Document 1QwD0D3kQrekax2kr4o47yrMK
From: Sent: To: Subject:
Jenny Ivarsson den 30 november 2023 09:56
@epeeglobal.org' Sv: PFAS Restriction proposal - Meeting request with EPEE
Dear Mr Roussel, Thank you for your e-mail. We appreciate your invitation to a meeting, but we will have to decline. The 6-month consultation period ended on September 25, and the dossier submitters and the scientific committees of ECHA can only take into account substantiated information that came in through this consultation. We will take any relevant information into account in the updates of our proposal.
Best regards, Jenny Ivarsson
Jenny Ivarsson Strategic advisor Development of Legislation and Other Instruments Department\Proposals for Classification and Restriction Swedish Chemicals Agency Direct: +46 8 519 41 363 Tel: +46 8 519 41100 www.kemikalieinspektionen.se
Fran: Manon Roussel <
_@ epeeglobal.org>
Skickat: den 28 november 2023 17:32
Till: Per Angquist <
@kemi.se>; Jonas Falck <
<
@kemi.se>
Amne: PFAS Restriction proposal - Meeting request with EPEE
_@kemi.se>; Lars Andersson
Dear Mr Angquist, Mr Falck and Mr Andersson,
I hope you are doing well!
I am happy to contact you on behalf of EPEE, the voice of the Refrigeration, Air Conditioning and Heat Pump (RACHP) manufacturers in Europe, an association based in Brussels. In the context of the PFAS Universal Restriction proposal submitted to the European chemical agency ECHA, we would like to highlight to you and your ministry our concerns and recommendations.
Indeed, the proposal covers a wide range of fluorinated gases, used in our sector as refrigerants, and all fluoropolymers, used as essential components for the proper functioning of the equipment.
While we understand the importance of addressing issues related to PFAS emissions, the Restriction proposal raises for us many concerns that deserve to be taken into consideration. The RACHP products provide essential heating and cooling services to society: refrigeration for food supplies, safe transport of medicines and vaccines, comfort to citizens in homes and offices, substitution of fossil fuels by heat pumps, etc. Our products show very low leakages rates and are treated trough their entire life cycle in an environmentally sound manner.
Please find in attachment a summary of our submission to ECHA, and our full submission for your information.
We would be happy to have an online or in-person meeting with you in the coming weeks to share our position and discuss the points that your ministry and that Sweden should consider when the Restriction proposal will be assessed by Member states.
Thank you for your kind consideration!
Kind regards,
Manon Roussel
Policy Manager EPEE - European Partnership for Energy and the Environment The Voice of the Refrigeration, Air Conditioning and Heat Pump Industry in Europe Avenue des Arts, 44, B1000 Brussels EU Transparency Register Nr. 2227673891567