Document 6RGL0OnnqjLp41v24pveO2yqo

From: To: Cc: Subject: Date: Attachments: ECHA Restriction PFAS RE: RAC restrictions in 14 July 2022 10:41:00 image003.png image004.png image005.png image006.png image007.png image008.png image009.png image010.png image011.png image012.png image013.png in firefighting foams year 2021 : PFAS Dear Apologies for the long delay in replying to you. I just found your email. In response to your questions. 1. Harmonised classification for the PFAS class is not part of the proposed restriction. 2. The restriction option described as an export ban would strictly be a ban on the formulation of foams containing PFAS ingredients. This would be because of the releases associated with the formulation step. A ban on formulation would automatically result in a ban on export. The wording was used to ensure that stakeholders understood the implications of this restriction option. The wording used in the Background Document (the version of the proposal that RAC and SEAC ultimately make their opinions on) has been revised to remove the term export from the draft Annex XVII text based on feedback from some stakeholders that this is misleading and outside of the scope of REACH. 3. The proposed restriction on firefighting foams contains sector-specific transitional periods, which can be understood to be derogations. The phrase `no derogations' on corresponds to at the end of the transitional periods. The proposed restriction ensures the phase-out of PFASs in firefighting foams. The approach to derogations in the universal PFAS restriction is the responsibility of the 5 Member States preparing the proposal. 4. The decision to delay the submission of the universal PFAS proposal until January 2023 was taken to ensure that the quality of the proposal was sufficient. They have very large volume of information to process. Any further questions I would be pleased to answer and hopefully more quickly than these. Yours, Senior Scientific Officer / Restriction Process Coordinator Risk Management I / D3 European Chemicals Agency P.O. Box 400, FI-00121 Helsinki, Finland http://echa.europa.eu/ 8888 AiTsgheaendcdayrb.eosvsTeehdir.sepeIrmfeyasoieu,ntIhsnactvlheuerdeiocnpgeiniaivnoeyndoltfheitshaemteatsuatschhaoegrdeatinond1e,rirsIosniro,ntptaleneanosfdeifcnoioartliftpyhosetihuteisoeanoutfohtfohrtheaesIEnusdroioovpnieadasunatpColohsewsmihbiolceamlsIt nd delete the message. ToFoSernmt::E 17 March 2022 22:17 E Subject: RE: RAC restrictions in year 2021: PFAS Good eveniJI ng Unfortunately, | missed your presentation (as attached) last Monday March 14" scheduled for 17.30 as given much earlier (1 should have indicated RAC secretariat that | had particular interest in this subject so that | would have received warning the programme was advanced). Nevertheless very interesting ppt and please allow to ask me some questions for clarification : Slide 12 : Harmonized Hazard Classes could be applicable for PFOS.,does this mean also for PFAS in FFF but also for the universal PFAS? + Slide 19: RO3 see to be the preferred restriction approach, inc. export ban = tis is the first time we see expert ban ina restriction, i this correct understanding? In addition it s written "No derogations", would this also be applicable for the universal PAS restriction? And what about essential uses like in pharmaceutical products and PPPs, very much vertically regulated whereby stringent risk assessment are applied? In addition, | am wondering why the U-PFAS restrictions proposal initially foreseen Mid 2022; is now delayed till an. 2023 : any particular reason ? Your feedback on the above points would be very much appreciated. Best regards, -- REACH, CLP, PIC & POP a CropLife Europe, aisbl 9 Rue Guimard, 1040 Brussels, Belgium www.croplifeeurope.eu | Twitter | LinkedIn BE 0447 618 871 - Register of Legal Persons Francophone Section of he Business Court of Brussels EU Transparency Register ID No.0711626572-26 VAT: BE 0447 618 871 The content of this e-mail and its attachments are intended for the recipient(s) specified in he message only. If you are not an intended recipient, please notify the sender and follow with its deletion. CropLife Europe is committed to ensuring the security and protection of he personal informa ion that we process, and to providing a compliant and consistent approach to data protection. If you have any questions related to our GDPR compliance, please click here to consult our Privacy Policy or contact us at xxxxxxxxxxxx@xxxxxxxxxxxxxx.xx From: Sent: 07 June 2021 16:00 To: Cc: Subject: RE: RAC restrictions in year 2021 : PFAS Dear Could I suggest that, if you have not already done so, you subscribe to ECHA's `weekly' news bulletin. All PFAS-relevant announcements about risk management, including any entry to the ROI, will be made via this platform. I'm sure that you'll appreciate that we cannot undertake to keep you informed personally about developments. https://www.echa.europa.eu/news In terms of timing, I've not heard anything to suggest that the five countries planning has been changed. Yours, Senior Scientific Officer / Restriction Process Coordinator Risk Management I / D3 European Chemicals Agency P.O. Box 400, FI-00121 Helsinki, Finland http://echa.europa.eu/ The above represents the opinion of the author and is not an official position of the European Chemicals Agency. This email, including any files attached to it, is intended for the use of the individual to whom it is addressed. If you have received this message in error, please notify the author as soon as possible and delete the message. From: Sent: 07 June 2021 16:40 To: Cc: Subject: RE: RAC restrictions in year 2021 : PFAS CAUTION: This email originated from outside ECHA. Do not click links or open attachments unless you know the content is safe. Check the email address of the sender. It is possible that the name of the sender is known to you (e.g. a colleague), but the actual sender is someone else. Good afternoon Many thanks for your feedback and would very much appreciate if you can keep me in the loop of communication on PFAS topic and the intended broad restriction as Regular Stakeholder in RAC and SEAC. In this respect, it was foreseen Entry in RoI towards end 1st Half 2021 and can you please inform me if this is likely going to be delayed? Thanks for your further feedback. Best regards, Advisor - REACH, CLP, PIC & POP CropLife Europe, aisbl 9 Rue Guimard, 1040 Brussels, Belgium www.croplifeeurope.eu | Twitter | LinkedIn BE 0447 618 871 - Register of Legal Persons Francophone Section of the Business Court of Brussels EU Transparency Register ID No.0711626572-26 VAT: BE 0447 618 871 a The content of this e-mail and its attachments are intended for the recipient(s) specified in the `message only. If you are not an intended recipient, please notify the sender and follow with its domain wv octets ao ros 3 SONOS deletion. Croplife Europe is committed to ensuring the security cite spo and protection of the 3 08 personal protection. If you have any questions related to our GDPR compliance, please click here to consult our Privacy Policy or contactus atdata-privacy@croplifeeuroepue om:I = o Subject: RE: RAC restrictions in year 2021 : PFAS. vearjill Thfecountieswerkingon thebroad restrictionofPEAS hosted a lini the autumn of 20to2 upda0te stakeholders on the likely scope and timing. This is available on the ECHA website here: reach Theres isoanaccompanyingQ8Adocument on the samepage JI is isht that we have not yet received the notification to the ROI (registry of intentions), Rk wmagement 1103 `Senior Scientific Off/Riestcrie ctiron Process Coordinator European Chemicals Agency ema P.O.Box 400, FI-00121 Helsinki, Finland peter simpson@echaeuropa.eu htto://echa.europa.eu/ asas TChheemaibcaotvse Ann Ts ovat nating ms les represents the opinion of the author sacha and is not an mended for the sof he. official position of the European individual to whom it is addressed. Ifyou have received this message in error, please notify the author as soon as possible and delete the message. From: Sent: 04 June 2021 11:26 To: Cc: Subject: RAC restrictions in year 2021 : PFAS Dear Thank you for your question on the upcoming restriction proposals. The below slide refers to the current entry in the Registry of restriction Intentions (RoI) which aims at restricting the use of per- and polyfluoroalkyl substances (PFAS) in fire-fighting foams (planned to be submitted in October 2021 by ECHA). More details of the scope of the restriction proposal can be found at https://echa.europa.eu/registry-of-restriction-intentions//dislist/details/0b0236e1856e8ce6 The broader PFAS restriction is yet to be included in the RoI, information on the scope and the expected timelines. might have more On behalf of RAC Secretariat Kind regards, From: Sent: 04 June 2021 10:20 To: Cc: Subject: RE: RAC restrictions in year 2021 : PFAS Hi Glad to see that someone actually reads the workplan J. As I understand it, the PFAS restriction proposal will be much broader than fire-fighting foams. I'm sure can provide general information on the nature of this proposed restriction in as far as we know it. I put our Restrictions coordinator in copy, should you want more detail on how such restrictions work in practice. With best regards, From: Sent: 04 June 2021 09:15 To: Cc: Subject: RAC restrictions in year 2021 : PFAS CAUTION: This email originated from outside ECHA. Do not click links or open attachments unless you know the content is safe. Check the email address of the sender. It is possible that the name of the sender is known to you (e.g. a colleague), but the actual sender is someone else. Good morning From the work programme new restrictions proposals 2021 (see hereunder), I have noticed that submission of PFAS restriction is foreseen Oct. 2021. Can you / ECHA please clarify the definition and scope of this PFAS restriction? Is it related to PFAS used in firefighting foams? The reason of my request is that w understand that 5 MSs (DK, SE, NL , DE and NO) are preparing a new proposal for a broad restriction of PFAS with intended proposal submission summer 2021. Also any information or clarification of the definition and scope of such new PFAS restriction as under preparation by the 5 MSs would be appreciated. Many thanks in advance for your feedback. Best regards; Advisor - REACH, CLP, PIC & POP CropLife Europe, aisbl 9 Rue Guimard, 1040 Brussels, Belgium www.croplifeeurope.eu | Twitter | LinkedIn BE 0447 618 871 - Register of Legal Persons Francophone Section of the Business Court of Brussels EU Transparency Register ID No.0711626572-26 VAT: BE 0447 618 871 The content of this e-mail and its attachments are intended for the recipient(s) specified in the message only. If you are not an intended recipient, please notify the sender and follow with its deletion. CropLife Europe is committed to ensuring the security and protection of the personal information that we process, and to providing a compliant and consistent approach to data protection. If you have any questions related to our GDPR compliance, please click here to consult our Privacy Policy or contact us at xxxxxxxxxxxx@xxxxxxxxxxxxxx.xx