EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren

Europaudvalget 2022-23 (2. samling)
EUU Alm.del
Offentligt

Date: 23/9/21

Kind attention:

Mr. Martijn Beekman - Netherlands

Dr. Mandy Lokaj - Germany

Mrs. Jenny Ivarsson - Sweden

Mr. Toke Winther - Denmark

Mr. Audun Heggelund - Norway

Mr. Mark Blainey - ECHA

[email protected]

Through:

Pro-K Industrieverband Halbzeuge und Konsumprodukte aus Kunststoff e.V. (pro-K), Städelstr. 10,

60596, Frankfurt am Main, Germany

The members of pro-K mainly focus on processing of Fluoropolymers, part manufacturing and its applications,

the involvement of downstream users in PFAS process.

Subject:

PFAS restriction proposal & request for exemption of FLUOROPOLYMERS

Reference:

PFAS - Registry of restriction intentions until outcome (RoI) dated 15

July 2021

Dear Sir/Madam,

With regards to Registry of Intention (RoI) filed by 4 EU Member States (Germany, the Netherlands, Sweden,

and Denmark) & Norway for the restriction of PFAS, we, a member of fluoropolymer downstream user industry,

hereby, would like to share some salient facts related to the importance of fluoropolymers, critical

functionalities, performance and benefits of its applications to society, while acknowledging concerns regarding

PFAS emissions related to the use of fluoropolymers and their end of life.

Registry of Intention for PFAS restriction was announced by ECHA on 15

July 2021, to prepare a restriction

proposal for PFAS. Fluoropolymers are also included in the scope. The restriction proposal is intended to be

submitted to ECHA by 15

July 2022.

Fluoropolymers are a distinct subset of PFAS and are inherently safe, non-mobile, non-bio accumulative and

non-toxic. Fluoropolymers are different from other PFAS as they

do not share the toxicological and

environmental profiles

associated with PFAS of concern. Fluoropolymers have

unique set of physicochemical

properties,

they meet OECD polymer of low concern criteria, and are considered to have

insignificant

environmental and human health impact.

Fluoropolymers ensure safety, reliability, durability and critical performance in numerous technologies,

industrial processes and everyday applications that are important for human health, safety, and the

EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren

environment. With a unique combination of functionalities, fluoropolymers are irreplaceable across many key

sectors/applications. Alternatives to fluoropolymers, if exist, escalate safety risks, carbon footprint, technology

regression, and do not match the advanced performance of fluoropolymers. Most importantly, restriction on

fluoropolymers will make EU industry lose its technological superiority over other economies and could put

Europe’s climate and energy goals at risk. Overall, fluoropolymers contribute heavily to Europe’s socio-economic

status and are critical for the betterment of the society.

The fluoropolymer downstream user industry acknowledges the concerns regarding PFAS emissions due to the

use of fluoropolymers and end of life processes. We wish to assure the authorities and EU Member States that,

we are implementing Best Available Technologies to ensure reduction in PFAS emissions in a systematic way and

eventually eliminating them to achieve EU’s sustainability goals. Parallelly, we are consciously working on

recyclability and reusability to meet circular economy goal.

Fluoropolymers play an important role in achieving EU Green Deal objectives and UN Sustainable Development

Goals (UN SDG) because of their vital use in Lithium-ion batteries, Green hydrogen, Fuel Cell, Solar and Wind

energy. No new-age technologies are possible without the use of fluoropolymers. Restriction on the use of

fluoropolymers would adversely impact implementation of these technologies crucial for planet’s future as well

as in all existing applications vital for the society.

Considering the benefits of fluoropolymer applications to environment and society, low PFAS emissions and

initiatives being taken by the processing industry to further minimize emissions and closing the loop by

implementing circular economy wherever possible, we request for a

complete exemption of fluoropolymers

from the PFAS restriction proposal.

Fluoropolymers processed by us:

PTFE & PFA

Service application industries:

We manufacture PTFE and PFA lined piping products. These are used principally

by our customers for the manufacture of pharmaceuticals, fine chemicals, and electronic components. They are

also used across a wide variety of other industries to handle corrosive process media.

Important Note.

As far as I can see, the use of fluoropolymers in the manufacture of pharmaceuticals is not a

use that has been considered as part of the whole exercise to consider a restriction/ban of PFAS.

Sincerely yours,

David MacGregor

Engineering Manager

Corrosion Resistant Products

Todmorden Rd

Littleborough

OL15 9EG