Document 5k3MpX6n3EnxgqR1x6BQ3Vp05

PFAS restriction What does this mean for the technological industry? Divided into 59 groups of companies BUILDING TECHNOLOGIES Office & warehouse equipment Windows, doors and facades Lifts Lighting Home Automation Individual Heating (CIV) Heating, ventilation & cooling Smart Building ENERGY TECHNOLOGY Multi-Energy MANUFACTURING & PROCESS TECHNOLOGY Gears and Transmissions Compressors Textile Machinery Machine Construction & Components Pumps & Valves Industrial Ovens Industrial Cooling Food Equipment Machines for the food industry, packaging and pharmaceutical industries Industrial Automatisation Metal-Alliance.be SAFETY, SECURITY & DEFENCE Defence technology Defence Equipment & Services Agoria Fire Technologies Agoria Security Technology & Solutions CO-CREATION, CONTACTING & MATERIALS Material Solutions Non ferrous metals Foundries Metal Oroducts Plastics Processing Composites Subcontracting Additive Manufacturing Contracting & maintenance Technical Project Management and Assistance Innovation, Design & Engineering Services Assembly and Cranes TRANSPORT & MOBILITY TECHNOLOGIES & SOLUTIONS Commercial Vehicles & automotive suppliers Smart Railway Solutions Shipping Technologies Smart & Sustainable Mobility Bicycles and accessories Agricultural & horticultural machinery and breeding equipment Civil engineering machinery AEROSPACE TECHNOLOGIES & SOLUTIONS Aerospace Agoria FLAG (Flemish Aerospace Group) Aeronautic platform technologies Space assemblies and technologies MANUFACTURING DIGITAL DIGITAL INDUSTRIES Data centers Digital Public Sector Analytics & Information Management Cloud & Datacenters Geo Business & Drones Mobile business Information Security Smart Cities Digital Value and Agility Digital Skills & HR Reprobel/Auvibel, POS-systems TELECOM INDUSTRIES Investissements et infrastructures Telecom et consommateur conomie et socit digitales 2 Agoria - the technological industry Broad range of industry groups (59) ranging from: Building technologies Energy technology Manufacturing & process technology Safety, security and defense technology Co-creating, contracting, materials Transport, mobility technology & solutions Aerospace technology & solutions Digital Telecom > 2.100 member companies active in the digital and manufacturing industry 324.000 people Work in the technology industry PFAS within the technological industry - used in multiple sectors/products: As a substance: cooling, lubrificant, foam, coatings, ... In an article: sealings, isolation, electronics, etc... Can be hidden in complex products within the global value chain: Typical value chain can range between 100 > 1000 suppliers worldwide Potential consequence of restriction? Broad restriction proposal > 10.000 substances with very limited proposed derogations ( 20 + potential 20 supplementary) for all types of uses of PFAS Timing of derogations limited to 6,5 or 13,5 years from EiF Some challenges for to technological industry: Identifying PFAS within complex value chain Finding substitutes for PFAS Redesign of multiple products including potential redesign of production facilities Applicable other legal frameworks - compliance can be challenging / conflicting Maintenance, repair, remanufacturing, recycling challenges, ... Limited time frame for derogations within complex products, value chains, ... Level playing field: cost, efficiency, competitiveness, ... ... Often very specific per product/application/sector 4 Feasibility of substitution ? Multiple uses are linked to the specific technical features offered by PFAS, such as: Water, dust, oil repelling, ... Heat resistance, heat exchange properties, ... High pressure, ... Lubrification capacity .... For certain use cases finding substitutes will involve more than "a drop in" substance: Product is designed taking into account the specific technical feature of the PFAS -> complete redesign will be needed For certain use cases substitutes will have a negative impact on different elements: Functioning of the product (energy efficiency, resource use, ...), process, complete review of product, complete replacement of product, ... And for multiple applications no clear view on technically feasible substitutes available to date Some examples... 5 Restriction proposal - what does it mean? Provided exemptions (~20) are very limited and nearly not applicable to our broad range of impacted products Technical feasibility to substitute within proposed time limit (2025/2026) is impossible for multiple applications R&D for finding substitute Re-design of product Potential impact on production process Compliance with other legal frameworks (ESPR, Safety, F-gas, ...) ... Important need for multiple exemptions for the technological industry: Current proposed generic timeframes for exemptions (6,5 or 13,5 years) will probably not be feasible given the challenges ahead 6 Even more challenges ahead... PFAS definition with very low concentrations (25, 250 ppb / 50 ppm): Can this be measured with existing technology for that broad range of substances? Restriction applies also to imported articles: How will Member States step up enforcement ? What with maintenance, repair, remanufacturing and recycling with no drop in alternatives existing? Most products in the technological industry have a life time well beyond 20 years - are we accepting a shorter life time period due to this restriction? This will have a huge impact for multiple products/installations/etc.. Derogation needed over the life-time of the equipment !!! Lack of coherence with other legislative frameworks and EU ambitions: Chips act, Net Zero industry act, F-Gas, ESPR,, FIT for 55, material efficiency, ... 7 Conclusions Most challenging restriction proposal: Wide range of substances and applications Very limited exemptions both in number and time frame Conflicting ambitions (Green Deal, net zero industry act, chips act, ....) This can lead to important market failure and difficulties to achieve EU ambitions (Green Deal, industrial plan, chips act, net zero industry act ...) Proper design of exemptions is needed taking into account reality within broad range of applications: Certainly generic exemption over lifetime for maintenance, repair, remanufacturing for products where no drop in alternative is existing but many other specific exemptions with feasible time frames Not a `one of a life-time stakeholder consultation': need of clear involvement of Belgian industry in design of restrictions needed to avoid market failure Need for more in-depth discussion in order to support exemptions for the technological industry in Belgium to avoid market failures 8 Thank you For your attention Embracing technology Embracing ambition .AGORIA 9