Document 2J1e5XY3VEk3JmyVZd69a821b
September 25th, 2023 ECHA Committee do European Chemicals Agency P.O. Box 400 00121 Helsinki Finland restriction@echa.europa
Subject: 2023 ECHA Annex XV Restriction Report Proposal These comments are submitted on behalf of Polaris Inc. and its subsidiaries (Polaris).
Introduction Polaris designs, engineers, and manufactures all-terrain vehicles ("ATVs" or "quads"), recreational and utility side by side vehicles ("SbS"), in addition to other powersports vehicles. In the EU, these vehicles are regulated in a few categories as machinery, T-category, and L-category. With a portfolio of more than 30 brands, Polaris shares the ECHA's goal of enabling consumers to use these vehicles safely. Polaris is a member of the European Association of Motorcycle Manufacturers (ACEM), which represents the largest manufacturers of mopeds, motorcycles, tricycles and quadricycles with operations in Europe. These comments are intended to supplement comments previously submitted by ACEM. Definition of Transport Vehicles ANNEX XV Restriction Report, E.2.10, states that "The transportation sector covers all modes of transport, by road, rail, air and sea." Polaris respectfully submits that the final report includes the term "offroad" to include non-road mobile machinery that operates off-road, such as all-terrain vehicles and side by side vehicles, in their definition of transportation sector." Conclusion Polaris appreciates the opportunity to respond to the per- and polyfluoroalkyl substances (PFAS) ECHA public consultation to reduce the hazards associated with certain chemicals. If you have any questions or comments regarding any of the above, please contact me directly.
Best Regards,
POLARIS
Think Outside
Polaris Inc. I 2100 Highway 55 I Medina, MN 55340 I 1
Pola ris.com