Document 3Nq94vMe7VY28mpMMvJ45DpEn
etwescozzesaens- nazz Ref. Ares(2023)7829799 - 17/11/2023
SFernotm:: To: Scubeject:
Dear ie JI
22 December 2022 16:23 ew) RE: 3MtoExitPFAS ManufabcyttheuEnrdoif2n02g5
mIeasmtirnegawchiitnhgoouutrtDoiryeoctuorregfoarrdCiinrcgutlhaer ErceoqnueosmtybMerloAwurienclaCsieo[ banu-I DordI ea.I would be interested in You have indicated the week between January30and February 3, therefore | would ike to already indicate that Mr Ciobanu-Dordea could be available on Thursday 2 February, either morning or
aDfotne'rtnhoeosni,taftoer atnolien-mpeerskonnomwesehtoiungl.dJR] be interested and available, and we can procead vith
the practicalities in January.
`Thank you very mich in advance. Kind regards,
EDiurreoctpoeraanteC-oGemnmeiraslsfioornEnvironment Directorate 5 - Circular Economy.
CIT sgn
Website:
sanionert
Follow us on: [EI@ &
From: ENV DIRECTOR GENERAL <ENV-GDENIERRAL@EacC.ouTropOa.eRu>
ToSe:nt: Thursday,December 22, 20m2m2m1.2:c4o8mP>M
Ce:CIOBANU-DORADurEeAl (ENV)
ec.europa eu]
(Env)ss
ec.ouropa.eu>>;
SubREj: 3MetocExittPF:AS ManufabcyttheuEnrdoif2n02g5
oear wr.
We are able to come back with an answer. Unfortunately, due to a very charged agenda and prior commitments for the mentioned dates for Ms Fink-Hooijer, we are unable to propose a slot, to our regret.
However, Director Aurel Ciobanu-Dordea is available to step-in and represent Ms Fink-Hooijer and DG ENV for this meeting.
If agreed, details.
, will contact you directly and arrange the
We take this opportunity to thank you for the collaboration and send our best wishes for 2023.
Kind regards,
European Commission/Directorate-General for the Environment Avenue d'Auderghem 19, B-1000, Bruxelles/Brussel
env-director-general@ec.europa.eu Website: http://ec.europa.eu/environment
Disclaimer This message represents solely the views of its author and cannot in any circumstances be regarded as the official position of the European Commission. It is intended solely for the person to whom it is addressed and may contain confidential information.
From: ENV DIRECTOR GENERAL <ENV-DIRECTOR-GENERAL@ec.europa.eu>
Sent: Wednesday, December 21, 2022 11:21 AM
To:
@mmm.com>
Cc: CIOBANU-DORDEA Aurel (ENV) <
@ec.europa.eu>;
@mmm.com>;
@mmm.com>; ENV DIRECTOR
GENERAL <ENV-DIRECTOR-GENERAL@ec.europa.eu>
Subject: RE: 3M to Exit PFAS Manufacturing by the End of 2025
Dear
,
On behalf of DG Fink-Hooijer, we hereby acknowledge receipt of your enquiry and we thank you for sharing the news related to 3M exiting PFAS manufacturing by 2025. We shared the information with relevent collegues.
Related to the possible meeting we will come back to you with a reply as soon as possible.
Best regards,
European Commission/Directorate-General for the Environment Avenue d'Auderghem 19, B-1000, Bruxelles/Brussel
env-director-general@ec.europa.eu Website: http://ec.europa.eu/environment
Disclaimer This message represents solely the views of its author and cannot in any circumstances be regarded as the official position of the European Commission. It is intended solely for the person to whom it is addressed and may contain confidential information.
From:
@mmm.com>
Sent: Tuesday, December 20, 2022 4:59 PM
To: FINK-HOOIJER Florika (ENV) <
@ec.europa.eu>
Cc: CIOBANU-DORDEA Aurel (ENV) <
@ec.europa.eu>;
ENV DIRECTOR GENERAL <ENV-DIRECTOR-GENERAL@ec.europa.eu>;
@mmm.com>;
@mmm.com>
Subject: 3M to Exit PFAS Manufacturing by the End of 2025
Dear Florika,
I wanted to thank you again for the good working lunch at AECA end October -
we appreciated your openness during the fruitful exchange of views.
I also wanted to inform you today re. a piece of news from 3M with the
attached press release.
We would be pleased to further exchange with you on that matter.
FYI we will have again
coming to Europe during the week of
January 30 until February 3.
This could be a good time to further exchange ideas and debrief you on this
major 3M decision and the impact for the industry.
Meanwhile I wish you and your team the best for the holiday season.
I copy Aurel with whom we also had a fruitful exchange early October!
Best regards,
Hermeslaan 7 | 1831 Diegem (Brussels) Belgium
office:
1 Mobile:I
ier:
ww,3M.com
EU Transparency Register ID Number: 91425447458-88
FSreontm::N Saturday, 22 OctoberN 2022 16:2v3vcon>
To
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|
pr ngs ir @ec eurewo;CpHILaD Patrick01093 eu>; CIOBANU-DORADu; rEeAl
document&s courseofaction DEeaar rMisn.lOFcitionebkeHrro,oi|hjaed--rtheopportunitytofollowuponourdiscussionand engage withMr.Ciobanua-nDd| ord. ea| greatlyvaluedthe exchange andthe insightsand perspectiveofMr. Ciobanu-Dordea an[1d1] 1`G7reen Dheaalv.ebIe'veeantvtearcyhheedltphfeufloalslwoew-cuopntmiatneureitaolswforrokmtihnsautpdpisocrutsosifonthfeorEUy.our reference. Idbehappy tofollow-upandprovideyouoryourteamwithfurther details ontheproposalsandcontinuethediscussion. Thank youfortheopenand ongoing engagement. Best rogard--s
amScience.
Applied to Life."
3OMffCee:nt+e1r|Bldg 220-7|WSt-.P0au2l, MN55144-1000 Mobile: + I FSreonmt::FI riday, October 21, 20N 22 3:37AM o>
To: CIOBANU-DORDEA Aurel <
Cc:
@ec.europa.eu;
@mmm.com>; @mmm.com> Subject: Meeting with 3M documents & course of action
@ec.europa.eu>
@ec.europa.eu>; @mmm.com>;
(October 6): follow up
Dear Aurel,
It was good meeting you and Peter on October 6. Thank you again for the open discussion about the EU Green Deal, CSS and the need for specialty materials to achieve EU strategic objectives (decarbonized, digital, resilient and autonomous Europe).
I would like to stress again 3M's support for a strong Single Market and the EU Green Deal objectives, including the zero-pollution ambition. Recalling our discussion on the need for companies to have certainty and balanced future legislation to plan investment, I would like to reiterate the following points:
x Durable products will require persistent materials. Many products need the functionality provided by persistent chemicals to be durable and perform over time under demanding, sometimes extreme conditions. Despite the negative perception currently assigned to the persistence of certain chemicals like PFAS, persistence can be beneficial as it enables critical performance, durability and functionality of the application. Persistence can also support the circular economy's approach as performance means less materials, and durability means less waste generated.
x Regulating PFAS requires pragmatism ("smart grouping"). The EC should not embark into banning all PFAS without a full understanding of its broad impact. There is a need for closing the data gap as to which PFAS poses an unacceptable risk to the environment or health, and for ensuring that the EU industry has the time to develop suitable alternatives, if at all possible. We would like to ask the EU regulator to consider an alternative to the grouping approach for regulating PFAS. For example, a decision tree based on risk assessment, starting with the analysis of (eco)toxicological profile of relevant PFAS and their use, would be useful.
x Need to distinguish between legacy PFAS and modern fluorochemistries. While legacy PFAS such as PFOA and PFOS have been found to bioaccumulate, this is not true for all PFAS, especially the shorter chain PFAS and other PFAS structures (e.g. fluoropolymers). Human biomonitoring results continue demonstrating this as well.
x PFAS emissions in the environment can be controlled and will be further limited. 3M committed to reduce PFAS discharges from its manufacturing processes by more than 99% by 2024. In addition, we are
working with downstream users and industry partners to control emissions throughout the life cycle of products (closed systems, recovery, recycling). x Health science on PFAS is not settled. As mentioned, while "legacy PFAS" like PFOA and PFOS can bioaccumulate, it is key to recognize that these legacy PFAS-substances are no longer manufactured or used in Europe for more than 15 years and that their levels have been steadily dropping since the past 20 years. It is equally important to acknowledge that scientific evidence demonstrates no cause-and-effect relationship for any of the studied effects at levels people are exposed to. As a matter of fact, there is a large safety margin between the no-observedadverse-effect level (NOAEL) assessed in laboratory animals and the measured levels in humans or the environment.
Per your suggestion, I attach for your consideration 2 thought starters with a few ideas on how PFASs could be regulated differently re. alternative grouping & derogation process. We would be happy to follow-up with you and your team on a more detailed proposal based on the existing legal framework.
We look forward to continuing our discussion - please let us know when you would like to have another meeting, and thank you for any feedback. I also attach for your information the 3M presentation from our meeting.
Sincerely yours,
Hermeslaan 7 | 1831 Diegem (Brussels) Belgium
Office:
| Mobile:
@mmm.com | www.3M.com
Twitter: @
EU Transparency Register ID Number: 91425447458-88
From: CIOBANU-DORDEA Aurel
Sent: Wednesday, 28 September 2022 13:46
To:
@mmm.com>
Cc:
@mmm.com>;
@ec.europa.eu>
Subject: [EXTERNAL] RE: Meeting with 3M
or Friday 7 morning
Dear
,
@ec.europa.eu> : Thursday 6
Sorry for thedelay in replying. Thursday 6 in the morning would be fine. in copy,will get in contactwith youforthe
preparations Thanks and looking forward to the discussion, Aurel
From:NN cncom>
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Dear Mr. Ciobanu-Dordea /DearAurel,
1wouldliketofollow-uponthisemail |senttoyou earlylastweekW.e `werewonderingwhetheryouwouldhaveanyavailabilityto meetwith `our [iillin town next week? Would perhaps Thursday morning (8:30-
9t:i3me0s)loortFsrfirdeaeywinoyrokufrocrayleonud?aPrl.easeletme knowwhatwouldbethe
`We would liketotalk about the strategic executionofthe green deal:
importance of specialtychemicals / matfore strr ategi icvaa luel chas ins in Europe and innovation an/gselarechforalternativTehse. objective
`cooftohrdiisnmaeteitoinn.gistoexchangewithyoure.strategy &policy
Thankyouforyourattention andapologiesforshortnoticebut think can be avaryvaluable exchange.
3M 5 Kind regards,
|__|
Applied toLife."
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`Subject: Meeting with3M
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afternooroWne,d5afternoonorThursday 6or Friday 7 morning.
Dear Mr. Ciobanu-Dordea /DearAurel,
twasvaryice &-maating you25achrofAmChamEUEnvironment Sa dcimon. `Coem arlmySi eptt embt er--e thae nk you again for your time and a very
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Thankyo tootmeknowwhethryouwouldbeavaiableandwhat
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Bestregards,INI
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pTdo: FINKHOOLERFlora lennm.con- pec eucpacu>
2eac europa.eu>; Dac CHILDPatrick 01503 015; IO|B@AecN.GeDurOoRpOa.EeAu>;
Aurel
@ec.europa.eu>
Subject: RE: Thank you - follow up from discussion
Dear Florika -
Thank you for following up. I believe
has provided you with the
materials. My apologies for not including it in my earlier note.
Please let me know if there is any comments or questions on the
material. I'm happy to follow-up with you and your staff at your
convenience
I look forward to continuing the discussion
Thanks
From: FINK-HOOIJER Florika
@ec.europa.eu>
Sent: Wednesday, July 27, 2022 9:23 AM
To:
@mmm.com>
Cc:
mmm.com>;
@mmm.com>;
@ec.europa.eu>; CHILD Patrick
@ec.europa.eu>;
@ec.europa.eu>; CIOBANU-DORDEA
Aurel
@ec.europa.eu>
Subject: [EXTERNAL] RE: Thank you - follow up from discussion
Dear Mr B
, dear
It was a pleasure meeting you and your colleagues and I am appreciative for the informative exchange of views we had.
As explained, discussions are ongoing on the concept of essential use and on the next steps regarding the targeted revision of REACH. I took well note of the additional arguments provided in your mail, which I am sharing with my colleagues in charge of this specific file. I might have overlooked it but I did not saw the final version of the 3M presentation from our meeting you were referring to as an attachment to your mail. Your team may wish to resend it to all colleagues in copy. Thank you.
We shall stay in contact, Best Florika
FDilroercitkoar FGIenNeKraHlOODER
.DirectorateCGoemnmeirsasoironEnvironment Avenue daudershe 13, 81000 Belgium
joec.europa.eu
From:
@mmm.com>
TSoe:ntF:IWNeKdHneOsOdUaEyR, Fulloyrk2a0,(2EN0V2)2 6:47 PM
ce |@mmmcom> @mmm com>;
`Subject: Thyaou nfolklow up rom discussion
|@ecouronacu>
Dear Ms. Fink-Hooije-r
Thank you again for our discussion early July about the EU Green Deal, EU Industrial Policy and the need for specialty chemicals to achieve EU strategic objectives (green, digital, resilient / strategic autonomy). | twhoeuldElUike tGoresetrnessDaegaalin 3obMj'esctsiuvpesp,ortifnocrluadisntgrongthseinglzeermoa-rpkoleltutainodn ambition. Recalling our discussion on the need for companies to have certainty and balanced future legislation to plan investment, |would ike to reiterate the following points:
Regulating
PFASrequirespragmatism("smartgrouping): The
EC should not embark into banning all PFAS without a full
understanding of its broad impact. There is a need for closing
the data gap as to which PFASposesan unacceptable risktothe
environment or health, and for ensuring that the EU industry
has the time to develop suitable alternatives. We would like to
ask the EC to consider an altemative (grouping) approach for
regulating PFAS. For example, a decision tree based on risk
assessment, starting with the analysis of (scoltoxicological
Durable profile opfrroedluecvatnstwiPlFlASreaqnudirtehpeeirrsiusset,enwtomualtdebreiaulssef(uclo.ntribution
to circular economy): Many products need the functionality
provided by individual PFAS to be durable and perform over time under demanding, sometimes extreme, conditions. Despite the negative perception currently assigned to the persistence of PFAS, it can be beneficial as it enables critical performance, durability and functionality of the application. Persistence can also support the circular economy's approach (performance = less materials needed, durability = less waste generated). x Substitution will take time and will be challenging for some applications. Some applications (especially industrial ones) will have more difficulties with replacing PFAS than others without compromising on the safety and performance. Inertness and durability are key requirements for certain applications, and such functionality cannot be easily substituted with non-PFAS alternatives. In cases where durability is required, an alternative would very likely also be persistent. x Health science on PFAS is not settled. While "legacy PFAS" like PFOA and PFOS can bioaccumulate in humans, it is key to recognize that these legacy PFAS-substances are no longer manufactured or used in Europe and their levels have been steadily dropping since the past 20 years. It is equally important to acknowledge that scientific evidence demonstrates no causeand-effect relationship for any of the studied effects at levels people are exposed to. As a matter of fact, there is a large safety margin between the no-observed-adverse-effect level (NOAEL) assessed in laboratory animals and the measured levels in humans or nature. x Need to distinguish between legacy PFAS and modern Fluorochemistries. While legacy PFAS such as PFOA and PFOS have been found to bioaccumulate in humans, this is not true for the shorter chain PFAS and other PFAS structures (e.g. fluoropolymers). Human biomonitoring results continue demonstrating this as well. x PFAS emissions in the environment can be controlled and will be further limited. 3M committed to reduce PFAS discharges by more than 99% by 2024. In addition, we are working with downstream users and industry partners to control emissions throughout the life cycle of products (closed systems, recovery, recycling).
I look forward to continuing our discussion and thank you for any feedback. I attach for your information the final version of the 3M presentation from our meeting.
Sincerely,
3M es Applied to Life."
Ba3MCenter 220|- St.7 PauT l,MW N55- 1440-10200
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