Document 2qOwzKL0QvorbR3VEJdjY1RQ5

TU NAP works. 21. September 2023 Proposed Restriction: Per- and Polyfluoroalkyl Substances-Annex XV Dear Sir or Madam, TUNAP GmbH Co. & KG respectfully submits the following comment to the European Chemicals Agency proposed restriction on per- and polyfluoroalkyl substances (PFAS) published on February 7, 2023. We appreciate cordially the provided opportunity. Introduction TUNAP GmbH & Co KG BOrgermeister-Seidl-Stralle 2 D-82515 Wolfratshausen P.O. Box 1640 D-82506 Wolfratshausen Phone +49 8171 1600 - 0 Telefax +49 8171 1600 - 40 Mtunap com Your Contact Daniel Eisenschmid E-Mail tunap.com Extension Phone Page 1 of 2 The TUNAP GROUP headquartered in Wolfratshausen, Germany is an european manufacturer of aerosols, lubricants, and cleaners for industrial and technical applications. With innovations and reliable products from its own development and production as well as a comprehensive international direct sales organization, TUNAP is a successful and indispensable partner of the industry. With its production facilities, a large network of distributors supported by highly qualified and motivated employees, TUNAP is in many markets worldwide present. TUNAP supports the preservation of our natural resources and apart from the environmental aspect, continue to develop in the areas of economic and social sustainability. Concernment As a chemical producer, our activities are pertinent to a wide variety of chemical substances, in particular hydrocarbon-based solvents, and fluids, which must be stored and processed in a closed system, to ensure the health of employees and not to pose a risk to the environment. The use of fluoropolymers like PTFE and PVDF in this context is crucial to seal the various parts of our systems and thus prevent leaks and associated emissions into the environment due to their very special properties like temperature tolerance, chemical and high wear resistance, durability, low coefficient of friction and high media compatibility etc., which have not yet been demonstrated by any other material reasonable for an industrial use and technical functions. General Privacy Notice: Information on the processing of your data is available at www..tuna.p.com/en/tunap/rechtliches/datenschutz.php TUNAP GmbH & Co. KG Court of Registration: Munich HRA 52 062, Registered Office: Wolfratshausen Vat No: DE131 706 706 Tax No. 169/178/50902 Banking Account: DZ-Bank Munchen (BLZ 70160000) No_ 149 286 IBAN: DE44 7016 0000 0000 1492 86 BIC: GENODEFF701 General Partner TUNAP Deutschland Vertriebs GmbH Court of Registration: Munich HRB 43 469, Registered Office: Wolfratshausen Management Board: Maximilian Buchner, Oliver Graetsch EORI Nummer: DE33 95 55 3 TUNAP.com TU NAP works. After a rough estimate, TUNAP expects to have up to thousands number of mentioned fluoropolymers in different form of sealings in the affected production facilities as well as in the sector of transport, including but not limited to: Air compressors Nitrogen generators Refrigeration dryers Filling machines Sealing machines packaging machines Condensers Storage tanks and tanker coupling adaptors Pumps Machine and pipe fittings Regulators and valves Thread seals and other kind of sealings Pipe networks Homogenizer, mixers, roller mill machines and industrial kneaders TUNAP GmbH & Co. KG BOrgermeister-Seidl-Stralle 2 D-82515 Wolfratshausen P.O. Box 1640 D-82506 Wolfratshausen Phone +49 8171 1600 - 0 Telefax +49 8171 1600 - 40 Mtunap.com Your Contact Daniel Eisenschmid E-Mail tunap.com Extension Phone Page 2 of 2 Comment The use of fluoropolymers can afford the environmental protection as well as a safe transport and sustainable handling of the critical materials which may result in a potential damage. Implementing the proposed restrictions applied to the fluoropolymers will cause far-reaching technical issues and expecting socio-economic consequences for our branch of industry. TUNAP acknowledge ECHA for regulating chemicals and protecting the environment and human health and also value the proposed restriction. However, as set out for the mentioned reasons, TUNAP asks ECHA to consider the described issues for adopting the further approaches. Many Thanks in advance. With kind regards, TUNAP GmbH & Co. KG Daniel Eisenschmid i. V. Daniel Eisenschmid 21.09.2023 10:43:25 [UT Head of Integrated Management Systems General Privacy Notice: Information on the processing of your data is available at www..tuna.p.com/en/tunap/rechtliches/datenschutz.php TUNAP GmbH & Co, KG Court of Registration: Munich HRA 52 062, Registered Office: Wolfratshausen Vat No: DE131 706 706 Tax Na 169/178/50902 Banking Account DZ-Bank Munchen (BLZ 70160000) No_ 149 286 IBAN: DE44 7016 0000 0000 1492 86 BIC: GENODEFF701 General Partner TUNAP Deutschland Vertriebs GmbH Court of Registration: Munich HRB 43 469, Registered Office: Wolfratshausen Management Board: Maximilian Buchner, Oliver Graetsch EORI Nummer: DE33 95 55 3 TUNAP.com