Document 5bGkzyQQ5vOgM37RyLLxpZMYD

FHT ITALIA SRL roonHamlingrecrinoiogtes Travagliato, 7th September 2021 Kind attention: Mr. Martijn Beekman - Netherlands Dr. Mandy Lokaj - Germany Mrs. Jenny Ivarsson - Sweden Mr. Toke Winther - Denmark Mr. Audun Heggelund - Norway Mr. Mark Blainey - ECHA @rivm.nl @baua.bund.de Jenny.lvarsson@kemi.se @milodir.no echa.euro a.eu Through: fluorseals S.p.A - Via Tribolina, 20/22 - 24064 Grumello del Monte (BG) - Italy The members of fluorseals S.p.A mainly focus on processing of Fluoropolymers, part manufacturing and its applications, the involvement of downstream users in PFAS process. Subject: PFAS restriction proposal & request for exemption of FLUOROPOLYMERS Reference: PFAS - Registry of restriction intentions until outcome (Rol) dated 15th July 2021 Dear Sir/Madam, With regards to Registry of Intention (Rol) filed by 4 EU Member States (Germany, the Netherlands, Sweden, and Denmark) & Norway for the restriction of PFAS, we, a member of fluoropolymer downstream user industry, hereby, would like to share some salient facts related to the importance of fluoropolymers, critical functionalities, performance and benefits of its applications to society, while acknowledging concerns regarding PFAS emissions related to the use of fluoropolymers and their end of life. Registry of Intention for PFAS restriction was announced by ECHA on 15th July 2021, to prepare a restriction proposal for PFAS. Fluoropolymers are also included in the scope. The restriction proposal is intended to be submitted to ECHA by 15th July 2022. Fluoropolymers are a distinct subset of PFAS and are inherently safe, non-mobile, non-bio accumulative and non-toxic. Fluoropolymers are different from other PFAS as they do not share the toxicological and environmental profiles associated with PFAS of concern. Fluoropolymers have unique set of physicochemical properties, they meet OECD polymer of low concern criteria, and are considered to have insignificant environmental and human health impact. Fluoropolymers ensure safety, reliability, durability and critical performance in numerous technologies, industrial processes and everyday applications that are important for human health, safety, and the environment. With a unique combination of functionalities, fluoropolymers are irreplaceable across many key sectors/applications. Alternatives to fluoropolymers, if exist, escalate safety risks, carbon footprint, technology regression, and do not match the advanced performance of fluoropolymers. Most importantly, restriction on fluoropolymers will make EU industry lose its technological superiority over other economies and could put Europe's climate and energy goals at risk. Overall, fluoropolymers contribute heavily to Europe's socio-economic status and are critical for the betterment of the society. The fluoropolymer downstream user industry acknowledges the concerns regarding PFAS emissions due to the use of fluoropolymers and end of life processes. We wish to assure the authorities and EU Member States that, we are implementing Best Available Technologies to ensure reduction in PFAS emissions in a FHT Italia S.r.I. Registered Office: 10, Via Vittor Pisani - 20124 Milan - Italy - VAT No. 091911809BB Operational Headquarters: 52, - 2502" resole) Tel. - Fax - Email fhtitalia.com FHT ITALIA SAL FiuorocaroonHanattncirecnnotoptes systematic way and eventually eliminating them to achieve EU's sustainability goals. Parallelly, we are consciously working on recyclability and reusability to meet circular economy goal. Fluoropolymers play an important role in achieving EU Green Deal objectives and UN Sustainable Development Goals (UN SDG) because of their vital use in Lithium-ion batteries, Green hydrogen, Fuel Cell, Solar and Wind energy. No new-age technologies are possible without the use of fluoropolymers. Restriction on the use of fluoropolymers would adversely impact implementation of these technologies crucial for planet's future as well as in all existing applications vital for the society. Considering the benefits of fluoropolymer applications to environment and society, low PFAS emissions and initiatives being taken by the processing industry to further minimize emissions and closing the loop by implementing circular economy wherever possible, we request for a complete exemption of fluoropolymers from the PFAS restriction proposal. Fluoropolymers processed by us: High Pressure PTFE flexible hoses, PTFE tubing, FEP tubing, PFA tubing, Convoluted PTFE tubing, semifinished products like sheets, skived tapes, extruded rods and tubes, molded rods and tubes. Service application industries: hydraulic & pneumatic, industrial and medical gases, automotive, oil&gas, chemical, packaging, food & beverage, medical devices, textile machinery, paper machinery, ceramic industry Sincerely yours, ARCO Oi I 'LE is OIP k. Italia Srl Via Viffor Pisani 10, 20124 Milano (MI) FHT Italia S.r.l. Registered Office: 10, Via Vittor Pisani - 20124 Milan - Italy - VAT No. 09191180988 Operational Headquarters: 52, Via dell'Artigianato - 25039 Travaaliatn rPrescia) - Italy Tel. +39 030 B700142 - Fax - Email sales@fhtitalia.com