Document 0qmV0Kb20MadY8dV47XE4yZDm

Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 1(12) FMV submission to the open consultation of Per- and polyfluoroalkyl substances (PFAS) Content 1 Ammunition............................................................................................................................................2 2 Fluorinated gases....................................................................................................................................3 2.1 HVACR (Heating, ventilation, air conditioning, refrigeration agents) .................................. 3 2.2 Fire suppressants in military vehicles and naval vessels incl. submarines ............................. 4 3 Fluoropolymers ...................................................................................................................................... 6 3.1 Fuel filters for aviation..................................................................................................................6 3.2 Fuel handling equipment .............................................................................................................. 6 3.3 Underwater weapons.....................................................................................................................6 3.4 Underwater sensors ....................................................................................................................... 7 3.5 Engine components ...................................................................................................................... 7 4 Medical devices.......................................................................................................................................8 4.1 Medical devices; equipment ......................................................................................................... 8 4.2 Medical devices; consumables (single use and multi-use)........................................................9 5 Paints and cleaning fluids....................................................................................................................10 6 Lubricants..............................................................................................................................................11 6.1 Lubricants .....................................................................................................................................11 6.2 Hydraulic fluids for aviation.......................................................................................................11 7 Electronics, batteries and semi-conductors......................................................................................12 7.1 Semi-conductors ..........................................................................................................................12 7.2 Batteries.........................................................................................................................................12 Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 2(12) 1 Ammunition FMV has identified the need for derogation for the use of fluoropolymers (which is one of the subgroups of polymeric PFAS) in coating explosive grains. FMV also identifies a need for a derogation for PFAS as a part of the composition of pyrotechnic ammunition. FMV procures a large number of ammunition products containing fluoropolymers. The assessment is that fluoropolymers in explosives can be found in ammunition for all anti-tank weapons procured by FMV and in artillery ammunition, in cases where ammunition with low sensitivity properties has been required by the Swedish Armed Forces, SwAF. Added to this is the area of pyrotechnic ammunition such as countermeasures ammunition (flares), protective smoke, tracers and igniters where PFAS substances often is a part of the composition. PFAS and fluoropolymers are used for various functions in the ammunition but mainly as booster charges or main charges. An example of these products is PBXN-5, which contains VitonTM. VitonTM is a type of synthetic rubber, belonging to the group of fluoropolymers (PFAS). The function of the plastic is to encapsulate the explosive grains in order to give the explosive so-called low sensitivity properties, IM (insensitive ammunition). IM ammunition provides an increased ability, due to that the ammunition reacts less violently in the event of fire or if hit by enemy fire. This property and function of PFAS and fluoropolymers in ammunition is supported by the response to the consultation given by GICAT (#4528). Qualification of military ammunition is strictly regulated via international military standards. This means that the process of developing and qualifying an explosive that can replace, for example, PBXN-5 is long. After the explosive has been qualified, a requalification of the products in which the explosive is included also needs to take place. This will lead to FMV having difficulties in procuring the necessary ammunition for the SwAF needs, without a derogation for the products described above. New ammunition (without PFAS) will also probably have poorer low-sensitivity properties over a period of time, until replacements are developed with the same excellent properties as todays fluoropolymers. Hence, FMV propose two derogations related to ammunition, with a duration of at least 13.5 years after EiF, for: - use of fluoropolymers to encapsulate explosive grains in a plastic matrix. - use of PFAS as a part of the composition of pyrotechnic ammunition. Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 3(12) 2 Fluorinated gases 2.1 HVACR (Heating, ventilation, air conditioning, refrigeration agents) Military vehicles and naval vessels are equipped with mobile air conditioning equipment containing fluorinated-gases (f-gases) that are considered PFAS. The specific function of air conditioning equipment is to provide military personnel with a comfortable environment in a stressed and sometimes dangerous situation. No non-PFAS alternatives for mobile air conditioning are currently technically feasible for general defence purposes, combat vehicles or naval vessels. The non-PFAS alternatives available today are not suitable for mobile air conditioning equipment mainly due to safety issues since they are flammable. Existing vehicles and vessels are covered by the proposed derogation 5.i "maintenance and refilling of existing HVACR equipment put on the market before [18 months after EiF] and for which no drop-in alternative exist until 13.5 years after EiF". However, FMV is deeply concerned regarding the possibility to, during this (in defence perspective) short time frame, find a suitable cooling media and also to re-design and re-build all vehicles and ships already in use. Key issues includes workshop availability as well as defence capacity when many vehicles or vessels at the same time are put out of operation. For submarines it is crucial that the derogation duration is extended well beyond the proposed 13.5 years, due to the unique onboard environment. The consequences of not extending the derogation duration for HVACR-agents used in submarines will have major consequences for the SwAF operational capability. FMV also stresses the fact that contracts already agreed upon, where the design of a vehicle or vessel is decided, will be valid both before and after the estimated EiF of the proposed restriction. Hence, FMV propose that the potential derogation 5.dd "[use as refrig erants and for mobile air conditioning in vehicles in military applications until 13.5 years after EiF]" is reconsidered to be included in the restriction proposal. For derogation 5.i., FMV propose an extended derogation duration well beyond 13.5 years after EiF. A wide variety of substances containing PFAS are today used as cooling media in refrigerators and freezers used in military healthcare, for example mobile or portable coolers for pharmaceuticals, blood and other infusates. Some devices are commercially available but more common is that they are developed from the SwAF specific needs. When in use the mobile and portable coolers are a substantial part of the emergency care since they are used for transportation of crucial blood for wounded soldiers as well as necessary pharmaceuticals. A ban on PFAS without derogation for maintenance and refilling of cooling media would have a major effect on treatments and procedures in the short term since none or at least very few PFAS free coolers are available today. Only one PFAS free medical cooler have been identified so far with a cost 5 times a conventional cooler; hence, more resources are needed. Performance including long term storage and use need to be evaluated. FMV foresee an outcome which includes a major tactical and logistical effect. Hence, FMV propose to include a new derogation for placing on the market of portable coolers used in healthcare, with a duration of 6.5 years after EiF. To be able to maintain and refill the existing coolers, the proposed derogation 5.i is necessary to include in the restriction. Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 4(12) 2.2 Fire suppressants in military vehicles and naval vessels incl. submarines Comments concerning derogation 5.m: "clean fire suppressing agents where current alternatives damage the assets to be protected or pose a risk to human health until 13.5 years after EiF". FMV foresee great difficulties to fulfill the requirement to implement new fire suppressing agents without PFAS within the proposed duration of the derogation (13.5 years after EiF). The time for implementation must be elongated, hence the derogation duration must be extended. There has been little, if any, research in the field of fire suppression agents suitable for use in confined spaces with personnel in recent years. This means that research and development activities, as well as testing and qualifications processes, must be performed before an alternative can be presented. Some of the current suppliers have stated that they will not develop new agents due to commercial reasons. Therefore, a period of at least 5 years is needed for the development of the agent itself. In parallel, the development of an adopted or new fire suppression system for platform integration must be conducted. This may add a 1-2 years. This means that more than half of the proposed derogation duration of 13.5 years will pass before any modification of the vehicles and vessels can take place. Based on the experience from the shift from halon-based (Halon) fire suppressants to HFC-based (Deugen-N) fire suppressants, the exchange of suppression systems in the whole vehicle fleet will take a substantial amount of time. One key element for a change is workshop capability. The modification of the Swedish fleet, when changing from halon to HFC-based system, was decided in 2003 and will be concluded next year, 2024. Even if the process would be more efficient this time, a time frame of at least 25 years is required to fully comply with the ban on PFAS fire suppressing agents. Replacing the clean fire suppressing agent with a substance not considered clean would have devastating consequences for the SwAF. It is of outmost importance that a replacement to the current suppression agent is "a clean agent" from two perspectives: since the crew compartment is a confined space, which the crew is not supposed to leave, the agent shall not be toxic or produce toxic substances when used. The agent shall in addition not leave any solid substances that have to be cleaned before the crew can continue its mission. The above is also valid for extinguishing systems in engine compartments. An agent that is not clean and damages the engine cannot be used since a demobilized vehicle will put the crew, the soldiers, in a dangerous situation since they will have to abandon the vehicle to escape from the enemy. This is valid for suppression systems in crew compartments as well as in engine compartments. As the Halon Alternatives Research Corporation (HARC) states in their response to the consultation (#4457), damage to assets and risk to human health are clearly important parameters but there are several other outstanding features of PFAS-containing fire suppressants. Speed of extinguishment, time required for agent discharge as well as ability to suppress re-ignition are also crucial properties when used for example in a critical situation. Other important properties are weight of the agent and equipment as well as space required for the agent and equipment. Submarines are one type of vessel that has to be specifically considered. Enclosed in a very tight space, below the surface of the sea, the crew has no possibilities to escape and the only way to suppress a fire is through clean fire suppression. Since the breathing air inside a submarine cannot Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 5(12) easily be replaced, the fire suppressing agent must be non-toxic and the oxygen level must be kept at the correct level. Submarines are even more sensitive to changes in design where re-design will affect other systems that also need to be redesigned, which will have major consequences for the entire system. A transition has major impacts on operational capability and availability for the naval forces within the SwAF. Hence, for submarines it is crucial that the derogation duration is extended well beyond the proposed 13.5 years, due to the unique design and unique onboard environment. Consequences of not extending the derogation duration for submarines will have major consequences meaning delayed delivery of capability to the naval forces as well as endangering the submarine crew working environment. Since most of the countries in the EU are members of NATO, regulations in the United States has a great impact on what fire suppressing agents that are possible to use. Host nation support of US military equipment must be possible within EU no matter which fire suppression agent is used. Regarding fire suppressing agents, Sweden has to follow the requirements of NATO standards, eg. STANAG 4317, when choosing fire suppressing agent. The consequences of a full ban on PFAS, including the ban of clean fire suppressing agents, is a dramatically raised risk level for the crew. Even with the proposed derogation duration of 13.5 years, a transition to PFAS-free efficient fire suppression system in military vehicles will not be achieved within the proposed time frame since an acceptable PFAS-free substitute will not be fully implemented by then. Based on the experience from the shift from halon-based (Halon) fire suppressants to HFC-based fire suppressants, at least 25 years is needed for a controlled and secure transition. Hence, FMV propose an extended duration for the proposed derogation 5.m, as follows: 5.m. "clean fire suppressing agents where current alternatives damage the assets to be protected or pose a risk to human health until 25 years after EiF". Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 6(12) 3 Fluoropolymers FMV propose derogations for fluoropolymers within several fields of use. PFAS containing plastics and elastomers, fluoropolymers and perfluoropolyethers, are used for example as sealants and gaskets, cables and filters in several types of defence applications. They are generally chosen, despite their higher price, due to their excellent ability to withstand harsh conditions over time. 3.1 Fuel filters for aviation The removal of contaminants, including water, from jet fuel is essential and a requirement for airworthiness. Water contamination in the jet fuel can lead to engine problems, flight disturbances and in worst case an aircraft crash. Contaminants, including water, are removed by passing the jet fuel through filters all along the whole distribution chain. The common practice within the aviation industry (civilian as well as military) is to filtrate the fuel at every fuel transfer. The most common method to filtrate jet fuel is to use filter-water separators, which compose of two different types of filter elements, one type to remove dirt and coalesce water and a second type to separate water. The filter that separates the water is made of fluoropolymers, eg. Teflon or PTFE. As of today, there are no qualified fluoropolymer or PFAS free alternatives to remove water from jet fuel, neither for military nor for civilian aviation. Qualifying a new filter or filter technique will take several years and hence a derogation is required to sustain airworthiness. Without a derogation, airworthiness will be compromised and this would affect the operational capability in the flight domain to a severe extent. Hence, FMV propose a derogation for fluoropolymers in fuel filters for aviation, with a duration of at least 13.5 years after EiF. 3.2 Fuel handling equipment For fuel handling, especially for elastomers in contact with aviation fuel, fluoropolymeric parts of the equipment are common. These polymeric materials are used as gaskets, O-rings and seals within fuel handling equipment. One common material used is VitonTM which is chosen because of its outstanding ability to withstand harsh conditions. Finding suitable substitutes for fluoropolymers is a challenge due to the harsh and diverse chemical environment that these elastomers must withstand, including a wide temperature span. Today few, if any, replacement materials without PFAS are available on the market and therefore a lack of performance is expected. Qualifying possible replacements will be costly and time consuming and as all development and qualification processes within the field of aviation it will require several years to qualify replacements. Hence, FMV propose a derogation for fluoropolymers in fuel handling equipment, with a duration of at least 13.5 years after EiF. 3.3 Underwater weapons Underwater weapons (torpedoes and naval mines, mine disposal devices etc.) are complex in their composition and the performance demands of seals, gaskets and packing adhesives is extreme in ensuring that these weapon systems work in a harsh environment. One example is the use of hydrogen peroxide for propulsion of torpedoes. To keep hydrogen peroxide inside its container the sealing must withstand harsh conditions. A leakage of hydrogen peroxide will not only result in a lack of performance but also cause a major safety issue since both energy and oxygen will be Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 7(12) released at the wrong time. Replacement products must be able to meet the same level of performance as existing seals and gaskets without changing the design of underwater weapons and thereby sacrificing operational capability. At present there are no other options than fluoropolymers as sealants for this type of harsh conditions caused by an aggressive chemical environment. For a deeper understanding and further evidence, FMV refer to the expected public consultation submissions of Saab AB. Hence, FMV propose a derogation for fluoropolymers in underwater weapons, with a duration of at least 13.5 years after EiF. 3.4 Underwater sensors Underwater sensors (sonar equipment etc.) are complex in their composition and the performance demands of seals, gaskets and packing. The systems are exposed to high external pressures but also an internal aggressive (cooling agents) environment. Replacement products must be able to meet the same level of performance as existing seals and gaskets without changing the design of underwater sensors and thereby sacrificing operational capability. At present there are no other options than fluoropolymers as sealants. Hence, FMV propose a derogation for fluoropolymers in underwater sensors, with a duration of at least 13.5 years after EiF. 3.5 Engine components Higher engine operating temperature helps increase efficiency and reduce emissions. Together with a low fuel consumption it leads to longer intervals between refills; hence an engine operating with less interruption and increased reliability. In some sealing locations in engines, the temperature can reach well above 200C which can only be withstood by fluoropolymers. To ensure sealing at elevated temperature the use of fluoropolymers or perfluoropolyethers is required to meet the combination of lifetime, fluid compatibility and temperature requirements. Chemical resistance is also a requested property of engine components and is necessary for sealings as well as cables and wires inside, or in close contact with the engines. Fluoropolymers are outstanding in their ability to withstand such harsh conditions and non-PFAS elastomeric solutions will not withstand the thermal or chemical exposure load. Hence, FMV propose a derogation for fluoropolymers in engine components, with a duration of at least 13.5 years after EiF. Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 8(12) 4 Medical devices 4.1 Medical devices; equipment Over 400 000 types of medical equipment exist on EU's internal market and many of them use PFAS components or components including PFAS. PFAS containing parts are also used in the production or during maintenance activities. Virtually all are commercial-off-the-shelf (COTS) and commercially available and CE-marked according to the medical devices Directives or Regulations. Many electronic medical devices contain PFAS, e.g. ventilators, oxygen administrators, pulse oximeters, ultrasonic scanners and defibrillators. PFAS is also an essential component of sealants, gaskets for oxygen or high/low temp applications and are also used in connectors, valves, displays, cables, batteries and as coatings. PFAS substances are chosen because of their ability to withstand harsh conditions and in high-pressure oxygen equipment, PFAS sealings are crucial due to fire safety. It is believed that certain device manufacturers will have challenges replacing certain PFAS containing components, especially in the short term. Development is believed to be driven by the civilian healthcare sector and by the fact that estimated time on the market is 5-7 years for a certain medical device type. From an FMV point of view this estimated time on the market is short with the consequence that FMV will have to replace stored medical devices, obtain new spare parts and/or obtain consumables more often than ordinary military custom made materiel. . One of the experiences made from the covid-19 pandemic was the fact that there is a need to keep equipment in storage. This is also in line with how FMV equips the SwAF; a lot of material is procured to be stored for a critical mission or situation. Also, spare parts are procured and stored for many years. The full PFAS ban is likely to have highest effect on sealants, gaskets, O-rings for e.g. oxygen devices and systems, cryo temp systems or high temperature/pressure systems and spare parts for such medical devices. FMV foresee a risk of stored equipment not being fit for use in a critical situation due to non-existing spare parts and consumables for stored equipment. If PFAS free spare parts cannot be obtained for already stored medical ventilators, oxygen systems, it will have a major effect on tactical performance and the ability to save lives. Regarding cleaning fluids for oxygen-enriched environments (derogation 5.l) FMV would like to stress the outstanding properties of PFAS and fluoropolymers when it comes to harsh conditions and oxygen-enriched environments. For this specific technical application PFAS is chosen because of its ability to withstand ignition and fire and thereby creating safe surroundings and preventing explosions. Derogations from the full PFAS ban are necessary also for other components than cleaning fluids in enriched or high concentrate or high-pressure oxygen environments, such as high pressure gas cylinders, valves, compressors, sealants, gaskets as well as for certain components inside ventilators for medical use. Hence, in line with FMVs response to the product category Paints and cleaning fluids, FMV propose an extended derogation duration, well beyond the 13.5 years after EiF, for proposed derogation 5.l "cleaning fluids used in oxygen-enriched environments until 13.5 years after EiF". FMV also propose that the potential derogation 6.o "applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods until 13.5 years after EiF" will be reconsidered for inclusion in the Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 9(12) final version of the restriction and that the scope of derogation 6.o is expanded to include not only vehicles but also medical equipment. 4.2 Medical devices; consumables (single use and multi-use) PFAS have been used for a long time, mainly as coatings, in several types of consumables in order to have dirt and water repellant properties, facilitate low friction catheters, facilitate adhesion etc. There are already today many medical device consumables which are deemed PFAS free. It is likely that adequate replacement consumables will be marketed even more for most application areas. Most items are simple or of a less complex design and hence, should be more easily replaced if needed. Several items are believed to have PFAS but a lot of work is ongoing to make these PFAS free. A PFAS ban is likely to have a minor effect given the EiF dates. Likely, higher costs for PFAS free items will also apply in this category but performance will likely not be affected. One group of concern is wound dressings for burns. Burns are a quite common injury in our area with explosives and fire. The treatment of burns, especially severe burns, is a very specific field within trauma care and burn wounds are subject to special care. It is FMV's understanding that a derogation is needed since no alternatives for treating burn wounds exist today (or have inferior clinical performance and entail higher patient pain or discomfort). FMV therefore advocates the potential derogation 6.i to be considered as a valid derogation. The derogation proposed for tubes and catheters (6.c), with a duration of 13.5 years after EiF, is perceived as adequate. Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 10(12) 5 Paints and cleaning fluids Comments concerning derogation 5.k "Industrial precision cleaning fluids until 13.5 years after EiF." and 5.l "Cleaning fluids for use in oxygen-enriched environments until 13.5 years after EiF." Maintaining oxygen gas manometers includes a cleaning fluid containing PFAS. PFAS is chosen due to its property to withstand ignition and fire in an oxygen rich environment and a substitute is not available. Development, testing and qualification of a new product is estimated to take longer time than the suggested 13.5 years. Hence, FMV propose an extended derogation duration (beyond 13.5 years after EiF) for cleaning fluids, especially those intended for oxygen-enriched environments. For aviation, PFAS containing paints are sometimes chosen for certain applications. One example is the corrosion protection and surface treatment of the interior of the fuel tank where the surface treatment must withstand chemicals and other harsh conditions. The requalification of a new surface treatment takes at least 2 years, and before that development and testing has to be performed. If the paint is subject to requirements in a standard document, the standard has to be updated which adds another 3-5 years to the process. Failure to protect the interior of a fuel tank is closely connected to the airworthiness and proper functioning of the aircraft. Hence, FMV propose that the potential derogation 6.o "[applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods until 13.5 years after EiF]" is reconsidered to be included in the final version of the restriction. FMV also propose an extended derogation duration (beyond 13.5 years after EiF) regarding derogation 5.i "maintenance and refilling of existing HVACR equipment put on the market before [18 months after EiF] and for which no drop-in alternative exist until 13.5 years after EiF". Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 11(12) 6 Lubricants 6.1 Lubricants Lubrication of military applications is necessary for defence ability. Some of the lubricants (oils and greases) for special applications include PFAS. The lubricants are used for naval applications as well as aviation and army applications and they are common also in civilian vehicles. These lubricants are fluorinated synthetic oils, which are non-reactive to oxygen, hydrogen peroxide, ammonia and other chemicals and these oils are also non-flammable. The lubricants containing PFAS are specifically chosen to withstand harsh conditions and they are the only available alternative on the market. The ability to withstand hazardous chemicals and to avoid ignition is very important to prevent fires, accidents and explosions and contributes both to the safety, function and reliability of the materiel. The qualification of new products for these applications is very complicated, costly and time-consuming. Since no substitutes are known on the market today, the proposed derogation duration of 13.5 years is a minimum. Hence, FMV strongly supports the proposed derogation 5.s "Lubricants where the use takes place under harsh conditions or the use is needed for safe functioning and safety of equipment until 13.5 years after EiF" but propose an extended derogation duration (beyond 13.5 years after EiF) for a controllable transition. 6.2 Hydraulic fluids for aviation The Swedish Air Force is dependent on hydraulic fluids, which contains PFAS. The products has higher self-igniting temperature than other aircraft hydraulic fluids and the use strongly contributes to the safety of the aircraft. The time to substitute and qualify alternative hydraulic fluids for an aircraft is depending on flexibility of given standards, market availability and the manufacturers willingness to qualify and accept alternative hydraulic fluids. It is important to note that not all military aircraft in use in the Swedish Air Force are built within the EU. If the qualification process is possible, it will be very costly. Without derogation 5.o "additives to hydraulic fluids for antierosion/anti-corrosion in hydraulic systems (incl. control valves) in aircraft and aerospace industry until 13.5 years after EiF", no flights can be made. This would severely affect the operational capability of the Swedish Air Force. Hence, FMV propose an extended derogation duration (beyond 13.5 years after EiF) for hydraulic fluids for aviation. Unclassified Date 2023-09-12 FMV Document ID 23FMV3911-3 Document number n/a Subject type 1.3 Page 12(12) 7 Electronics, batteries and semi-conductors 7.1 Semi-conductors In an ever-so-increasingly connected world we heavily rely on electronic devices such as computers, smart phones and transmission networks. The access to digital technologies is an essential, even vital, part of most European citizens' lives and the defence sector is no exemption. Electronic devices are used in many different military applications, e.g. unmanned aerial systems (often referred to as "drones"), weapon systems, communication devices, radars, satellites, electronic control units for vehicles and many more. Semiconductors are central to the digital economy. However, the vast majority of semiconductors are produced outside of Europe. A number of governmental reports and memoranda have identified the importance of semiconductors and the necessity of sustainable supply chains, e.g. from USA and EU. FMV welcomes the European Chips Act to increase production of semiconductors within the EU to secure supply chains. However, such initiatives will likely have a longer timeframe and planning horizon than the PFAS restriction proposal. By the semiconductor industry PFAS is considered being essential to the production of semiconductors and must therefore be reviewed in the light of the ambitions for an increased production and demand. A shortage of semiconductors on a global scale occurred in conjunction with the COVID-19 pandemic. There is a risk of continuation or escalation of the shortage in case there is no derogation for the semiconductor manufacturing process, especially considering an expected large increase in demand between 2022 and 2030 as reported by the EU. Hence, FMV propose that the potential derogation 5.ee "[the semiconductor manufacturing process until 13.5 year after EiF]" is reconsidered to be included in the final version of the restriction. 7.2 Batteries FMV procures large amounts of different types of batteries for the SwAF, for instance lithium-ion, lithium primary (non-rechargeable), nickel-cadmium and nickel metal hydride, which all contain PFAS. The batteries are used in many different applications and scenarios and they are crucial for the SwAF operational capability. For example, vehicle functionality, communication equipment, back-up power systems and field hospitals all relies on these types of batteries. In addition, batteries play a significant role in the effort to decrease fossil fuel dependence in the SwAF. Although lead-acid batteries are usually free from PFAS, they are not suitable for all applications due to their low energy density, high maintenance and short life-time. In addition, lead has recently been restricted by ECHA for use in portable batteries. As RECHARGE (comment #3925) highlights in their report, PFAS plays an essential role for both safety and functionality in most battery types and there are no suitable replacements available until massive research breakthroughs are made. Hence, FMV propose a derogation for use of PFAS in batteries, for a duration of at least 13.5 years after EiF.