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: 28/09/2021

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 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

OLDRATI GUARNIZIONI INDUSTRIALI S.p.A.

Via Giacomo Quarenghi, 2 - 24060 Villongo (BG) - Italy

Phone +39 035 9160111 Fax +39 035 9160112

P.IVA 01237700164 - Reg. Imprese di BG n. 01237700164 - R.E.A. n.185451

Cap. Soc. € 3.508.800,00

i.v. [email protected] | www.oldrati.com

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

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:

Oldrati is a company that made articles with FKM compounds that contain fluoropolymer and

other additives.

We do not producer

fluoropolymers itself and so we can’t make any declaration and we can’t

support the information about the chemical safety of the polymer reported in this document.

As articles’ producer we can only confirm that fluoropolymers are strategic material

irreplaceable across many key sectors/applications. Their replacement is unthinkable both

economically and at the level of performance.

Service application industries:

Automotive, Oil & Gas and generic industries use

Sincerely yours,

Name and signature

Paolo Morandi, R&D Group Director