Ms Cristina, de Avila, DG ENV
cristina.de-
Ms Fulvia Raffaelli, DG GROW
Ms Claudia Canevari, DG ENER
Mr Philip Owen, DG CLIM
Brussels, 15
th
July 2021
Reference: Forthcoming REACH restriction proposal on per- and polyfluoroalkyl
substances (PFAS)
PU Europe, the European Federation of polyurethane insulation manufacturers, represents
the interest of one of the most efficient insulation materials available on the market.
Our industry supports the European Green Deal and the headline objectives of the Chemicals
Strategy for Sustainability (CSS), but we take the pen today to highlight to you a possible
negative development in relation to pre-legislative REACH activities on per- and
polyfluoroalkyl substances (PFAS,
also known as the “forever chemicals”).
Firstly, you must know that the use of blowing agents
1
in the production of rigid PU foam is
critical to achieve the exceptional insulation properties of our products. For certain
applications, in-situ manufacturing of bespoke insulation and discontinuous production lines,
a selection of Fluorinated gases are used as blowing agents. Committed to make EU
regulations success stories, our industry is right now finalising its transition to two low Global
Warming Potential (GWP) substances: HFO-1336mzz-Z and HCFO-1233zd-E
2
.
Then, in spring 2020 a call for evidence on the use of PFAS was launched by Germany, the
Netherlands, Norway, Sweden and Denmark, and their
entry to the Registry of Restriction
Intentions has been released today.
A
“group” of substances approach, relying on a
broad
definition of PFAS (including F-Gases), has been chosen and this is a source of concern for
our industry.
With this letter, PU Europe would like to draw your attention to the potential consequences
that an unaltered scope of the PFAS restriction, which inaccurately grant persistency and
bioaccumulation properties to all the substances covered and considered to be PFAS, could
have for our industry and the European Union objectives. We understand the will of
legislators to address substances that ultimately degrade into TFA (trifluoroacetic acid and
its salts), however scientific literature reports that this is not the case for HFO-1336mzz-Z
and HCFO-1233zd-E
3
.
PU Europe will continue to make its case to the five REACH Competent Authorities for the
two above mentioned substances not to be covered by the final restriction proposal, as
Blowing agents are used to produce a cellular structure during a foaming process. Those gases remain
trapped inside the closed foam cells minimising in this way the heat transfer. This enables the blowing
agent to positively impact foam properties, including the insulating value.
2
Ahead of the 2023 deadline set in the Fluorinated Gas Regulation for the HFCs phase down, our
industry has already almost completed its transition from HFC-365mfc and HFC-245fa to HFO-
1336mzz-Z and HCFO-1233zd-E and mixtures. Those two substances present the advantage of
having 99% lower GWP a nearly zero ODP (Ozone Depletion Potential).
3
Theoretical TFA yield assumed to be below 4% and 2% respectively.
1
PU Europe AISBL
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Rue Belliard 65, B-1040 Brussels
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www.pu-europe.eu
VAT BE 0870.426.629 RPM
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