 and Annex V, so it is banned for export (Rotterdam Convention Annex III) ^[9].
• Stockholm Convention: listed in Annex A (elimination) by decision SC-6/13 ^[10].

US: unreasonable risk found, but no ban

• TSCA Inventory: both CAS numbers are ACTIVE and carry the "S" flag; 3194-55-6 also carries "TP" ^[11][12].
• SNUR (40 CFR 721), 80 FR 57293, effective 2015-11-23: anyone making, importing or processing HBCD for consumer textiles (other than in motor vehicles) must notify EPA 90 days in advance ^[13].
• TSCA section 6(b) risk evaluation:
  • HBCD was one of the first 10 chemicals; EPA issued its risk evaluation in September 2020 ^[14][15].
  • The June 2022 revision concludes that HBCD as a whole presents unreasonable risk to health and the environment ^[16].
  • The risk is driven by import, processing (formulation, articles, recycling of XPS/EPS foam), building-material installation and demolition. No unreasonable risk to consumers was found ^[17][18].
• Section 6(a) risk-management rule: EPA says it will propose one (Federal Register snippet). I found no official record of a proposed or final rule.

China: banned under Stockholm implementation

• MEE et al. Announcement 2016 No. 84: production, use, import and export banned from 26 Dec 2016. Two exemptions applied: EPS/XPS in buildings, under registration that in principle ended 25 Dec 2021; and laboratory-scale research or reference standards ^[19].
• Customs trade bans: included in the 8th Prohibited Import Goods Catalogue and 7th Prohibited Export Goods Catalogue (MOFCOM Announcement 2023 No. 21, 2023-06-08). HS code is 2903890020; the five CAS numbers listed are 25637-99-4, 3194-55-6 and 134237-50-6/51-7/52-8 ^[20].
• Priority Controlled Chemicals List (Batch 1): entry PC012, Announcement 2017 No. 83 ^[21].
• Key Controlled New Pollutants List (2023): in force from 1 March 2023. HBCDD is in the "phased-out" category: production, processing/use, import and export are prohibited (MEE search snippet).
• IECSC inventory: listed in the 2013 edition (CAS 25637-99-4) ^[22]. Being listed doesn't override the bans above.
• Severely Restricted Toxic Chemicals List (2023 edition): no HBCDD entry found.

Sources:

• Federal Register: HBCD revised TSCA risk determination (2022)
• MEE: 重点管控新污染物清单（2023年版）