Document 06JYwx5EqLBNxE8JwJ2MZkYDR

CEIR CEIR Answer to Echa consultation on PFAS restriction: Annex Question 8. Other identified uses - Analysis of alternatives and socio-economic analysis: Table 8 in the Annex XV restriction report provides a summary of the identified sectors and (sub-)uses of PFAS, their alternatives and the costs expected from a ban of PFAS. More details on the available evidence are provided in the respective sections in Annex E. For many of the (sub-)uses, the information on alternatives and socio-economic impacts was generic and mainly qualitative. In particular, evidence on alternatives was inconclusive for some applications falling under the following (sub-)uses: technical textiles, electronics, the energy sector, PTFE thread sealing tape, non-polymeric PFAS processing aids for production of acrylic foam tape, window film manufacturing, and lubricants not used under harsh conditions. More information is needed on alternatives and socio-economic impacts to conclude on substitution potential, proportionality, and the need for specific time-limited derogations. Therefore, specific information (if not already included in the Annex XV restriction report or covered in the questions above) is requested on alternatives and socio-economic impacts covering the elements listed in points a) to g) in question 6 above. Application (no finished list) Valves in chemical process industry Use Gaskets, seals, wear parts, diaphragm, inserts Valves in energy generation Gaskets, seals Property Resistance against aggressive chemicals Temperature resistance Low coefficient of friction High temperature resistance even in the presence of air borne oxygen PFAS FKM, FFKM, PTFE, PVDF, PFA FKM, FFKM, PTFE, PFA Valves in the pharmaceutical and biotechnological industry Submersible pumps in dewatering Coatings, seals, gaskets, diaphragm Seal, cable sheath Resistance to high temperatures and aggressive chemicals being used in CIP and SIP Low coefficient of friction Weathering resistance and low water uptake. PTFE, PVDF, FKM, FFKM, PFA PTFE, PVDF, FKM, FFKM, PFA Valves in other industries - Wastewater treatment - Dosing - HVAC - Cryogenic application - H2 production - other Spare parts for valves Machining industry - production of (PFAS AND NONPFAS containing) materials - production of (assembled) products - spare parts Seals, gaskets, diaphragms, cables, coatings, wear parts, bearings, ... Resistance against chemicals, temperature, weather, or a combination thereof. Safety. Use due to tribological functionality. energy efficiency, duration, safety Use due to hygienic aspects. health PTFE, FKM, FFKM, FPE, (PFPE), ETFE, ECTFE, PVDF, PFA, PCTFE Seals, gaskets, diaphragms, cables, coatings, wear parts, bearings, ... Seals, gaskets, coatings, production aids, sliding parts, .... To be specified by machine manufacturers Resistance against chemicals, temperature, weather, or a combination thereof. Safety. Use due to tribological functionality. energy efficiency, duration, safety Use due to hygienic aspects. health Temperature (changes), chemicals, steam, anti-stick properties, hygiene,... PTFE, FKM, FFKM, FPE, (PFPE), ETFE, ECTFE, PVDF, PFA, PCTFE PTFE FKM FFKM FPE (PFPE) ETFE ECTFE PVDF PFA PCTFE