Document 5Dqn51LK444mvQpxQ7EVdwyQ8

Questions on the uPFAS proposal 6 September 2023 | Second Open Ad-Hoc Belgium REACH Committee (BCR) on uPFAS restriction It took about 24 months for the European Commission to receive #1 ECHA's opinion on the multi substance/multiuse microplastics restriction proposal. Is it likely that the similar uPFAS will take the same amount of time? #2 Is there still a strong commitment from the European Commission to phase out all PFAS substances and uses, or could the scope be reshaped (like for PFHxA)? The impact of the uPFAS restriction on industry is a lot bigger than #3 anticipated. Is there an appetite from Member States and RAC/SEAC to rethink the scope of the uPFAS restriction? There is an increasing number of exclusion requests in the submissions. #4 Does SEAC have a legal mandate to propose an exclusion from the restriction for a specific sector? If not, what is the consequence of requesting such an exclusion? Given the alarming number of PFAS uses, how to ensure regulatory #5 compliance for companies still identifying PFAS in their supply chains when the consultation period has ended or decision taken and new uses emerge that will be difficult to substitute by EIF? #6 What are the consequences of unintentionally added PFAS in products coming from recycled materials? There is a growing awareness of PFAS used in manufacturing and #7 other industrial uses. Is there a possibility to change the scope of the restriction to exclude or derogate manufacturing for a longer period of time? There are highly regulated sectors which lead to longer substitution processes and require market #8 authorisation for new products. This was not considered in setting the maximum derogation length in the restriction proposal. Could that lead to longer derogations? Enforcement of REACH restrictions are challenging already now and #9 some studies show close to 20% noncompliance. Is there a good plan how to deal with difficult to measure PFAS in products during enforcement ? Brussels office T +32 (0)2 613 2828 Rue de la Loi 227 I 1040 Brussels I Belgium London office T 1700 201Borough High Street I SEii.JA London I United Kingdom fipra. corn 1 1,1141111,M1 1rm4vr4-w*ri -