Document 6RrVq8gv1JGJq4NpqLjDzL6OE

AEM Association of Equipment Manufacturers Association of Equipment Manufacturers (AEM) The impact of a Potential PFAS Restriction on nonroad equipment for AEM Members Examples of non-road equipment include construction equipment, cranes, road building machinery and mining equipment. Report No. 2023-0518 Rev. 0 Project No. REG50169-001 Rev. Description Prepared by Controlled by Approved by Date 0 Issue 1 Emily Tyrwhitt Jones Maitheya Riva Paul Goodman September 2023 RINA Tech UK Limited I 1 Springfield Drive, Leatherhead, Surrey, KT22 7AJ, United Kingdom I P. @rina.org I www.rina.org Company No. 07419599 Registered in England and Wales All rights, including translation, reserved. No part of this document may be disclosed to any third party without written consent of RINA Tech UK Limited The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Note on report approval The persons identified above have signed off each stage of this report in accordance with RINA's BMS/QA procedure. Disclaimer Whilst great care has been taken in the compilation of this report, use of the information contained herein is entirely at the risk of the client or recipient. It does not constitute legal advice and should not be relied upon as such. To the extent permitted by law, RINA Tech UK Limited ("RINA") accepts no responsibility or liability for loss or damage arising out of acting upon or refraining from action as a result of any material in this publication. FEEDBACK QUESTIONNAIRE As a valued client your feedback on this project is important to us. We would be grateful if you could spare a few minutes to complete the questionnaire found via the QR code or hyperlink below: Link: RINA Questionnaire Thank you. Issue and Revision Record Rev. 0 Description Issue 1 Prepared by Emily Tyrwhitt Jones Controlled by Maitheya Riva Approved by Paul Goodman Date September 2023 Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 2 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members EXECUTIVE SUMMARY RINA Tech UK Limited (RINA) was requested by the Association of Equipment Manufacturers (AEM) to gather information from members to support the stakeholder engagement currently being undertaken for per- and polyfluoroalkyl substances (PFAS) under the REACH restriction proposal. Based on this information, this report provides an assimilation of the technical and socio-economic requirements which apply to AEM members' products regarding uses of PFAS substances. AEM is an international trade group representing non-road equipment manufacturers and their connected supply chain. AEM represents more than 1,500 member companies whom provide critical products for the European market. AEM members develop and produce a wide range of products, technologies, components, and systems that ensure non-road equipment operates safely, while operating in some of the most demanding and severe environments on earth, with product lifetimes spanning decades (up to 40 years and sometimes longer than this). Non-road equipment supports various industry sectors, including construction, agriculture, mining, forestry, and utility sectors, with a large swath of diverse machine forms and product types supporting a variety of end-uses and applications. These diverse sectors include farming, road building, construction of industrial, commercial, and residential projects, movement of aggregate material, etc. Although AEM is North American based, their members manufacturer and distribute products globally which include the European Union. AEM members provide a wide range of equipment, each of which provides unique functionality to the end user. These end-use applications provide the customer great value but can result in niche products with very low production volumes. Due to these challenges, replacing PFAS in each piece of equipment, presents a uniquely challenging endeavour from both a design and a qualification perspective. AEM members are typically manufactures that incorporate critical components containing PFAS into their products and must rely on their supply chain, which can be over 22 layers deep, to identify, develop, validate, and provide PFAS-free alternatives. With over 100,000 parts in many pieces of non-road equipment, this process of phasing out PFAS is an incredibly complex task. This effort is further complicated due to the fact that in many cases PFAS are the only known materials with the technical characteristics for the equipment to withstand the following technical requirements and guarantee reliability over their lifetime: Pressure up to 500 bar. Temperatures as high as 800C and cyclical temperatures of -57 to +230C. A high degree of mechanical wear and shear forces. Electrical and flammability resistance. Vibration up to 45.0mm/s causing alternating stress between joint components. Chemical resistance to substances such as fuel, hydraulic fluid, coolant with additives like 2-ethyl hexanoic acid, and carboxylic acids, exhaust gas fumes (highly acidic) and engine oil (highly alkaline). Long-term durability (up to 40 years) against factors such as ultra-violet (UV) light, mechanical damage, dusty, humid, wet, muddy, damp environments, and exposure salt spray. Lightweight to ensure the energy consumption required to operate certain systems are minimised. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 3 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Operation in hazardous or explosive environments requiring ATEX rating. These performance, durability, and safety requirements present a complex set of challenges when searching for and introducing PFAS-free alternatives. It is essential that replacement materials meet these requirements and still offer the same durability, quality, and safety attributes of PFAS. Non-road equipment is tested to rigorous safety standards as the equipment operates in inherently dangerous environments. Equipment operating in standard non-road environments require extensive testing to specific qualifications in order to comply with current regulations while ensuring the safe operation of the machine. Under these conditions, typical product development cycles for non-road equipment can range anywhere from 8-25 years depending on the technology and end use application. It is critical that derogations for the maximum validity period are permitted as AEM members have identified that more than 20 years will be needed from when a PFAS-free alternative is made available for the transition. AEM suggests changes to the proposed wording for derogation 6o, to ensure the critical systems they supply are able to support the critical infrastructures as highlighted by this report. Applications affecting the proper functioning related to the safety, reliability and durability of transport vehicles, non-road equipment, Internal Combustion Engine systems and Alternative Powertrain systems, and affecting the safety of humans or reliability of equipment until 20 years after entry into force (EIF). Given the envisaged timeline to qualify alternative refrigerants, it is also highlighted that derogation 5p refrigerants in mobile air conditioning-systems in combustion engine vehicles with mechanical compressors needs to be permitted until 20 years after EiF. Non-road equipment has long lifespans and therefore without a derogation which permits the manufacture and use of spares, repairs, and remanufacturing, will result in the early disposal of many products. It is also important that there is a proportionate process to allow derogations to be extended if needed. AEM members also support the need for derogations for lubricants, textiles, and batteries (with at least 3 years after PFAS-free batteries are developed and become available commercially to allow for system level qualifications). Due to the importance of PFAS in non-road equipment, and the unavailability of alternatives, without a derogation it is expected that up to 74 billion of annual revenue would be lost from the EU. As a result of the proposed restriction, the majority of product ranges currently offered could no longer be supplied in the EU. Given that non-road equipment supports key industries such as power generation, which is used for emergency and standby power generation for applications such as hospitals, waste and recycling, agriculture, and construction, as well as supporting the broad societal aims of EU policymakers, such as the EU green deal. A number of key industries would be impacted by the loss of machinery produced by AEM members. Furthermore, the majority of AEM members have indicated that they would need to hire additional staff to be able to investigate potential alternatives due to the significant number of parts which are affected, with members indicating this could be up to 28 full time employees (FTEs) per company. However, AEM members deem it unlikely that they would be able to find appropriately experienced and qualified staff, as global staffing shortages are already challenging for industry. It is therefore expected that research and development activities would halt, impacting new innovations and technology introductions of AEM's member company products. One such innovation which will be impacted is research into new alternative Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 4 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members power technologies, such as lithium-ion batteries, hydrogen fuel cells, and alternative fuels which provide low carbon solutions which will almost certainly be impacted by any restriction. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 5 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members TABLE OF CONTENTS EXECUTIVE SUMMARY 1 INTRODUCTION 1.1 Profile of the AEM Membership 1.2 Importance to Society 2 PFAS SUBSTANCE IDENTIFICATION 2.1 Challenges in Substance Identification 2.2 PFAS use within Non-road Equipment 3 TECHNICAL REQUIREMENTS AND ANALYSIS OF ALTERNATIVES 3.1 Seals and Hoses 3.2 Electronics 3.3 Mechanical Systems 3.4 Hydraulic Fluids 3.5 Paints and Coatings 3.6 Sealing Technologies 3.7 Lubricants 3.8 Refrigerants 3.9 Fabrics 3.9.1 Fabrics in Operator Interacting Parts 3.9.2 Fabrics for Sound and Vibration Attenuation 3.10 Alternative Power Systems 3.11 Production Facilities 4 QUALIFICATION REQUIREMENTS 4.1 Standards Development 4.2 Component Validation Testing 4.3 Product Validation Testing 4.4 Emissions 5 ENVIRONMENTAL IMPACT, END OF LIFE AND WASTE CONSIDERATIONS 5.1 Environmental Considerations 5.1.1 Decarbonisation Strategies and Technologies 5.1.2 Engine Emissions 5.2 End-of-Life Considerations 5.2.1 Impact of PFAS-free Components on Waste 6 PROPOSED DEROGATION UTILISED BY AEM MEMBERS 6.1 Non-road Equipment 6.2 Refrigerants in Mobile Air Conditioning-systems 6.3 Batteries Page 3 11 11 13 16 18 19 20 23 26 28 29 30 30 31 32 35 35 36 36 37 37 39 40 40 42 42 43 43 44 46 46 47 48 49 49 Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 6 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 6.4 Spares, Repairs and Remanufacturing 49 6.5 Derogation Extension Process 49 7 SOCIO-ECONOMIC IMPACTS 50 7.1 Economic Impact on the Industry 50 7.2 Cost of Qualification 50 7.3 Employment Effects 51 7.4 Impact on End-Users 52 APPENDIX A - STANDARDS POTENTIALLY AFFECTED BY PFAS 53 Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 7 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members LIST OF TABLES Table 2-1 PFAS substances currently identified by AEM members and uses, ordered by most common uses. 16 Table 2-2 Estimated Timeline for the Non-Road Equipment Industry to identify PFAS within its supply chain. 19 Table 3-1 Standards which lubricants are qualified to (non-exhaustive list). 31 Table 3-2 Technical review of PFAS-free lubricants. 32 Table 4-1 Minimum steps and time to be considered to test and recertify a PFAS-free material in non- road equipment after viable alternatives are identified. 38 Table 7-1 Estimated costs of qualification of PFAS-free alternatives, assuming that viable alternatives are available. 50 Table 7-2 Standards identified in various end sectors which may be potentially impacted by PFAS component changes. 53 LIST OF FIGURES Figure 1-1 Example products of AEM members. 12 Figure 1-2 Value of capital assets accumulated by producers (). 13 Figure 1-3 Shares of construction equipment sales in Europe from CECE. 14 Figure 1-4 Agriculture and construction value in EURO. 15 Figure 3-1 Relationship of weight and CO2 emissions. 21 Figure 3-2 Compressive Stress Relaxation Sealing Force via SAE J2979 in Organic-Acid Technology (50-50 Premixed Ethylene Glycol- Distilled Water) Coolant Aged at 175C. 24 Figure 3-3 Aging of FKM vs. HNBR O-rings in B0, B20 and B100 Fuels at 125C via ASTM D471 for Compression Set via ASTM D395. 25 Figure 3-4 Long term sealing performance. 26 Figure 3-5 Comparison of the effect of flame occurring. 34 Figure 3-6 Simplified example Fault Tree, where all events need to occur for event to occur. 35 Figure 4-1 Number of standards in different product end sectors potentially affected by PFAS. 41 Figure 4-2 Crane boom testing. 42 Figure 5-1 Production share of alternative power source vehicles.14 44 Figure 5-2 Emissions evolution over time.10 45 Figure 5-3 Estimated engine redevelopment timeline following updated emissions requirements. 45 Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 8 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members AC AHRI ASHARE CARB CARB CLP EiF EPA EPA EPDM FEP FFKM FKM FTE GDP GHS GWP HFC HFO HNBR IC ICE IMDS LED MSHA NBR NRMM ODP OEMs PEEK ABBREVIATIONS AND ACRONYMS Air conditioning Air-Conditioning, Heating and Refrigeration Institute American Society of Heating, Refrigerating and Air-Conditioning Engineers California Air Resources Board California Air Resources Board Classification, Labelling and Packaging Regulation Entry into Force Environmental Protection Agency US Environmental Protection Agency Ethylene Propylene Diene Monomer Fluorinated ethylene propylene Perfluoroelastomer Fluorine Kautschuk Material (Fluorine Rubber) Full Time Employees Gross Domestic Product Harmonised System of Classification and Labelling of Chemicals (GHS) Global Warming Potential Hydrofluorocarbons Hydrofluoroolefins Nitrile-butadiene Rubber Internal Combustion Internal Combustion Engine International Material Data System Light Emitting Diodes US Mine Safety and Health Administration Nitrile Rubber Non-Road Mobile Machinery Ozone Depleting Potential Original Equipment Manufacturers Polyether Ether Ketone Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 9 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members PFA PFAS PFPE PPS PTFE PVD PVDF PVF REACH SDS UV VMQ XNBR Perfluoroalkoxy alkanes Per- and Polyfluoroalkyl substances Perfluoropolyether Polyphenylene Sulfide Polytetrafluoroethylene Polyvinyl fluoride Polyvinylidene fluoride Polyvinyl fluoride Registration, Evaluation, Authorisation of Chemicals Safety Datasheet Ultra-violet Light Silicone Rubber Vinyl Methyl Silicone Carboxylated nitrile rubber Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 10 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 1 INTRODUCTION RINA Tech UK Limited (RINA) was requested by the Association of Equipment Manufacturers (AEM) to gather information from its members to support the stakeholder engagement currently being undertaken for Per- and Polyfluoroalkyl substances (PFAS) under the REACH restriction proposal1. Owing to the wide range of desirable physical and chemical properties that PFAS provide, they are used in a wide variety of products produced and applications for non-road equipment, as outlined in this report. 1.1 Profile of the AEM Membership The Association of Equipment Manufacturers (AEM) is an international trade group representing nonroad equipment manufacturers and suppliers with a global footprint. AEM comprises more than 1,500 member companies comprised of Original Equipment Manufacturers (OEMs), service providers and the extended equipment value chain. The full member list is available on the AEM website.2 These companies manufacture and provide critical products for the European market that serve valuable societal functions. AEM members develop and produce a wide range of products, technologies, components, and systems that ensure non-road equipment remains safe and efficient, while operating in some of the most demanding and severe environments on earth. Equipment often have extended lifetimes, with some equipment lasting over 40 years for certain applications. Non-road equipment is designed to execute specific functions relative to their intended applications in non-road environments. These complex machines normally require between 8 and 15 years of product development and testing prior to their introduction to the market. These end uses include operating in the construction, agriculture, mining, forestry, and utility sectors, and due to the variety of end-uses leading to a large swath of diverse machine forms and product types across the non-road sector. These diverse sectors include farming, road building, construction of industrial, commercial, and residential projects, movement of aggregate material, etc. Although AEM is North American-based, their members manufacture and distribute products globally with extensive holdings, sales and manufacturing activities in the EU. More specifically, non-road equipment can be broken down even further into more specific categories based on their operations and functionality, with example products shown in Figure 1-1: Equipment that is self-propelled or serves a dual purpose by both propelling itself and performing another function. - Examples: excavators, tractors, dozers, front end loaders, rough terrain forklifts. Equipment intended to be propelled while performing its function. - Example: chippers, plows, cultivators, wagons. Large-scale fixed installations include a combination of several types of apparatus and, where applicable, other devices intended to be used permanently in a pre-defined and dedicated location. - Example: tower cranes, light towers, generators, crushers, and screeners. ______ 1 Annex XV reporting format 040615 (europa.eu) 2 https://memberdirectory.aem.org/8_0/#/ Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 11 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Figure 1-1 Example products of AEM members. Machinery of this type represents significant capital investment from companies, which in 2023 is estimated to be 1.2 trillion as outlined in Figure 1-2. Considering the significant capital investment, it is critical that the equipment is operational for the maximum timeframe, which is dependent on the provision of spares and repair schemes, as outlined in Section 5.2. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 12 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Trillions 8.00 7.00 6.00 5.00 4.00 3.00 2.00 1.00 0 Figure 1-2 Value of capital assets accumulated by AEM customers ().3 1.2 Importance to Society AEM member companies have a combined revenue value of >$700 billion, with over 74.4 billion located in the EU region4. The sector supports 2.3 million direct jobs, which pay 33% above the national average.5 AEM members support the following key industries, which would be significantly impacted if a derogation for PFAS in this sector is not granted: Agriculture including forestry applications: The global population is expected to increase by 2.2 billion by 2050, which means farmers will have to grow roughly 70% more food than what is now produced. Maximising the potential of every acre farmed will be essential to meet this growing demand. Non-road equipment will help the agricultural sector meet this challenge, as well as help assist with key challenges such as precision agriculture (with the environmental benefits of this outlined in the AEM paper6), optimisation of water use and reduction of emissions.7 Construction and mining (including above ground/underground): Construction spans residential, commercial, industrial and infrastructure projects. The construction industry is a key contributor to the EU economy, representing roughly 5.5% of the EU gross domestic product (GDP).8 The EU equipment market in 2023 generates roughly 80 billion in revenue, employing 300,000 people in ______ 3 As provided by Fitch Solutions, with a conversion rate of 1 USD to 0.92 EURO. 4 Calculated from the value of construction equipment based on Our Sector in Figures (cece.eu), with and an additional equivalent to 86% of value of construction equipment. The additional revenue is calculated on the relative values of the global revenue figures to represent EU agricultural equipment revenue. 5 AEM Economic Impact Report - AEM | Association of Equipment Manufacturers 6 Microsoft PowerPoint - Environmental Benefits of Precision Agriculture 2021.pptx - Read-Only (aem.org) 7 Future of Food Production | Association of Equipment Manufacturers, AEM 8 Construction sector (europa.eu) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 13 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members the EU. If EU suppliers, distributors, and service partners are also considered these numbers are even greater. Construction and mining equipment is used to clean contaminated land, through mechanisms such a soil remediation, allowing health hazards to humans and animals as well as the environmental impact of the land to be addressed. The shares of construction equipment in the EU is outlined in Figure 1-3. Figure 1-3 Shares of construction equipment sales in Europe from CECE.9 Over the last 30+ years the construction equipment technologies industry has enabled many improvements within the broader construction industry, such as10: - 79% reduction in construction worksite injuries - 96% reduction in NOx and particulate emissions per gallon of diesel consumed - ~13% reduction in CO2 emissions per machine hour - 10-15% increase in fuel efficiency Power generation used for emergency and standby power generation for applications such as hospitals, alternative power sources for applications which are cut off from readily available power such as construction sites, mining, or agricultural applications. Waste and recycling - which facilitate more sustainable waste management systems and circular economy principals by extracting high-quality resources from waste where possible. As well as supporting broad societal aims such as the EU green deal. ______ 9 CECE Annual Economic Report, 2023 Annual economic report. 10 Construction equipment technology progress report draft Presented at CONEXPO 2023 (aem.org) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 14 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Billions The combined industry value of these sectors is even more significant to the wider economy, with the Agriculture and construction industry valued at over 1.3 trillion in 2023 as outlined in Figure 1-4. 1,600 1,400 1,200 1,000 800 600 400 200 0 Agribuisness value Construction Industry Value Figure 1-4 Agriculture and construction value in EURO.11 Diversity of the product ranges supplied AEM members provide a wide range of equipment, each of which provides unique functionality to the end user. These end-use applications provide the customer great value but can result in niche products with very low production volumes. Due to these challenges, replacing PFAS in each piece of equipment, presents a uniquely challenging endeavour from both a design and qualification perspective. Equipment manufacturers design equipment for different work sites, load types, duty cycles, end use applications, performance characteristics, customer requirements, and a number of other considerations. These design considerations can result in up to 10+ different design variants per machine form. Each unique machine variant requires its own battery of testing and validation to its intended operational environment as well as unique design considerations which require specific performance, quality, and safety testing. It is through these unique functionalities that AEM member customers, end users, and the wider market will capitalise on the value offered by off-road equipment. The following are examples of how the PFAS restriction could impact non-road equipment due to resource limitations (lack of qualified engineers, testing facilities, product designers, money, etc.): Equipment currently offered at a variety of size/weight ratings will be reduced to a more limited offering For example, cranes are designed to handle different load requirements, with larger loads tending to require larger cranes. Different sized equipment has different technical requirements, which necessitates the need for specific testing relative to the envisaged product use; meaning that the ______ 11 Fitch Solutions, with conversion of USD to Euro at 1USD= 0.92 Euro. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 15 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members qualification of one product does not mean all products are suitably qualified. As such, if only higher rated cranes were to qualify PFAS-free alternatives due to time or resource limitations, lower rated cranes would no longer be available for the EU. As a result, sites unable to accommodate larger cranes due to geographical limitations, would go unsupported by the off-road equipment sector, as using larger cranes could cause an increased rate of damage to the worksite. A similar situation could be expected for a host of other equipment types, including excavators which are offered in a variety of weight categories. Specialist application products with less revenue, may not have sufficient demand to undertake qualification activities For example, agricultural equipment for grape harvesters or orchard low clearance tractors are niche products of low volume, which compared to standard-design tractors will be less of a priority to qualify PFAS-free alternatives where they are available. This will result in whole industry sectors, such as the wine industry, with less specialised and suitable equipment. Another example is horizontal directional drills which are only manufactured in quantities of a dozen or so per annum, and as such should be classified as a low volume sale. As with the above example, equipment of this type will not be a priority for qualification and redesign which will result in equipment not being available for the market. Without these specialised machines alternative techniques will need to be used, such as utility projects requiring full trenches, which result in significantly higher costs and waste. The only way to continue to use newer, more efficient methods would be to use older equipment, which will need to remain in service longer, requiring the use of PFAS containing spares parts. As such, it is critical that sufficient time is permitted in the derogation for all equipment to have sufficient time to identify and qualify PFAS-free alternatives. Supply chain effects The non-road equipment supply chain makes these impacts even more significant, complex and widespread. Non-road OEMs have supply chains that are up to 22 layers deep with up to 10,000+ suppliers for a single manufacturer. Each end product contains around 100,000 unique parts which make any PFAS restriction incredibly impactful. As such, the impacts of the proposed restriction will create extensive repercussions across the global supply chain that are orders of magnitudes higher than the impacts outlined above as the effects will be multiplied throughout the supply chain. 2 PFAS SUBSTANCE IDENTIFICATION PFAS are used as substances, mixtures, and polymers for use in components as well as in the manufacturing process. Table 2-1 outlines a general overview of the known PFAS uses in the non-road industry. The effort to identify all PFAS in AEM member equipment is still on going and poses a number of challenges as outlined in Section 2.1. Table 2-1 PFAS substances currently identified by AEM members and uses, ordered by most common uses. Currently identified PFAS substances Polytetrafluoroethylene (PTFE) CAS 9002-84-0 Indicative Uses Seals and O-rings in a wide range of applications Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 16 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Currently identified PFAS substances Fluoro-rubber (FKM) Poly(vinylidene fluoride) (PVDF) CAS 24937-79-9 Perfluoroalkoxy alkane (PFA) Fluorosilicone (FVMQ) Perfluoropolyether (PFPE) Fluorinated ethylene propylene (FEP) Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene 1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene and tetrafluoroethene CAS numbers 9011-17-0, 26655-00-5, 185701-88-6, 60164-51-4, 9002-84-0, 25190-89-0 1-Hexene, 3,3,4,4,5,5,6,6,6-nonafluoro-, polymer with ethene and tetrafluoroethene CAS number 68258-85-5 Poly[oxy[trifluoro(trifluoromethyl)-1,2-ethanediyl]], .alpha.-(1,1,2,2,2pentafluoroethyl)-.omega.-[tetrafluoro(trifluoromethyl)ethoxy]- CAS number 60164-51-4 Indicative Uses Hoses for uses such as fuel, hydraulic, coolant, and air systems. Mechanical systems parts such as hydraulic cylinder rings, thrust plates, pistons, hydraulic control valves and vents. Lubricants and greases. Electrical wiring and components such as light emitting diodes (LED's). Paint Seals and O-rings in a wide range of applications. Hoses in applications such as coolants. Mechanical systems such as in clutch disks and control valves. Electrical wiring O-rings and seals O-rings and seals Oil additives Various components Engine components such as valves and wiring. Hoses Power train control and energy systems. Drive train PCB and electronic assembly parts such as engine control modules, actuators, temperature sensors and NOx sensors. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 17 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Currently identified PFAS substances 4,4'-[2,2,2-trifluoro-1-(trifluoromethyl)ethylidene]diphenol (bisphenol AF) CAS number 1478-61-1 Hydrofluorocarbon (HFC) & Hydrofluoro olefins (HFO) such as 134a and 1234yf N-(Methyl)nonafluorobutanesulfonamide Propanoyl fluoride, 2,3,3,3-tetrafluoro-2-(1,1,2,3,3,3-hexafluoro-2(heptafluoropropoxy)propoxy)-, polymer with trifluoro(trifluoromethyl)oxirane, reaction products with 3(ethenyldimethylsilyl)-N-methylbenzenamine Oxetane, 2,2,3,3-tetrafluoro-, homopolymer, fluorinated CAS number 113114-19-5 Hexafluorosilicic-acid CAS number 16961-83-4 Benzene, 4-[(trans,trans)-4'-ethenyl[1,1'-bicyclohexyl]-4-yl]-1,2-difluoro(9CI) CAS number 142400-92-8 1-Butanaminium, N,N,N-tributyl-, hexafluorophosphate(1-) (1:1) CAS number 26655-00-5 Methanone, bis(4-fluorophenyl)-, polymer with 1,4-benzenediol CAS number 29658-26-2 Indicative Uses Grease applications Gasket, seals, valves, and sensors. Refrigerants used in cabin cooling and battery thermal management systems. Covers and seats PCB's Other uses 2.1 Challenges in Substance Identification Efforts are underway by AEM members to obtain data on the chemical composition of their products, but as yet not all PFAS have been identified due to the following reasons: 1. AEM members are reliant upon their supply chain for the identification of PFAS in components and sub-systems supplied. The supply chain of AEM members is global and complex, with up to 22 layers covering over 250,000 parts that are at risk of containing PFAS. As of yet there is no regulatory obligation for the recordkeeping, reporting and communication of PFAS information to downstream users or regulatory bodies. Due to the inexperience and immaturity of the global supply chain in addressing global chemical compliance regulations, it is estimated that the offroad equipment industry needs at least 5 years to collect roughly 80% of the needed data on PFAS. The information flow through the supply chain is outlined in Table 2-2. This estimate assumes that upstream suppliers are able to provide high quality chemical information to downstream manufacturers in a timely and efficient manner. This estimate also assumes the number of PFAS chemicals under assessment are limited in scope and identifiable by CAS number. These efforts also assume the data collection effort will not be hampered by confidentiality claims which prevent the communication of PFAS information to downstream users. It is possible due to the scale, complexity, and knowledge-base of the global supply chain that this timeframe will be much longer. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 18 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members These efforts will be complicated further by the fact that even when equipment manufacturers obtain substances with safety data sheets (SDS), the SDS may not identify all constituent chemicals in the underlying product, as some PFAS are not classified as hazardous substances under the Classification, Labelling and Packaging (CLP) Regulation/ Harmonised System of Classification and Labelling of Chemicals (GHS)). As such, without an identified hazard classification, the SDS will not indicate any PFAS chemicals contained within the material. AEM members through their engagement with their supply chain regarding PFAS are working to educate their suppliers for the need to collect and report this information. However, due to the vast and global nature of their supply chains, this will take a considerable length of time and resources. 2. The determination of what is a PFAS substance. Due to the way that PFAS has been defined there is no exhaustive list of identified PFAS chemicals. To complicate this issue further, different references from academic research, regulatory agency activity or incoming legal requirements use different descriptions of PFAS in their defined scope. Some of these definitions are narrower, requiring multiple adjacent carbon atoms with a varying number of attached fluorine atoms to the larger chemical structure, to the broadest definition which includes any compound whose structure contains at least one carbon atom attached to a fluorine atom. These definition differences introduce confusion to the marketplace, hampering a company's efforts to identify the total number of PFAS compounds in their products. 3. The number of substances. The number of PFAS included in the scope of the restriction is estimated to be >12,000 unique chemical substances. This is the first time such a significant number of substances have been dealt with at one time and as such, it is important that sufficient time is permitted to allow alternatives to be identified and qualified which introduces constraints regarding resources to undertake such work in parallel. Table 2-2 Estimated Timeline for the Non-Road Equipment Industry to identify PFAS within its supply chain. Activity Identify all substances classified as PFAS Identify high risk component types Create list of at-risk parts and subcomponents Update internal data collection and compliance systems Supplier Communication and training Request data from suppliers Format data into a consistent format as the non-road industry does not possess a system like International Material Data System (IMDS) so there is currently no common format to collect the required information. Data accuracy checks and data storage. Total Time 6 months 8 months 6 months 9 months 9 months 20 months 2 months 60 months 2.2 PFAS use within Non-road Equipment Manufacturers of non-road equipment rely upon the unique functionality of PFAS for their equipment, components, and manufacturing processes, with members estimating that up to 99.5%12 of their components would either be directly or indirectly affected by the PFAS restriction. ______ 12 Based on AEM member review of known PFAS uses within their current Bills of Materials. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 19 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 3 TECHNICAL REQUIREMENTS AND ANALYSIS OF ALTERNATIVES AEM applications often require demanding technical requirements due to the challenging environments in which these types of machines operate. Manufacturers design their products to operate for decades under extremely harsh, demanding, and arduous work environments. Materials, parts, and components need to meet rigorous design and testing requirements to ensure critical functions operate safely, continuously, and effectively on the jobsite. The specific characteristics are informed by the technical function of the component/system but can be generally described by a combination of the following: Pressure - various systems, such as the hydraulic and engine systems, experience extreme pressure environments up to 500 bar. Temperature - the engine compartment, regenerative breaking components13 and exhaust system operate at temperatures as high as 800C. - Non-road equipment is also exposed to cyclical temperature cycling due to its operation outside which can be exposed to temperatures ranging from as -57C to 230C. Mechanical - machines possess a high degree of mechanical wear and tear, sealing parts must survive the shear forces due to the mechanical movement of the equipment. Chemical resistance - seals interact with various fluids and gases, requiring a high degree of chemical and corrosion resistance to ensure the reliability of exposed parts. - Exposure to substances such as fuel, hydraulic fluid, coolant with additives like 2-ethyl hexanoic acid, and carboxylic acids, exhaust gas fumes (highly acidic) and engine oil (highly alkaline). Electrical and flammability resistance. Vibration up to 45.0 mm/s which can cause high frequency fatigue to components due to the repeated strain imposed. The mechanical alternating stress between joint components will make joints undergo cyclic tension and pressure, which may cause the generation, expansion, and extension of cracks. Long-term durability against factors such as ultra-violet (UV) light as the machines are used in outdoor environmental. Light weight such that the energy consumption and CO2 to move the system is minimised, as shown in Figure 3-1. Operation in hazardous or explosive environments requiring ATEX rating (the minimum safety requirements for workplaces and equipment used in explosive atmospheres), such as in chemical plants, mining, and petrochemical applications. High reliability over periods of up to 40 years. Withstand harsh environments, such as: ______ 13 Such as break resistors which recover the heat from breaking to decrease the overall energy requirements of the system. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 20 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members - Landfills where machines will experience consistent exposure to a wide variety of substances and mechanical damage. . - Mining and earth moving equipment where operation in extremely dusty, humid, wet, muddy, and damp environments is necessary. The operation of such equipment is often up to 24 hours a day over extended periods of time. Due to the need to carry heavy payloads over rough terrain, the energy and therefore high temperature requirements of these systems are especially demanding. - Exposure to salt spray due to their operation near the sea. It is essential that any replacement material meets the necessary performance requirements and still offers the same durability, quality, and safety of PFAS. The importance of the reduction in weight of a system can be seen in Figure 3-1, which shown as the average weight of the system increases, so does the real-world CO2 production, with modern cars being pushed to have lower weight to meet regulatory requirements. Figure 3-1 Relationship of weight and CO2 emissions.14 Safety requirements Operating non-road equipment includes a number of inherent challenges, such as working alone, at night, in high traffic metropolitan areas, in a remote work area, or in confined spaces. As such, the ______ 14 The 2022 EPA Automotive Trends Report: Greenhouse Gas Emissions, Fuel Economy, and Technology since 1975 (EPA420-R-22-029, December 2022) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 21 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members equipment is tested to rigorous safety standards which is key for AEM members as their equipment operates in inherently dangerous environments. Mitigating safety risks associated with the use of non-road equipment is a critical objective for AEM member companies. One fifth of all fatal accidents in the EU occur in construction sites whereas the mining sector experiences ten fatal accidents per 100,000 employees.15 AEM members continually work to improve their product's safety features by designing their equipment to meet voluntary consensus safety and performance standards, as well as mandatory regulatory requirements. In the mining sector, fire safety represents a major hazard that regulators look to mitigate as much as possible. In order to address this risk, the US Mine Safety and Health Administration (MSHA) promulgates their mandatory regulatory standard, ASAP 500116 which establishes robust requirements for flame testing, product evaluation and acceptance of solid products taken into underground mines. Hazards relating to fire have significant impacts on the safety of operators, with one large equipment manufacturer within AEM reported that there were approximately one hundred fire related events reported per year in the U.S. alone. Incidents such as this represent approximately forty percent of all accidents reported over an eight-year reporting period. PFAS provides critical functionality to current and future safety design requirements, and there is the concern that the removal of PFAS will significantly increase the fire safety risks for operators. AEM Members voluntarily participate in a multitude of recognised standards development activities which assist in the continuous improvements of their products. The product safety requirements for nonroad equipment must meet and often exceed the plethora of performance requirements listed in international safety and performance standards such as: ISO 12100 Risk Assessment standard, ISO 19014 Functional Safety standards, and ISO 19353 Safety of machinery -- Fire prevention and fire protection to ensure safe-systems and safety policies needed as it relates to the products. The 12100 risk assessment process requires an evaluation of potential hazards or the likelihood of causing harm that may arise from an identified safety related malfunctioning component, system, or the entire equipment. Therefore, if any component used as a safety related control is changed after the original functional safety assessment is performed, then the product must be revalidated and verified under a new risk assessment. Any piece of equipment may contain many thousands of such components, each which would need to be tested for factors such as mean time to dangerous failure. Such testing is currently based on historical field failure data, which relies on the historic use of PFAS as a critical component of most machine safety systems. As such, understanding PFAS restrictions on component performance and mean time to failure would take years to fully understand. Application specific requirements The following sections outline each of these requirements in detail, bringing forth specific requirements that non-road machines need to meet. ______ 15 According to EUROSTAT data. 16 ASAP 5001 - Application Procedures for Acceptance of Flame-Resistant Solid Products Taken (msha.gov) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 22 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 3.1 Seals and Hoses Fluoropolymers are used in gasket, seals, and hoses to transport fluids from one location to another, prevent fluid leaks, and maintain the cleanliness of the equipment's components and systems. The requirements of such components include: High temperature performance with some applications up to 250oC Withstand highly pressurised environments, for hoses experiencing up to 415bar Withstand exposure to chemical substances with low absorption Suitable mechanical properties such as material hardness within 60 to 95 Shore, excellent recovery, and creep Long service life, with some equipment requiring highly demanding technical performance for up to 40 years A typical device manufactured by AEM members can contain anywhere between 50 to over 3000 PFAS seals in a single device, with the exact number depending on the specific requirements of the device and its complexity. A single AEM member can have over 100,000 different hose types to support the equipment that they manufacture. Hydraulic hoses are tested to standards such as ISO 3457 and EN 474-1 which state that such hoses contain fluid at more than 50 bar and/or having a temperature over 50oC which require guarding to ensure the safety of operators. Specialist hydraulic hoses are designed to ensure that the risks of pinhole leaks and high pressure bursts are minimised while still maintaining compatibility with the broad range of substances the hoses are exposed to. As yet there are no technical alternatives to PFAS, with some suggested alternatives having decreased flexibility and strength over time, degrading the durability and lifecycle of the component. The closest alternative nitrile rubber (NBR) material is estimated by AEM members to reduce the life of the system by 97%, with a FKM O-ring having a 120x longer lifetime than a NBR substitute. In part this is due to NBR having a 30-fold increase in fuel permeability compared to FKM. The decrease in performance can be observed with tests such as the exposure to coolant as outlined in Figure 3-2 which showed failure of Hydrogenated Acrylonitrile Butadiene Nitrile Rubber (HNBR) after 1 week. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 23 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 350 300 PFAS 250 HNBR Sealing Force (N) 200 150 100 50 0 0 24 48 72 96 120 144 168 192 Time (hr.) Figure 3-2 Compressive Stress Relaxation Sealing Force via SAE J2979 in Organic-Acid Technology (50-50 Premixed Ethylene Glycol- Distilled Water) Coolant Aged at 175C. As a consequence of the reduced lifetime, the replacement of O-rings which is currently around every 6 months, will be reduced to weekly replacements with significant increases in the amount of waste produced. Frequent parts replacement and maintenance will increase the downtime of equipment, which depending on the location of the seal can vary from 1 hour to 24 hours. During the maintenance and part replacements there is also the possibility that contaminants will be introduced into the system due to the surrounding environment. These contaminants can introduce further degradation issues and can result in the increased wear and tear on all system components, or the early failure of the entire system. Given the number of essential end sectors which AEM members support, the unavailability of equipment for up to 1 day per week will have a significant impact on the sectors they support. There is also a particular concern with hoses in high pressure fuel systems. PFAS-free alternatives are currently not compatible with bio-based renewable fuels, as shown in Figure 3-3 with the drop in performance after 1000 hours. The HNBR test specimen degraded with blisters and cracks occurring, which resulted in the part not being suitable for further testing as it was no longer dimensionally stable. This lower durability would lead to leaks in the high pressure fuel system, which can lead to significant safety and environmental hazards. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 24 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members B0 (ULSD)_FKM 60 Compression Set, % 50 B20 (20% B100 / 80% B0)_FKM 40 B100 (100% Biodiesel)_FKM 30 B0 (ULSD)_HNBR 20 10 B20 (20% B100 / 80% B0)_HNBR 0 B100 (100% Nexsol 0 1000 2000 3000 4000 BD-100 Aging Time, hr. Biodiesel)_HNBR Figure 3-3 Aging of FKM vs. HNBR O-rings in B0, B20 and B100 Fuels at 125C via ASTM D471 for Compression Set17 via ASTM D395. While there are many other known materials that are marketed for use in sealing, each material beyond NBR has technical and chemical limitations which prevent their use in non-road equipment. This is especially true when considering the performance and durability profile of non-road equipment is measured in decades, requiring long-lasting parts and systems. As shown in Figure 3-4, the long-term performance of PFAS is significantly longer than any known alternative. The combination of properties make PFAS uniquely suited for use in non-road equipment, and as such when considering potential alternative, it is crucial to understand the technical characteristics required for use in these machines. For example, the synthetic rubber ethylene propylene diene monomer (EPDM) is unable to operate under the high pressure and temperatures in which non-road equipment operate. Sudden pressure losses due to hydraulic hose failures can cause loads to drop suddenly on a jobsite, significantly increasing potential harm to workers and negatively impact the environment with fluid leaks. Furthermore, polyamide resin materials, when compared to PTFE, have a fuel permeability 140 times higher. Replacing PFAS with inappropriate material substitutes would compromise the functionality of corresponding parts and components, cause safety issues and significantly increase waste and product obsolescence as outlined in Section 5.2.1. ______ 17 Essential for Static Sealing Capability. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 25 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Figure 3-4 Long term sealing performance.18 3.2 Electronics Electronics are deployed ever more frequently in non-road machinery to provide the functionality expected of such equipment, as well as to provide essential safety and environmental features. For example, cameras and displays are often used to ensure safety of the operator and those working near the machine. In addition, the displays provide important machine diagnostics and status to the worker. Sensors and engine control systems are also integral to the engine emissions systems. There is also a growing regulatory and market interest in the adoption of zero emissions equipment, which drive an even higher demand for lightweight, compact electronics. Cables and electrical insulation, including heat shrink tubing, is a key component of most electronic components. Electronic components need to meet the following characteristics: Withstand the operational temperatures of the machines. Low water vapour permeability due to the operation in high humidity environments. Oil resistance. High insulation resistance, with fluoropolymers having the lowest dielectric constant (2.1) and dielectric loss tangent (2x10-4) among all polymers. Non-flammable characteristics due to high oxygen index of 95% or more, making it difficult to combust. With cables utilising standards such as UL94V-0.19 ______ 18 Fluoroelastomers Handbook, The Definitive Users Guide. 19 Standard for Tests for Flammability of Plastic Materials for Parts in Devices and Appliances. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 26 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Suitable mechanical properties (high tensile strength, bending modulus, and elongation) to withstand damage, while having suitable sliding requirements. Small diameter due to size constraints of many devices and the consideration that increased weight of the overall equipment which would likely result in higher CO2 emissions. Cables in AEM equipment are often classified to standards such as ISO 6722 Class D.20 Only fluoropolymers, such as FEP and PTFE, meet these performance requirements. PFAS-free materials would result in a drastic reduction in the durability of components, and therefore AEM members products as alternatives have a much higher level of brittleness. Additionally, PFAS provides insulation properties in wiring and other electrical systems, losing PFAS would expose the machine to a drastic loss of insulation when exposed to extreme temperatures, increasing the risk of shorting, electrical shock, and fires. Finally, the loss of PFAS would decrease the flame retardancy of various components which are critical to the ongoing safety of people, products, and the public. Importance of fire retardancy Non-road equipment are heavy duty machines intended for use in hazardous and extreme environments. Almost all these machines will require a high degree of fire and flame suppression to keep the operator and other worksite people safe from harm. Even with manufacturers designing their equipment to modern high quality safety standards, there are still instances of fire related accidents, with examples outlined below. Therefore, it is essential that any design change does not adversely affect the flame retardancy of the overall system. Since the year 2000, there have been more than 150 underground mine fires reported in the United States. Two mine workers were fatally injured because of an underground mine conveyor belt fire in 2006 in West Virginia, causing smoke to obscure the fresh air passageway that the miners were supposed to use for their escape. During the same time, twenty-five spontaneous combustion fires have been reported in underground coal mines. According to the MSHA, there are approximately fifty fire related ignitions each year. AEM members have already observed a limited number of fire related events that were likely caused by a change of flame retardant material without proper re-certification.21 OEMs take fire risks very seriously, where the design and implementation of an effective fire suppression systems and the use of fire retardant components can help save lives. PFAS are used in high-voltage electrical circuits to limit arc fault impacts to equipment operators and bystanders. Arc faults are a result of electrical discharge which involves significant heat and light generation followed by a pressure wave. Arc faults can occur due to voltage spikes from the switching of reactive loads, touching of electrical probes to an incorrect surface, worn, loose electrical connections, dust, and corrosion, or during lightning strikes. An arc fault can carry thousands of amps of energy/power that pose a significant safety risk to nearby workers. Arc flash events will become significantly more problematic as more electrically powered products are introduced and replace traditional internal combustion powered products to market. AEM members expect increased fire and electrical hazard events if a derogation is not permitted for PFAS substances, as currently no alternative can offer the same performance, durability, or protection for the end user. It is also possible that any fire events would be more severe in nature without PFAS. ______ 20 Road vehicles -- 60 V and 600 V single-core cables -- Dimensions, test methods and requirements. Class D requiring the testing between -40C to 150C. 21 The details of which are confidential to AEM member companies. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 27 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Semiconductor essential uses Semiconductors are used in critical systems to ensure the safe use of machines including machine control systems that provide functional safety, engine emission reductions, object-detection, collisionavoidance, and autonomy. PFAS are key enablers of the semiconductor manufacturing process and are broadly used in electronics due to their flame retardant properties, resistance to environmental chemicals and operational temperature range. 3.3 Mechanical Systems Numerous mechanical systems are utilised in non-road machinery, with the types of system dependent on their intended function in the equipment. The following are indicative examples of such systems in non-road equipment and is not intended to be an exhaustive list. Gearing mechanisms: The use of gears typically facilitates the transmission of energy from the powertrain system to the physical operation of the machine. PFAS provide frictional and mechanical stress resistance to ensure the durability of the components found in these systems. Without gearing mechanisms, the machine is more likely to experience safety issues, mechanical failures, and premature obsolescence. Friction Plates: Friction plates allow the transmission input shaft and the engine to run at the same speed when rotating, without which the engine would not be able to properly transmit its power to the machine. Additionally, friction plates are also used in braking systems. The plates experience a significant amount of mechanical, friction, and heat stress, as well as a high rotational energy. PFAS provides essential chemical properties to safeguard the durability of the component. Without PFAS these components would fail at an unknown but elevated rate, leading to more waste, elevated safety risks, and shortened lifespan of the equipment. Clutch plates (high energy) and brake friction discs: PFAS are used in the clutch plates and friction disks due to their ability to withstand the high temperature, mechanical stress, and the number of cycles these components experience over their lifecycle. All potential substitutes would decrease the current life of the component by at least 75% and trigger the need for a full redesign of the transmission controls and cooling system, as well as a full recertification of the brake systems. As such, these systems would require a full replacement an estimated 3-4 times during the lifetime of an average product, with each replacement requiring over 100 hours of labour and a downtime of up to 3 weeks. Self-lubricating bearings: Bearings come in a variety of shapes, designs, and sizes, all of which are required to possess a combination of important properties to provide the required performance and reliability for the intended conditions of use and lifetime. The requirements for each specific property depend on multiple variables including engine capacity, conditions of use, conditions during rebuild and servicing, rotation velocity, loading, etc. Self-lubricating bearings require PFAS coatings like PTFE due the following properties: Thermal resistance up to 250C. Universal chemical stability. Low Coefficient of friction (dry) of the bearing < 0.2 (in Standardised FM-Test @ 10 MPa), usually this is between 0.03-0.05. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 28 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Bearings provide critical functionality to engines, with up to 40% failures in electric and hybrid engines being associated with bearing failures.22 Other potential alternative coating polymers with high thermal and chemical stability, such as polyphenylene sulfide (PPS) and polyether ether ketone (PEEK), are not able to offer the required coefficient of friction as PEEK has values of 0.35-0.45 and PPS around 0.4. Vents and membranes are used in AEM equipment in multiple different locations including: Manage internal pressure, moisture, and condensation. Filter and clear hydric fluids with up to 75% of hydraulic system problems are caused by contamination in the fluid.23 3.4 Hydraulic Fluids Hydraulic fluids enable the transfer of power from the engine to machine functions in their hydraulic systems. The vast majority of non-road equipment rely on hydraulic systems to carry, push, dig or lift heavy loads. Without this important technology, much of the work performed today would require radically different, and less efficient, technology solutions. Prominent examples of machines and systems that use hydraulic power include excavators, cranes, forklifts, lifts, dozers, graders, loaders, shovels, trenchers, and concrete pumping systems and off-highway haul trucks among others. Hydraulic fluids must possess a variety of crucial properties to protect the longevity of the hydraulic system and its components. In turn, the durability of these systems helps ensure that the machine continues to operate in a safe and efficient manner. Standards such as ISO 4413:2010 (Hydraulic fluid power -- General rules and safety requirements for systems and their components) specifies general rules and safety requirements for hydraulic fluid power systems and components used on machinery as defined by ISO 12100 (Risk assessment and risk reduction). The fire-resistance properties of hydraulic fluids are specified by various standards, such as ISO 7745:2010, which details crucial performance factors when selecting potential fluids. Voluntary consensus safety and performance standards, such as these, are used as a voluntary guideline by non-road equipment OEMs to meet the regulatory, safety, and customer requirements of the marketplace. Pin hole leaks, sudden drops in pressure, or contamination of the fluid can all cause serious safety issues for the operator or maintenance team. To avoid these types of safety concerns, hydraulic fluid producers utilise certain PFAS to provide the corrosion, chemical, temperature and wear resistance needed for the system to operate smoothly. The PFAS in hydraulic systems depend on the end application, but examples include 1-propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene, perfluoropolyether and propanoyl fluoride, 2,3,3,3-tetrafluoro-2. The longevity of hydraulic fluids is essential as several major original equipment manufacturers report that warranty claims tend to spike after an oil change, so extending the oil change interval has a direct impact on a machine's reliability.23 ______ 22 Frontiers | Performance Characteristics of Lubricants in Electric and Hybrid Vehicles: A Review of Current and Future Needs (frontiersin.org), 2020. 23 IFPE 2020 Expert Q&A: How Hydraulic Fluid Impacts Machine Performance (aem.org) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 29 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 3.5 Paints and Coatings Coatings protect non-road equipment from chemical, weather, and water erosion. Well-designed coatings can help extend the useful life and maintenance requirements for non-road products and are highly valued by OEM's and their customers. Many coating manufacturers use PFAS in their paints to improve: Paint flow and spread (the ability of a paint Scratch and scuff resistance, to form a smooth surface, rather than crack resulting in an orange peel effect), UV/weathering resistance, Anti-blocking (i.e. Reduce tackiness of painted surfaces) resulting in suitable dirt pickup resistance, Oil repellent properties, Flame resistance, In specialty paints to give stain-resistant, graffiti-proof, and water-repellent properties. Glossiness of the coating by decrease bubbling and peeling, The chemical identification of PFAS used in the coating, as well as the exact technical requirements of these substances are usually considered confidential business information. Any details on these specific pieces of information will need to be provided by the manufacturers of these substances. Powder coatings are used in many electrical systems as well as on cable and wiring. Due to the strength of the C-F bond in PFAS, they offer high thermal resistance. PFAS such as PTFE and PFA are noted as being particularly effective with melting points in the 260 - 327C range.24 Alternatives lack the thermal stability of PFAS, with most epoxy based coatings only rated up to 200C.24 Many non-road products have systems that will exceed 200oC, which only PFAS has the thermal stability to safety operate at without breaking down. 3.6 Sealing Technologies Adhesive tapes are used in non-road equipment to protect and bind wire harnesses that transmit electricity and electrical signals to power equipment and control equipment. The tapes are often based on PTFE, although other PFAS are also used. General PFAS containing sealants are also used within AEM equipment. PFAS are essential as they offer the essential combination of the following technical parameters: Heat resistance, Electrical insulation, Sliding wear resistance, Oil resistance, and Corrosion resistance, Chemical resistance PFAS substances are the only known materials that can withstand such environments. If other materials such as PVC, are used, the material will deteriorate in environments with repeated high and low temperatures, causing cracking and peeling, and will not retain its functionality over the long term. As a result, the wires in a wiring harness may break causing the electronic components or devices to fail. In many systems, electrical failure will cause immediate safety concerns, especially when those systems provide driving control, braking, visibility, or steering. In other cases, electrical system failure may disrupt ______ 24 Per- and Polyfluoroalkyl Substances and Alternatives in Coatings, Paints and Varnishes (CPVs) (oecd.org) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 30 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members the engine control unit, causing the release of untreated emissions from the engine. At this point in time, many sealing technologies used in non-road equipment have no known alternatives. The loss of these materials will severely impact the safety, performance, environmental, and control systems in almost all non-road machines. These failures will negatively impact the ability of policymakers to enforce many existing regulations that aim to prevent fluid leaks, engine emissions, CO2 reductions, safety hazards, end of life recycling efforts, and other environmental impacts. 3.7 Lubricants AEM member companies support the need for a derogation for lubricants where the use is undertaken in harsh conditions, or the uses are needed for the safe functioning and safety of the equipment. Nonroad equipment relies on the critical functionality lubricants provide to their products. AEM members manufacture products with a number of moving parts that require lubrication during operation. Lubricants fill at the molecular level the micro-roughness of metal surfaces preventing metal to metal contact reducing operating temperatures, friction, and wear. Considering the long-lifetime of non-road equipment, lubrication has to offer and maintain the necessary technical performance requirements for decades. Non-road equipment also have the added consideration that many of its pieces of equipment are used in: Demanding applications including the function of the equipment 24 hours a day, and In remote and/or dirty and potentially muddy environments where the reapplication of lubricants is not always possible, or could introduce contamination into the systems, therefore causing the premature failure of systems. It is also important to note that the use of lubricants not only enables the required technical functionality required by the equipment, but also leads to higher fuel efficiency, and lower CO2 emissions. Lubricants utilising PTFE are used in numerous applications, including the manufacture of the equipment which is discussed in Section 3.11. The following are some of the applications in non-road equipment: Engine and gear oil, Piston assemblies, Lubricate threads, joints, and assemblies such as the foot pedal. Bearings, Lubricants need to offer highly specific technical parameters, with the standards outlined in Table 3-1 being just some of the standards which lubricants are qualified to. Table 3-1 Standards which lubricants are qualified to (non-exhaustive list). Parameter Indicative Standard Consistency ASTM D217 Corrosion resistance ASTM D6138 Oil release properties IP 121, ASTM D1742, ASTM D6184 Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 31 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Parameter Indicative Standard Fretting resistance ASTM D4170 Oxidation stability DIN 51821 Resistance to high operating temperatures ASTM D22665 Low-temperature torque ASTM D1478 Mechanical stability ASTM D217 Resistance to physical degradation ASTM D18831 Seal compatibility ASTM 4289 Wear properties to rolling contact fatigue DIN 51818 Water resistance ASTM D1264 Although there are PFAS-free lubricants, they do not offer the necessary technical requirements to enable the safety and performance requirements of non-road equipment, as shown in Table 3-2. PFAS-free lubricant Table 3-2 Technical review of PFAS-free lubricants. Technical concern General mineral oils Lower heat resistance and low temperature resistance Unable to be used with prolonged periods with rubber components Silicone oils Greatly reduced lubricity Ester oil and polyglycol oil Unable to be used with prolonged periods with rubber components Acaltlecriunmat,ivaelumtihniicukme,nbearsriume.g. Lower heat resistance Dry Film Lubricants such as PTFE coatings, are also used in non-road equipment components such as sliding guides, piston skirt coatings, exhaustive gaskets, and rotators as they offer minimal friction, over extended time periods. Components such as these often have geometrical or accessibility issues which limit the use of non-solid greases or are used in areas where the migration of greases could contaminate the system. 3.8 Refrigerants Given the envisaged timeline to qualify alternative refrigerants, it is also highlighted that derogation 5p refrigerants in mobile air conditioning-systems in combustion engine vehicles with mechanical compressors needs to be permitted until 20 years after EiF. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 32 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Temperature management is a crucial product safety design requirement in the non-road sector in two keys areas: cooling of the engine, and cooling of the cabin. Internal coolants ensure machine systems are able to safely operate in demanding end-use applications and the severe environments frequently encountered in the non-road sector. For example certain equipment produced by AEM members operate in mine sites where it is not possible to control the environmental temperature exposing the equipment, and operator, to extremely high temperatures. Having access to effective refrigerants is crucial in these environments. Workplace safety requirements mandate cabin temperatures suitable for operators, with standards such as BS EN 13000 for Cranes requiring the `average air temperature inside the closed cabin at 25C maximum'. Many machines have enclosed operator cabins near large diesel engine exhaust systems, with few options for ventilation due to environmental concerns. Maintaining safe temperatures for the operator can only be achieved through the use of refrigerants and cooling systems. Ensuring equipment operators remain comfortable while working is an important safety and comfort feature needed in modern machines. Non-road equipment uses primarily two refrigerants, HFC-134a and HFO-1234yf. Ideal refrigerants need to possess non-corrosive and non-toxic characteristics with a low global warming potential (GWP), zero ozone depleting potential (ODP) and a low boiling point. Refrigerants, such as hydrofluorocarbons (HFCs) and hydrofluoro-olefins (HFOs), are used due to their thermal stability over long periods of time, low toxicity, and non-flammable and non-corrosive properties. There are only three refrigerants: R-152a (1,1,-difluoroethane, a PFAS), R-290 (propane) and R-744 (CO2) seen as potentially viable alternatives. However, due to significant technical challenges associated with these refrigerants, they are not used in off-road equipment. Specifically: R-152a is more flammable and has a higher GWP than R-1234yf and is only used in secondary loop systems. R-290 Highly flammable and not currently used in any systems. Would require dual secondary loop type systems. R-744 requires a 10-12x higher pressure than 1234yf, therefore requiring an alternative system design. It is also known to cause higher degrees of noise and vibration which would need to be managed. Further refrigerants such as ammonia can work for certain applications, such as in some large-scale fixed installations. However, in mobile systems these alternatives are not suitable due to their flammability and corrosivity concerns. Mitigating potential flammability risks from refrigerants is a key priority for AEM's member companies. Figure 3-5 outlines the effects of flame events in the presence of certain refrigerants. As shown, PFASrefrigerants burn more slowly and with less energy than known alternatives (R-290). In comparison, alternatives like butane burn with more energy at a much faster rate, making these types of alternatives unsuitable for any type of non-road machine. The types of tests involved in determining the suitability of refrigerants in this sector include the following: Flammability Including sets for basic property testing (burning velocity, heat of combustion, minimum ignition energy, lower flame limit to standards such as SAE CRP1234 with the full list of American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHARE) standards Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 33 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members and guidelines outlined on their website25), battery ignition and electrical short failure, engine bay simulation, and interior and underhood testing. Materials compatibility with all components envisaged to be potentially contacted by the refrigerant. Figure 3-5 Comparison of the effect of flame occurring. In addition to meeting the technical requirements, manufacturers perform detailed safety and risk assessments for each product using a fault tree approach such as the simplified version presented in Figure 3-6. Manufacturers consider a variety of different scenarios, such as the variables listed below, and only when the risk for all potential situations is determined to be low is it possible to adopt and implement the refrigerant: Refrigerant concentration after accidental release, such as during major collision scenarios. Air-conditioning (AC) system leak in engine compartment, e.g. abraded hose leak. Vehicle fire in engine compartment due to non-AC component failure. Vehicle fire due to vandalisms. Release during repair by professional service workers. ______ 25 Read-Only Versions of ASHRAE Standards Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 34 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Figure 3-6 Simplified example Fault Tree, where all events need to occur for event to occur. Over the last decade the refrigerant industry has examined hundreds of reports and commissioned a multitude of tests, with collaborative research programs initiated into the viability of alternatives. One such program is the $6 million program jointly funded by the US Department of Energy, ASHRAE, AirConditioning, Heating and Refrigeration Institute (AHRI), and California Air Resources Board (CARB) which investigates how flammable refrigerants might ignite and how they burn if released.26 As yet, no non-PFAS alternatives for non-road equipment have been identified. As detailed above, the design of refrigeration systems is lengthy and technically challenging due to the need to meet stringent safety requirements. Therefore, the continued access to these substances will be required for a long period as is recognised under the EU Fluorinated Greenhouse Gases Regulation. 3.9 Fabrics Fabrics are used in two main areas within non-road equipment, coverings for parts exposed to the operator such as seats, and as sound and vibration attenuation parts in the cabin and engine block to limit the amount of noise and vibration. 3.9.1 Fabrics in Operator Interacting Parts PFAS are used as coatings in non-road equipment to provide the following properties: Flame retardancy to prevent or delay the spread of fire. Most fabrics are highly flammable and represent a potential safety risk to the operator unless they are treated with flame retardants. Fabrics used in non-road applications are designed to meet several safety standards such as ISO 3795 and FMVSS 302. The use of such standards help reduce deaths and injuries to occupants caused by ______ 26 AHRI Flammable Refrigerants Research Initiative | AHRI (ahrinet.org) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 35 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members vehicle fires, especially those originating in the interior of the vehicle. Currently only PFAS based coatings are able to offer the necessary technical performance requirements. Stain, oil, and water resistance for fabrics which helps provide wear resistance and extended the useful life of the component. 3.9.2 Fabrics for Sound and Vibration Attenuation A variety of variables contribute to the interior noise of a vehicle which can be structure-borne or airborne sound. Acoustic textiles are used to control the noise and vibration in vehicles, and must provide airborne transmission reduction, damping, and sound absorption. Although interior noise lowers the comfort of using the vehicle, it also has impacts on safety as it can induce fatigue and limit the ability of the operator of the vehicle to communicate with others. Sources of noise and vibration are found inside and outside of the vehicle and examples include: Cooling Fans Fluid Routing Lines Road Noise and Wind Transmission Brakes Actuators Panel Holes Alternator Mounting Brackets PFAS are used to make non-road equipment sonically tolerable, but they also need to be flame resistant. 3.10 Alternative Power Systems The transition to decarbonise society is an important policy goal for a variety of governments around the world, including the EU. Non-road equipment manufacturers are investigating alternative power sources and technology solutions to reduce the greenhouse gas emissions of their products. PFAS will play a critical role in many of these technology developments, with batteries and hydrogen fuel cells being prominent examples. Batteries are present in many non-road products: Portable and industrial batteries, which includes battery packages consisting of battery cell, electronic components, cables, housing, displays, etc. Alternative power trains. Stationary energy storage systems. In most cases, OEMs produce battery packages but do not produce battery cells. For this reason AEM, and its member companies, support the submissions by EUROBAT and RECHARGE which outline the technical details on the essential use of PFAS substances in battery applications. AEM would like to take this opportunity to highlight the need for additional time beyond the request of the battery industry to implement PFAS-free batteries in their equipment. Equipment manufacturers need adequate time to design, test, certify and qualify their powertrain and equipment level systems to function with newer battery product offerings. These testing and certification cycles are estimated to take an additional 2 to 3 years after PFAS-free batteries are developed and become available commercially. This time is needed to perform a number of safety, performance, and qualification tests such as water repellency, durability, and the ability to operate at worksite environmental temperatures (-20 to 60C). Once the battery packs are qualified, OEMs need further design and test time to integrate PFAS-free batteries into current machine designs. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 36 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 3.11 Production Facilities PFAS also provide critical functionality to the production of AEM equipment, such as: Fluoropolymers aid in assembly and ensure critical system connections. Greases and lubricants in production equipment to ensure the safe functioning and safety of equipment. Mould releasers for moulded parts. 4 QUALIFICATION REQUIREMENTS For most PFAS, there are no currently known technical alternatives available for use in non-road equipment that does not compromise the safety, durability, or reliability of the finished product. AEM members produce equipment designed to consensus safety standards and subject to third party certifications, customer requirements, and regulatory testing obligations. Changes to materials and formulations which affect fit, form, function, performance, or safety must undergo extensive testing to ensure any new designs meet internal quality benchmarks, design specifications, and regulatory requirements. Due to the challenges outline in Section 2.1 it is extremely difficult to estimate the time needed to identify, test, and qualify alternative chemical substances for each end use. These estimates are based on the following assumptions: Suitable and viable technical alternative materials exist (although as described above, there are no known technical alternatives known for most PFAS use cases). Manufacturers do not encounter dead ends during these assessments, and suitable characteristics are identified the first time test are completed. Current supply chain issues throughout the world do not hamper shipping and transportation timelines. The total number of PFAS substances used in non-road equipment is a manageable size. Manufacturers will try to conduct simultaneous redesign work wherever possible, but they cannot implement changes across all product lines simultaneously as test cells, qualified staff, and other resources are all limited. The higher the number of PFAS substances used in the components and systems of the end-product, the longer the timeline will be. Resource Limitations Any transition away from PFAS will require significant time and resources to simply identify and qualify any PFAS-free material for use in the non-road equipment sector. AEM's member companies estimate that this effort would require a complete re-direction of all engineering resources within each member company to accomplish this task alone. Global engineering resources are extremely limited, with almost all companies facing severe staffing and human resource challenges. As such, non-road equipment manufacturers will need significant additional resources and time to address the qualification requirements for PFAS-free components, due to the fact that any individual company is highly unlikely to have the resources on hand to accomplish this task. This type of activity will impact all other R&D projects and other internal development programmes. It is likely that all these activities would pause in order to focus enough resource on PFAS qualification activities. If no derogation were to be granted, it Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 37 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members is highly likely that all product sales, manufacturing activities, and service actions for the EU would stop until suitable alternatives are identified, tested, designed, and qualified. Qualification Requirements Non-road equipment operates in some of the most demanding and severe environments over a product life cycle measured in decades. The equipment is a highly complex piece of machinery requiring each manufacturer to undertake component and system level qualifications to ensure the necessary performance characteristics are met. Due to this, AEM member companies estimate that at least 20 years from the date at which an alternative has been identified would be required to ensure proper performance of the machine, safety of the operator, maintenance personnel and the environment, as outlined in Table 4-1. Table 4-1 Minimum steps and time to be considered to test and recertify a PFAS-free material in non-road equipment after viable alternatives are identified. Activity Investigate alternative material Procure prototype materials Production Part Approval Process to ensure supplier is able to meet the appropriate quality and quantity requirements for the manufactured product Component validation of new material including: Various fire safety and flammability regulatory requirements27,28,29,30 set by a variety of domestic and international regulatory agencies. Safety, durability, and performance tests31,32 to ensure their products meet industry standards, internal quality specifications, as well as customer and regulatory requirements Timeline for Equipment Manufacturing Industry 15 Months 12 Months 48-120 Months Between 12 Months to 36 Months per component being changed, depending on the type of component. (excluding any time required to update standards or regulations) Up to 15 years of component validation within one equipment manufacturer Product validation with new material components including representative life testing which need to reflect product lifetimes of up to 40 years and 24 hour operation. ATEX certification (if required) 24 Months per machine validation 15+ years when all products within an equipment manufacturer are all tested 6-36 Months ______ 27 Flammability Test for Motor Vehicle Interiors, 49 C.F.R.571.302(1998). 28 Fire Protection and Prevention, 29 C.F.R 1926.24(2000), Fire Prevention, 29 C.F.R 1926.151(2001). 29 Fire Resistant Hydraulic Fluids, 30 C.F.R 35(2012), Requirements for the Approval of Flame-Resistant Conveyor Belts, 20 C.F.R 14(2008), Fire Protection 30 C.F.R 75.1100, Fire Protection, 30 C.F.R 77.1100, Fire suppression systems for dieselpowered equipment and fuel transportation units, 30 C.F.R 75.1911. 30Recommended Fire Safety Practices for Rail Transit Materials Selection, U.S. Department of Transportation, https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/NASFM_Recommended_Practices.pdf, 2008. 31 49 CFR 216, 223, 229, 231, 232, 238 - Passenger Equipment Safety Standards. 32 Flammable Fabrics Act, Public Law 83-88; 67 Stat. 111, June 30, 1953. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 38 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Activity Emissions re-qualification as outlined in Section 4.4. Timeline for Equipment Manufacturing Industry 18-24 months (without full engine redesign and recertification33) Up to 8 years (for full recertification) Administrative changes including part number changes, replacement instruction changes and associated documentation Turn inventory to purge supply chain and ensure compliance Total Up to 3 years 12 Months 20-25+ years once viable technical alternative has been identified 4.1 Standards Development Product safety and performance are key considerations for the non-road equipment industry. One of the primary methods the industry uses to ensure safe products, is the development and use of international voluntary consensus safety standards. Standards help maintain a necessary level of quality, performance, safety, durability, and reliability across products, machine forms and the industry at large. Standards are accepted practice across the world, with the EU playing a leading role in encouraging the development and implementation of standards to ensure consumers, users and operators are safe. For the non-road equipment industry, the EU has promulgated several safety and performance regulations that impact our industry (ATEX, F-Gas, EMC, etc.). One of the principal regulations that the industry follows is the Machinery Regulation 2023/1230/EU, which helps promote and ensure the safe design of non-road mobile machines. The way the Machinery Regulation, among other regulations, operates is through the adoption and use of harmonised standards intended to create industry wide safety standards for machines. The harmonised standards list contains hundreds of CEN standards intended for use by manufacturers in their design processes to help them meeting the requirements of the Machinery Regulation's objectives. The CEN standards in the Machinery Regulation are key guideposts for industry but are not the only standards used by OEMs. Appendix A outlines a small sample size of relevant standards (including many that are included in the Machinery Regulation) that have been adopted by industry to mitigate safety and performance risks of non-road equipment. Most ISO standards are built on the foundation of early equipment design that goes back into the 1950's and 1960's. Each of these standards are periodically updated every five years and can take anywhere from 3-5 years to complete a full review. Overall, the entire structure of the non-road equipment industry's safety and performance design philosophy is nearly a century old, and impossible to replicate and radically change quickly, which would be required if the PFAS restrictions enter into force without the derogations requested in this document. These standards, among hundreds not included in Appendix A, have all been developed with PFAS as an integral component of non-road equipment. If the non-road equipment industry loses access to PFAS through regulatory restrictions, each of these standards will need to be thoroughly re-evaluated, as many of the base assumptions that underpin the entire structure of non-road equipment standards will be radically altered. Not only will certain standards need to be reassessed to account for potential PFAS alternatives, but certain systems requiring radical redesign concepts will need wholly new standards to account for the severity of change to the overall product design. ______ 33 Assuming relevant availability of the testing facilities. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 39 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members The large number of standards currently in use by industry, the limited engineering resources available to review and develop new standards, the time requirements of the standards process itself, the many unknowns around any PFAS alternatives, and the process to revamp the entire non-road equipment standards foundation would take decades to complete. During this timeframe, the industry would be hampered in their efforts to mitigate safety and performance risks, unable to comply with most current EU regulations, or meet many of the current policy goals of EU decisionmakers. 4.2 Component Validation Testing Component validation testing needs to determine if a specific component meets the same functionality requirements. Testing can include a combination of the following parameters: Mechanical properties specific to the end application, such as gravel bombardment testing for exhaust system components, flow velocity Vibration Humidity Thermal cycling Chemical compatibility Flammability testing Stress fracture testing Water intrusion testing/ Immersion testing Thermal Shock: extreme temperature swings are used to stress the assembly Corrosion / Salt fog testing It is essential that all performance characteristics are properly vetted which can take considerable time and effort. For example, if the manufacturer needed to change the thickness of steel in the supporting components of the hydraulic system to support a PFAS-free elastomers (e.g. hoses or O-rings, supposing that PFAS-free substitutes could be found) the natural frequencies of all of the fasteners would need to be re-assessed. Furthermore, the product designers need to introduce new metal shapes to achieve the existing ergonomic performance properties of the machine. Other considerations may include the impact of new materials on the overall weight, vibration, noise, and energy use of the machine. The sheer number of design considerations make validation testing a resource and time intensive project, but one that ensures machines are designed to accommodate all safety, comfort, and performance requirements for the product. 4.3 Product Validation Testing Product validation testing needs to evaluate the reliability and durability of the substitute materials/components relative to their specific design requirements. This testing needs to be undertaken by each equipment manufacturer for each equipment type to ensure the testing reflects the demands of their application and the tolerances that are built into each system. Due to the operational requirements of non-road equipment, as outlined in Section 3, the testing to replicate all reasonably foreseeable operational conditions is time consuming. Depending on the end use application of the equipment, specific standards are used for testing purposes, where equipment must meet or exceed the requirements outlined within the standards. AEM member companies gathered a list of the highest priority ISO standards, identifying a total of 601 different technical standards which would be expected to be reassessed with any potential PFAS component changes. Depending on the end sector of the product there are varying numbers of standards, as outlined in Figure 4-1. A full list of the standards considered is outlined in Appendix A. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 40 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 34 105 Industrial trucks 57 189 Earth moving Tractors and machinary Elevated working platforms 8 Mining Cranes 208 Figure 4-1 Number of standards in different product end sectors potentially affected by PFAS. Each test can take a considerable length of time, in many cases lasting up to 6 months to complete, with an additional length of time needed for the set-up of the testing rigs. In many cases, these tests require the use of specially qualified employees, introducing potential bottlenecks and added costs to the design process. Depending on the end use of the equipment there are also a significant number of additional tests to ensure the overall functionality of non-road equipment. For example, crane equipment as shown in Figure 4-2, undergoes boom cycle testing which is required to validate the expected design life of the machine. The test requires up to 5 months to complete as it tests and validates multiple zones of lifting, with each zone requiring up to 10,000+ cycles of loading to ensure the structural integration of the system, as well as the wear and performance of internal components. It is typical that only one such test rig is owned by each equipment manufacturer, with each OEM manufacturing up to one hundred unique products. The models can be broken down into smaller groups, however due to the diverse nature of the product ranges it is estimated that retesting all the equipment for a single manufacturer would require around fifty tests and take a cumulative test time of over 20 years to finalise. Similar product specific testing would also be required for counterweights of systems, outriggers, swivels, jibs, and lifts (among many other types of machines and systems). All of which require product specific testing, each taking around 3 to 6 months per test. Most manufacturers will have at least five different groups of products, each requiring years of testing per manufacturer. Due to these various testing requirements, the non-road industry suffers from a variety of potential testing and validation bottlenecks that hinder quick product redesigns. This attribute is necessary to ensure products perform their functions safely but leads to an overall industry timeline of around 15 years or longer just to test a final product design. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 41 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Figure 4-2 Crane boom testing. 4.4 Emissions Any components which have the potential to affect the emissions of the equipment, such as sensors, need to undergo extensive in-house and third-party certification testing before the product can satisfy the current regulatory requirements governing its safety and performance. For example, in the EU, Regulation (EU) 2016/1628EN on requirements relating to gaseous and particulate pollutant emission limits and type-approval for internal combustion engines for non-road mobile machinery and the US Environmental Protection Agency (EPA), as part of their General Compliance Provisions for Highway, Stationary, and Nonroad Programs, identifies emission-related components in Appendix I to Part 1068. Changes to these critical components and systems require engine manufacturers to conduct a battery of emissions tests to ensure the equipment still meet emission standards. The details of these tests are outlined in detail in Section 5.1.2 with the emissions qualification process, taking between 11 and 14 years depending on the engine power band. 5 ENVIRONMENTAL IMPACT, END OF LIFE AND WASTE CONSIDERATIONS AEM member companies are downstream users of PFAS substances. As users there are no expected emissions of PFAS during the manufacturing process. The PFAS used within non-road equipment are generally located in areas with no user access, and if parts are accessed for maintenance purposes all users would be wearing personal protective equipment making the risk of exposure negligible. During the lifetime of an engine, it is possible that PFAS containing components may experience wear and damage from the operation of the product. These PFAS containing components would be collected in the engine oil which is handled and disposed of per EU legal requirements. Moreover, there are studies investigating the decomposition of PFAS substances during waste incineration processes. A Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 42 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members noticeable example is the complete thermal decomposition of PTFE at temperatures above 800C resulting in safe incineration in municipal waste incineration facilities.34 5.1 Environmental Considerations The non-road equipment industry continues to develop new strategies and solutions to reduce its environmental footprint. 5.1.1 Decarbonisation Strategies and Technologies As policymakers focus on mitigating the impact of climate change and deal with the availability and price increases of oil, the non-road equipment industry is working diligently on new decarbonisation strategies and technologies to introduce to the marketplace. Some of these technologies include: Refrigerants: Refrigerants and refrigerant systems are already highly regulated for their contribution to atmospheric ozone depletion, and their global warming potential. HFO-1234yf is commonly used in the automotive sector due to its zero ODP, and greatly reduced GWP (of 435) when compared to its immediate predecessor, HFC-134a. Alternative Power: Regulatory bodies have a decades long history of looking at on-road and nonroad engines to address air quality criteria pollutant concerns. With a growing focus on climate change, policymakers are also looking at engines to help address concerns over greenhouse gas emissions. Manufacturers will need to develop new low carbon powertrain technology solutions to achieve the criteria pollutant and greenhouse gas reduction levels set by regulators. Within the nonroad sector, manufacturers are researching new alternative power technologies, such as lithium-ion batteries, hydrogen fuel cells, and alternative fuels to provide low carbon solutions to their customers and markets they serve. The market share of alternative power sourced automotives is increasing to meet this demand, as shown in Figure 5-1, however a higher market share will need to be achieved to meet the overall emissions goals. PFAS provides the functional characteristics required to help foster the maturity and adoption of these new technologies across the market. Without PFAS, none of these technologies will remain viable and the necessary future developments will be unable to be undertaken. ______ 34Aleksando, K., Gehrmann, H-J., Hauser, M., Matzing, H., Pigeon, D., Stapf, D., Wexler, M. (2019). Waste incineration of Polytetrafluoroethylene (PTFE) to evaluate potential formation of per- and Poly-Fluorinated Alkyl Substances (PFAS) in flue gas - ScienceDirect 35 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014R0517 Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 43 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Figure 5-1 Production share of alternative power source vehicles.14 5.1.2 Engine Emissions One of the most impactful environmental concerns for products with internal combustion engines are engine emissions. Engine emissions normally fall into two different categories of concern for policymakers, criteria pollutants, and greenhouse gas emissions. The non-road equipment industry has a decades long history of technology development and adoption to mitigate the hazards associated with criteria pollutants. Figure 5-1 below demonstrates timing, NOx reductions and percent change over the last quarter century. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 44 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Figure 5-2 Emissions evolution over time.10 Several of the technologies used to meet engine emission rules rely upon PFAS, without which the ability to treat engine emissions will be much more difficult, if not completely impossible to achieve. Not only are PFAS critical to the function of the engine as well as the aftertreatment systems, but the components containing PFAS require full recertification with various regulatory bodies if the form, fit or function of the part is changed in a material way. Any PFAS alternatives, or design changes to accommodate the new materials, would require a full manufacturer recertification activity. Based on the current understanding of the engine, its components, and the role that PFAS plays in almost all current engine technologies, replacing PFAS would require a full engine redesign and recertification. Engine redesigns and recertifications are major undertaking both from a manufacturer and a regulatory perspective. Figure 5-3 shows an average engine development and equipment manufacturer transition from the publication of the last emissions rule (Tier 4) to the establishment of the final effective date, (Tier 4 Final). The example below shows the U.S. EPA timeline, but the U.S. and EU mirrored each other closely making US Tier 4 and EU Stage 4 very similar in timing and implementation. Tier 4 Reg USA (EPA) Nonroad Emissions Standards Tier 4 provided 13.5 years of total Lead Time for equipment OEMs P < 19 2000 19 P < 37 37 P#1 < 56 56 P < 75 75 P < 130 130 P < 225 225 P < 450 450 P 560 560 < P 2001 2002 2003 2004 2005 2006 2007 3.5 Year Lead Time 2008 2009 2010 2011 2012 % of production Flex 2013 2014 2015 2016 2017 8 Years Lead Time % of production Flex 7 Years Lead Time % of production Flex 6 Years Lead Time 6 Years Lead Time Equipment manufacturers utililized TPEM until 2018 Equipment manufacturers utililized TPEM until 2018 2018 2019 2020 2021 Tier 1 Tier 2 Tier 3 Tier 4 Interim Tier 4 Final Figure 5-3 Estimated engine redevelopment timeline following updated emissions requirements. It is important to note that under all engine emissions rules, (i.e., EU, US, Canada) there is a significant gap between certifying a new engine and the introduction of this certified engines into the marketplace. Once an engine manufacturer completes their design and verifies with the European Commission that the engine meets their emissions standards, the equipment manufacturer needs years of development time after this (known as flex time) to ensure the packaging of the equipment can accommodate and fit Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 45 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members the new engine. This is done because in almost all instances the engine manufacturer will need to make drastic overhauls of the entire design, making it incompatible for use in current equipment machine forms. The entire emissions qualification process, as shown in Figure 5-3 above, can take between 11 and 14 years depending on the engine power band. If PFAS is removed from the market due to regulatory restrictions, engine manufacturers will need to perform a complete engine redesign, beyond any type of normal emissions redesign work. PFAS is integral to the function of all seals, gaskets, O-rings, pistons, engine oils, and other fluids found in the engine, not to mention all the electronic controls and wiring systems. As stated, many times in this paper, the redesign efforts will take decades to complete, and in the meantime would endanger all modern engine emissions policy work and technology deployment put in place over the last several decades. 5.2 End-of-Life Considerations Owing to the significant retained value, durability, and cost of non-road equipment, most OEMs utilise robust remanufacturing operations to recycle, rebuild and reintroduce their equipment back into the market following its initial life cycle. For this reason, most of the equipment in the market today will not find its way into a municipal solid waste facility. Remanufactured equipment will undergo rebuilds, refurbishments, and reintroduction into secondary and tertiary markets for decades of continued use. For this reason, the total quantity of potential PFAS contamination from non-road component parts is negligible. It is critical that any restriction permits the use of spares, repairs, and remanufacturing efforts as otherwise this will contradict the EU's long term objectives of reducing waste materials, increasing recycling, and developing robust circular economy principles throughout industry. 5.2.1 Impact of PFAS-free Components on Waste Preserving the useful life of components such as hoses, seals, gaskets, coatings, and electrical components ensures the machine continues to operate for an extended period of time under severe conditions. Without the use of PFAS, machinery in the field will prematurely fail requiring an accelerated need for new parts and components, thus increasing the generation of waste. It is estimated that PFAScomponents have a decrease in useful life of 90%. In addition, this causes safety issues due to increased failure rates and fluid leaks. The impact on waste is significant and can be broadly characterised by two types of replacement schemes: 1. Direct replacement of the affected component. 2. Replacement of subsystem containing the affected component as the component is not able to be replaced without affecting the subsystem. It should also be noted that for the vast majority of PFAS uses there are no potential alternatives even when significant impacts to technical performance are considered. Considering that the operational environment of non-road equipment includes applications such as mines, it is not possible to eliminate external environmental contamination (i.e., dirt, dust, water) when systems are maintained or repaired. As such, for both strategies the replacement of items within nonroad equipment presents the opportunity to introduce contamination into the system. Non-road equipment is characterised by its high tolerances and high efficiency parts, so each instance of potential contamination increases the risk of damage to the overall equipment. This will ultimately result in more replacement and maintenance activities, higher rates of machine obsolescence, an increase in waste, Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 46 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members increased energy use and the degradation of the machines' safety and environmental systems. Overall, these activities will threaten the EUs waste and circular economy goals. Sub-system replacement Due to the lack of engineering data on potential PFAS alternatives, the impacts of a component failure are impossible to quantify at this stage. However, there are known component failures which could risk the viability and continued functionality of the larger sub-system: Hose failure resulting in the replacement of a hydraulic fluid system. As one study cites36, hydraulic hoses, O-rings (within the hydraulic systems), and hydraulic hose couplings represent 50% of the specific fluid spills from earthmoving plant and equipment. One of the leading causes of the failures was that the design did not anticipate conditions, which highlights the importance of the components ability to withstand the harsh conditions which currently only PFAS materials are able to withstand. A similar situation is expected for systems such as the air-conditioning system, coolant system, engine after-treatment and drive train system. Break line failure resulting in the replacement of the breaking/steering system. One such example of this, is the instance where the testing of Ford break lines (in cars) were undertaken only up to 88% of the expected performance and as such 1.3 million cars had to be recalled due to the safety concerns37. Given that certain PFAS-free alternatives have significant performance issues when compared to current systems that use PFAS containing components, the industry expects to see a much higher rate of sub-system replacements in the future, assuming the non-road industry does not receive a derogation as requested in this document. This issue highlights the importance of using components that meet the necessary technical and performance specifications currently required by the non-road market. Engine oil within pistons resulting in the replacement of the entire engine. In addition to this, there are also instances where not all parts can be directly replaced as it can affect the warranty of a sub-system and as such entire sub-systems require replacement which has a significant impact on the amount of waste produced in such instances. 6 PROPOSED DEROGATION UTILISED BY AEM MEMBERS Due to the critical PFAS uses within non-road equipment a suitable length of time to identify, develop and qualify PFAS-free alternatives where possible, is necessary. AEM member companies highlight the need for the following derogations, with points of alternation highlighted in bold: - 6o: Applications affecting the proper functioning related to the safety, reliability and durability of transport vehicles, non-road equipment, Internal Combustion Engine systems and Alternative ______ 36 Turlough Guerin, Root causes of fluid spills from earthmoving plant and equipment: Implications for reducing environmental and safety impacts, Engineering Failure Analysis, Volume 45, 2014, Pages 128-141, ISSN 1350-6307. 3737 Ford Recalls 1.3 Million Cars over Faulty Brake Hoses (autoweek.com) Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 47 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Powertrain systems, and affecting the safety of humans or reliability of equipment until 20 years after EiF. - A derogation to include batteries, permitting systems level qualification taking up to 3 years after PFAS-free batteries are developed and become available commercially. - 5u: textiles for the use in engine bays for noise and vibration insulation used in the automotive industry until 13.5 years after EiF. - 5s: lubricants where the use takes place under harsh conditions, or the use is needed for safe functioning and safety of equipment until 13.5 years after EiF. - 5p refrigerants in mobile air conditioning-systems in combustion engine vehicles with mechanical compressors until 20 years after EiF - Non-road equipment has long lifespans and therefore without a derogation which permits the time unlimited manufacture and use of spares, repairs, and remanufacturing, will result in the early disposal of many products. - It is also important that there is a proportionate process to allow derogations to be extended if needed. By permitting these derogations this will allow manufacturers of non-road equipment to undertake the necessary qualification and validation activities to utilise PFAS-free alternatives wherever possible. Nonroad equipment, components and manufacturing processes are essential in achieving broad societal goal such as the EU Green Deal, with research aiming at reducing emissions and the development of alternative powertrains for alternative energy transitions, outlined in Section 5. Without PFAS these goals cannot be achieved. 6.1 Non-road Equipment The derogation 6o is suggested to be updated to include the following wording based on the following rationale: The addition of reliability of equipment to ensure operation of the equipment without early failures. Due to the criticality of non-road equipment premature failure would cause severe repercussions on operation activities and would result in an increase in waste produced. Alter the scope from `transport vehicles' to non-road equipment, internal combustion engines systems and alternative powertrain systems, due to the similarity in the technical requirements of each of these product types. Furthermore, given the extensive supply chain overlap between the non-road equipment industry and the on-road industry, this would also ensure that essential components used within throughout industry are covered under this derogation, helping ensure the reliability of the system against future failures. Original wording included `affecting safety of operators, passengers or goods' which would limit safety considerations to specialised personnel and vehicles passengers. The safety concerns need to be expanded to the general public and to all engine applications beyond vehicles to include operators, technicians, passengers, or people in the vicinity of the operations. Derogation timeline Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 48 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Due to the need for considerable testing and recertification, as outlined in Section 4, the derogation is required for at least 20 years. The derogation timeline needs to start when a viable technical alternative has been identified and is commercially available. Given the wide variety of technologies, systems, and equipment types in the non-road industry, as well as the tremendous amount of uncertainty surrounding identifying and implementing PFAS-free alternatives, it is essential that the derogation can be adapted to reflect new scientific discoveries as outlined in Section 6.5. It is worthwhile highlighting that previous information provided by AEM member companies indicated that 13.5 years would be suitable, however after further investigations by AEM member companies into the applications PFAS is utilised in and the qualification requirements, this was deemed to be too short. 6.2 Refrigerants in Mobile Air Conditioning-systems Given the envisaged timeline to qualify alternative refrigerants, it is also highlighted that derogation 5p refrigerants in mobile air conditioning-systems in combustion engine vehicles with mechanical compressors needs to be permitted until 20 years after EiF. 6.3 Batteries Batteries play an important role for AEM member companies as they are integrated into non-road equipment to provide auxiliary power sources. Batteries have a key role in the aim to achieve electrification and net zero emissions in a number of industries. AEM member companies support the submissions by EUROBAT and RECHARGE which outline the technical details on the essential use of PFAS substances in battery applications. It is important to note that once battery manufacturers are able to qualify PFAS-free alternatives, AEM member companies will need to undertake systems level qualification taking up to 3 years after PFAS-free batteries are commercially available. It is essential that any derogation permits the necessary time to permit these activities to be undertaken. 6.4 Spares, Repairs and Remanufacturing It is important to note that PFAS are not only needed to manufacture new technologies and products but also for servicing and maintaining existing equipment already placed on the market. Non-road equipment generally has a long service life with devices having lifespans of up to 40 years. In many applications there will not be drop-in replacements for PFAS-free components on a 1:1 basis. Systems will need to be redesigned to permit the use of PFAS-free alternatives, which will impact the ability of users to maintenance and repair machines currently in-use. Without the general consideration to permit the use of PFAS in existing applications, this will cause the premature end-of-life and scrap of various products and machines which otherwise could be serviced, repaired, and maintained with PFAScontaining parts and be kept in service for an extended period of time. The restriction, as proposed, would also affect already produced products subjected to remanufacturing and have an impact on the second hand machinery market. Service, maintenance, and repairs are crucial for the success of the European Green Deal when it comes to better resource efficiency and therefore it is important that this is reflected in the derogation request. Due to the long life of AEM's members' products, a permanent derogation for PFAS in replacement spare parts is needed. 6.5 Derogation Extension Process AEM member companies and their supply chain are actively engaged in gathering information on the uses of PFAS within their products, however as yet not all PFAS uses have been identified. AEM Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 49 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members member companies are reliant upon their suppliers in many cases identifying PFAS-free alternatives before they are then able to undertake systems level qualifications. Due to the early stages of their development there is a significant degree of uncertainty in estimating an accurate timeline and additional time may be required. Due to these factors it is essential that a formal process for requesting permitted derogations to be extended beyond the originally agreed time period is permitted and published. 7 SOCIO-ECONOMIC IMPACTS Without the derogations outlined in Section 6 the following economic impacts are expected by AEM member companies. 7.1 Economic Impact on the Industry Considering that AEM member companies have stated that 99.5% of their components would either be directly or indirectly affected by the PFAS restriction, without a derogation up to 74 billion38 of annual revenue would be lost from the EU. Additional revenue would also be lost from AEM member companies supply chains in the EU. As a result, the majority of product ranges currently offered no longer being supplied in the EU. Based on the current proposed restriction, without an appropriate derogation for the non-road equipment industry, it is highly likely, that all EU based manufacturing or assembly of non-road equipment will be moved outside of the union. This is based on the consideration that as yet there is no technical feasible alternative. 7.2 Cost of Qualification AEM member companies utilise PFAS for their unique properties, as outlined above, and potential alternatives must be evaluated on a case-by-case basis considering technical, regulatory, as well as economic aspects. For the purposes of this assessment, AEM assumes that the fundamental characteristics of the products are not changed and that an alternative is a viable solution. This is unlikely to be the case for all non-road applications, as PFAS in many instances do not have a known viable alternative, or these potential alternatives are at a very early stage in their development. In some cases, substitution may prove to be impossible so that the only option will be to withdraw the product from sale in the EU. Although the costs of alternative solutions are outlined in this section it is important to note that there are other factors for considerations, such as the indications outlined in Section 5.2, that the lifetime of certain products is expected to be dramatically reduced. Table 7-1 outlines expected incurred cost per member company associated with the qualification of potential PFAS-free alternatives. Table 7-1 Estimated costs of qualification of PFAS-free alternatives, assuming that viable alternatives are available. Component Type Estimated cost of qualification for component/subsystem () per AEM member company Sealant 5K ______ 38 Based on the consideration that AEM member companies have an annual revenue of 74.4 billion in the EU. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 50 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Component Type O-ring or gasket Protective vent Self-lubricating bearing Hose All hydraulic systems in one AEM member company Product re-development Estimated cost of qualification for component/subsystem () per AEM member company 50-75K 100K 1M 2-6M depending on the viability of alternatives Up to 500M due to up to 300 models in one company. Costs associated with life cycle testing requiring up to 26 weeks of testing per system, recertification testing, retraining operators, tooling changes, training of field service technical and customers. >450M per product, with each manufacturer having a wide variety of products, each requiring specific testing. It should be noted that all of the above costs are estimates for the redesign of existing equipment, and the qualification costs for spare parts for products which rely upon PFAS already placed on the market would be in addition to those listed above. Due to the significant amount of testing spare parts would require, it is expected that these costs would also be significant. 7.3 Employment Effects The majority of AEM member companies would need to hire additional staff to adequately investigate potential alternatives due to the significant number of parts affected, with members indicating this could be up to 28 full time employees (FTE) per company. These additional employees would need a high degree of training and experience to process the qualification of PFAS-free alternatives in non-road equipment. There is already industry recognition in the automotive sector, of a significant skills shortage and finding appropriately experienced and qualified staff is challenging. This concern is shared by AEM member companies with the majority of the members raising concerns on the unlikeliness of finding suitable personnel to be able to adequately resource the qualification of PFAS-free alternatives. It is expected that in order to properly evaluate and validate new alternative PFAS materials, all current R&D activities would need to stop, impacting the development of new innovations for the non-road equipment industry. In many cases, the loss of PFAS, the unavailability of PFAS-free alternatives, and the prohibition on selling or manufacturing PFAS containing products into the EU market will result in the movement of manufacturing activities away from the EU for the non-road sector (for non-EU customers). Resulting in significant losses of EU manufacturing activity. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 51 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members 7.4 Impact on End-Users EU users of non-road machinery will not be able to obtain (buy, lease, etc.) new or second-hand equipment or service or repair existing equipment and this will increasingly affect many EU industries, especially construction, mining, and utilities. These industries will not be able to operate resulting in a significant loss to the EU's GDP of many billions per year and large numbers of job losses in these industries. There will also be safety impacts if this equipment is not available or cannot be repaired, such as if a hospital cannot repair or replace an emergency generator. Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 52 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Appendix A- Standards Potentially Affected by PFAS These standards, among hundreds not included in this list, have all been developed with PFAS as an integral component of non-road equipment. Each of these standards will need to be thoroughly reevaluated for non-PFAS components as many of the base assumptions that underpin the entire structure of non-road equipment standards will be radically altered. Table 7-2 Standards identified in various end sectors which may be potentially impacted by PFAS component changes. Name ISO 10262:1998 (R2009) ISO 10264:1990 (R2018) ISO 10265:2008 (R2013) ISO 10266:1992 ISO 10268:1993 (R2016) ISO 10532:1995 (R2016) ISO 10533:1993 (R2008) ISO 10968:2020 ISO 5006:2017 ISO 15818:2017 ISO 17253:2014 ISO 204741:2017 ISO 13459:2012 ISO 204745:2017 ISO 2047413:2017 Title Earth-moving machinery - hydraulic excavators - laboratory tests and performance requirements for operator protective guards Earth-moving machinery - key-locked starting systems Earth-moving machinery - crawler machines - performance requirements and test procedures for braking systems Earth-moving machinery -- Determination of slope limits for machine fluid systems operation -- Static test method Earth moving machinery - retarders for dumpers and tractor-scrapers performance tests Earth-moving machinery - machine-mounted retrieval device performance requirements Earth-moving machinery - lift-arm support devices Earth-moving machinery -- Operator's controls Earth-moving machinery -- Operator's field of view -- Test method and performance criteria Earth-moving machinery -- Lifting and tying-down attachment points -- Performance requirements Earth-moving machinery and rough-terrain variable-reach trucks -- Design requirements for machines intended to be driven on road Earth-moving machinery -- Safety -- Part 1: General requirements Earth-moving machinery -- Trainer seat -- Deflection limiting volume, space envelope and performance requirements Earth-moving machinery -- Safety -- Part 5: Requirements for hydraulic excavators Earth-moving machinery -- Safety -- Part 13: Requirements for rollers Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 53 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 2047412:2017 GB/T 199331:2014 GB/T 199332:2014 GB/T 199333:2014 ISO 2047411:2017 GB/T 199334:2014 GB/T 199335:2014 GB/T 199336:2014 ISO 22448:2010 GB/T 19929:2014 ISO 204747:2017 ISO 204746:2017 GB/T 17920:1999 ISO 10262:1998 ISO 102632:2009 ISO 102633:2009 ISO 102634:2009 ISO 10264:1990 ISO 10265:2008 Title Earth-moving machinery -- Safety -- Part 12: Requirements for cable excavators Earth-Moving Machinery - Operator enclosure environment - part 1: terms and definitions Earth-moving machinery. Operator enclosure environment. Part 2: Air filter element test method Earth-moving machinery. Operator enclosure environment. Part 3: Pressurization test method Earth-moving machinery -- Safety -- Part 11: Requirements for landfill compactors Earth-moving machinery. Operator enclosure environment. Part 4: Heating, ventilation, and air conditioning (HVAC) test method and performance Earth-moving machinery. Operator enclosure environment. Part 5: Windscreen defrosting system test method Earth-moving machinery. Operator enclosure environment. Part 6: Determination of effect of solar heating Earth-moving machinery -- Anti-theft systems -- Classification and performance Earth-moving machinery. Crawler machines. Performance requirements and test procedures for braking systems Earth-moving machinery -- Safety -- Part 7: Requirements for scrapers Earth-moving machinery -- Safety -- Part 6: Requirements for dumpers Earth-moving machinery. Lift-arm support devices Earth-moving machinery -- Hydraulic excavators -- Laboratory tests and performance requirements for operator protective guards Earth-moving machinery -- Operator enclosure environment -- Part 2: Air filter element test method Earth-moving machinery -- Operator enclosure environment -- Part 3: Pressurization test method Earth-moving machinery -- Operator enclosure environment -- Part 4: Heating, ventilating and air conditioning (HVAC) test method and performance Earth-moving machinery -- Key-locked starting systems Earth-moving machinery -- Crawler machines -- Performance requirements and test procedures for braking systems Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 54 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 10532:1995 ISO 10533:1993 ISO 10570:2004 ISO 11112:1995 ISO 11862:1993 ISO 12508:1994 ISO 12509:2004 ISO 13031:2016 ISO 13333:1994 ISO 6011:2003 ISO 6014:1986 ISO 6395:2008 ISO 6396:2008 ISO 6749:1984 ISO 143971:2007 ISO 6016:2008 ISO 7546:1983 ISO 7451:2007 ISO 9248:1992 Title Earth-moving machinery -- Machine-mounted retrieval device -- Performance requirements Earth-moving machinery -- Lift-arm support devices Earth-moving machinery -- Articulated frame lock -- Performance requirements Earth-moving machinery -- Operator's seat -- Dimensions and requirements Earth-moving machinery -- Auxiliary starting aid electrical connector Earth-moving machinery -- Operator station and maintenance areas -- Bluntness of edges Earth-moving machinery -- Lighting, signalling, and marking lights, and reflex-reflector devices Earth-moving machinery -- Quick couplers -- Safety Earth-moving machinery -- Dumper body support and operator's cab tilt support devices Earth-moving machinery -- Visual display of machine operation Earth-moving machinery -- Determination of ground speed Earth-moving machinery -- Determination of sound power level -- Dynamic test conditions Earth-moving machinery -- Determination of emission sound pressure level at operator's position -- Dynamic test conditions Earth-moving machinery -- Preservation and storage Earth-moving machinery -- Loaders and backhoe loaders -- Part 1: Calculation of rated operating capacity and test method for verifying calculated tipping load Earth-moving machinery -- Methods of measuring the masses of whole machines, their equipment, and components Earth-moving machinery -- Loader and front loading excavator buckets -- Volumetric ratings Earth-moving machinery -- Volumetric ratings for hoe-type and grab-type buckets of hydraulic excavators and backhoe loaders Earth-moving machinery -- Units for dimensions, performance and capacities, and their measurement accuracies Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 55 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 10567:2007 ISO 121172:2008 ISO 10268:1993 Earth-moving machinery -- Hydraulic excavators -- Lift capacity Earth-moving machinery -- Laboratory tests and performance requirements for protective structures of excavators -- Part 2: Roll-over protective structures (ROPS) for excavators of over 6 t Earth-moving machinery -- Retarders for dumpers and tractor-scrapers -- Performance tests ISO 6393:2008 Earth-moving machinery -- Determination of sound power level -- Stationary test conditions ISO 6394:2008 Earth-moving machinery -- Determination of emission sound pressure level at operator's position -- Stationary test conditions ISO 8813:1992 Earth-moving machinery -- Lift capacity of pipelayers and wheeled tractors or loaders equipped with side boom ISO 17063:2003 Earth-moving machinery -- Braking systems of pedestrian-controlled machines -- Performance requirements and test procedures ISO 15219:2004 ISO 11112:1995/ AMD 1:2001 ISO 15817:2012 Earth-moving machinery -- Cable excavators -- Terminology and commercial specifications Earth-moving machinery -- Operator's seat -- Dimensions and requirements -- Amendment 1 Earth-moving machinery -- Safety requirements for remote operator control systems ISO 21507:2010 Earth-moving machinery -- Performance requirements for non-metallic fuel tanks ISO 9533:2010 ISO 137661:2018 ISO 137662:2018 ISO 149901:2016 ISO 149902:2016 ISO 149903:2016 ISO 2860:1992 Earth-moving machinery -- Machine-mounted audible travel alarms and forward horns -- Test methods and performance criteria Earth-moving and building construction machinery -- Electromagnetic compatibility (EMC) of machines with internal electrical power supply -- Part 1: General EMC requirements under typical electromagnetic environmental conditions Earth-moving and building construction machinery -- Electromagnetic compatibility (EMC) of machines with internal electrical power supply -- Part 2: Additional EMC requirements for functional safety Earth-moving machinery -- Electrical safety of machines utilizing electric drives and related components and systems -- Part 1: General requirements Earth-moving machinery -- Electrical safety of machines utilizing electric drives and related components and systems -- Part 2: Particular requirements for externally-powered machines Earth-moving machinery -- Electrical safety of machines utilizing electric drives and related components and systems -- Part 3: Particular requirements for self-powered machines Earth-moving machinery -- Minimum access dimensions Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 56 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 2867:2011 ISO 3411:2007 ISO 3449:2005 ISO 3450:2011 ISO 3457:2003 ISO 3471:2008 ISO 64051:2017 ISO 64052:2017 ISO 6483:1980 ISO 6682:1986 ISO 6683:2005 ISO 7130:2013 ISO 8152:1984 ISO 9244:2008 ISO 5353:1995 ISO 67461:2003 ISO 12117:1997 ISO 102635:2009 ISO 144011:2009 Title Earth-moving machinery -- Access systems Earth-moving machinery -- Physical dimensions of operators and minimum operator space envelope Earth-moving machinery -- Falling-object protective structures -- Laboratory tests and performance requirements Earth-moving machinery -- Wheeled or high-speed rubber-tracked machines -- Performance requirements and test procedures for brake systems Earth-moving machinery -- Guards -- Definitions and requirements Earth-moving machinery -- Roll-over protective structures -- Laboratory tests and performance requirements Earth-moving machinery -- Symbols for operator controls and other displays -- Part 1: Common symbols Earth-moving machinery -- Symbols for operator controls and other displays -- Part 2: Symbols for specific machines, equipment, and accessories Earth-moving machinery -- Dumper bodies -- Volumetric rating Earth-moving machinery -- Zones of comfort and reach for controls Earth-moving machinery -- Seat belts and seat belt anchorages -- Performance requirements and tests Earth-moving machinery -- Operator training -- Content and methods Earth-moving machinery -- Operation and maintenance -- Training of mechanics Earth-moving machinery -- Machine safety labels -- General principles Earth-moving machinery, and tractors and machinery for agriculture and forestry -- Seat index point Earth-moving machinery -- Definitions of dimensions and codes -- Part 1: Base machine Earth-moving machinery -- Tip-over protection structure (TOPS) for compact excavators -- Laboratory tests and performance requirements Earth-moving machinery -- Operator enclosure environment -- Part 5: Windscreen defrosting system test method Earth-moving machinery -- Field of vision of surveillance and rear-view mirrors -- Part 1: Test methods Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 57 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 144012:2009 ISO 16001:2017 ISO 7135:2009 ISO 9249:2007 ISO 3164:2013 ISO 6015:2006 ISO 67462:2003 ISO 7457:1997 ISO 5010:2019 ISO 7096:2020 ISO 190141:2018 ISO 190144:2020 ISO 190143:2018 ISO 2047415:2019 ISO 24410:2020 ISO 16417:2020 ISO 10987:2012 ISO/TR 19948:2016 ISO 67501:2019 Title Earth-moving machinery -- Field of vision of surveillance and rear-view mirrors -- Part 2: Performance criteria Earth-moving machinery -- Object detection systems and visibility aids -- Performance requirements and tests Earth-moving machinery -- Hydraulic excavators -- Terminology and commercial specifications Earth-moving machinery -- Engine test code -- Net power Earth-moving machinery -- Laboratory evaluations of protective structures -- Specifications for deflection-limiting volume Earth-moving machinery -- Hydraulic excavators and backhoe loaders -- Methods of determining tool forces Earth-moving machinery -- Definitions of dimensions and codes -- Part 2: Equipment and attachments Earth-moving machinery -- Determination of turning dimensions of wheeled machines Earth-moving machinery -- Wheeled machines -- Steering requirements Earth-moving machinery -- Laboratory evaluation of operator seat vibration Earth-moving machinery -- Functional safety -- Part 1: Methodology to determine safety-related parts of the control system and performance requirements Earth-moving machinery -- Functional safety -- Part 4: Design and evaluation of software and data transmission for safety-related parts of the control system Earth-moving machinery -- Functional safety -- Part 3: Environmental performance and test requirements of electronic and electrical components used in safety-related parts of the control system Earth-moving machinery -- Safety -- Part 15: Requirements for compact tool carriers Earth-moving machinery -- Coupling of attachments to skid steer loaders Earth-moving machinery -- Hydraulic breakers -- Terminology and commercial specifications Earth-moving machinery -- Sustainability -- Terminology, sustainability factors and reporting Earth-moving machinery -- Conformity assessment and certification process Earth-moving machinery -- Operator's manual -- Part 1: Contents and format Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 58 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 45101:1987 ISO 45102:1996 ISO 6012:1997 ISO 6302:1993 ISO 63921:1996 ISO 63922:1996 ISO 64051:2017/AMD 1:2022 ISO 64052:2017/AMD 1:2022 ISO 7129:1997 ISO 7852:1983 ISO 8925:1989 ISO 8925:1989/ AMD 1:1997 ISO 8927:1991 ISO 9247:1990 ISO 9247:1990/ AMD 1:1998 ISO 10261:2021 ISO 12510:2004 ISO 12511:1997 ISO 12511:1997/ AMD 1:2021 Title Earth-moving machinery -- Service tools -- Part 1: Common maintenance and adjustment tools Earth-moving machinery -- Service tools -- Part 2: Mechanical pullers and pushers Earth-moving machinery -- Service instrumentation Earth-moving machinery -- Drain, fill, and level plugs Earth-moving machinery -- Lubrication fittings -- Part 1: Nipple type Earth-moving machinery -- Lubrication fittings -- Part 2: Grease-gun nozzles Earth-moving machinery -- Symbols for operator controls and other displays -- Part 1: Common symbols -- Amendment 1: Additional symbols Earth-moving machinery -- Symbols for operator controls and other displays -- Part 2: Symbols for specific machines, equipment, and accessories -- Amendment 1: Additional symbols ISO 7129:1997 Earth-moving machinery -- Plough bolt heads -- Shapes and dimensions (excluding thread dimensions) Earth-moving machinery -- Diagnostic ports Earth-moving machinery -- Diagnostic ports -- Amendment 1 Earth-moving machinery -- Machine availability -- Vocabulary Earth-moving machinery -- Electrical wires and cables -- Principles of identification and marking Earth-moving machinery -- Electrical wires and cables -- Principles of identification and marking -- Amendment 1 Earth-moving machinery -- Product identification numbering system Earth-moving machinery -- Operation and maintenance -- Maintainability guidelines Earth-moving machinery -- Hour meters Earth-moving machinery -- Hour meters -- Amendment 1 Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 59 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 151431:2010 Earth-moving machinery and mobile road construction machinery -- Worksite data exchange -- Part 1: System architecture ISO 151432:2010 ISO/TS 151433:2020 ISO 16714:2008 Earth-moving machinery and mobile road construction machinery -- Worksite data exchange -- Part 2: Data dictionary Earth-moving machinery and mobile road construction machinery -- Worksite data exchange -- Part 3: Telematics data Earth-moving machinery -- Recyclability and recoverability -- Terminology and calculation method ISO 23727:2009 ISO 6394:2008/ COR 1:2009 ISO 6396:2008/ COR 1:2009 ISO 6682:1986/ AMD 1:1989 ISO 9244:2008/ AMD 1:2016 ISO 10262:1998/ COR 1:2009 ISO 102631:2009 Earth-moving machinery -- Wheeled loader coupler for attachments Earth-moving machinery -- Determination of emission sound pressure level at operator's position -- Stationary test conditions -- Technical Corrigendum 1 Earth-moving machinery -- Determination of emission sound pressure level at operator's position -- Dynamic test conditions -- Technical Corrigendum 1 Earth-moving machinery -- Zones of comfort and reach for controls -- Amendment 1 Earth-moving machinery -- Machine safety labels -- General principles -- Amendment 1 Earth-moving machinery -- Hydraulic excavators -- Laboratory tests and performance requirements for operator protective guards -- Technical Corrigendum 1 Earth-moving machinery -- Operator enclosure environment -- Part 1: Terms and definitions ISO 102636:2009 ISO 10533:1993/ AMD 1:2005 ISO 121172:2008/AMD 1:2016 ISO 121172:2008/COR 1:2010 ISO 12117:1997/ COR 1:2000 ISO 17757:2019 ISO 190142:2022 Earth-moving machinery -- Operator enclosure environment -- Part 6: Determination of effect of solar heating Earth-moving machinery -- Lift-arm support devices -- Amendment 1 Earth-moving machinery -- Laboratory tests and performance requirements for protective structures of excavators -- Part 2: Roll-over protective structures (ROPS) for excavators of over 6 t -- Amendment 1 Earth-moving machinery -- Laboratory tests and performance requirements for protective structures of excavators -- Part 2: Roll-over protective structures (ROPS) for excavators of over 6 t -- Technical Corrigendum 1 Earth-moving machinery -- Tip-over protection structure (TOPS) for compact excavators -- Laboratory tests and performance requirements -- Technical Corrigendum 1 Earth-moving machinery and mining -- Autonomous and semiautonomous machine system safety Earth-moving machinery -- Functional safety -- Part 2: Design and evaluation of hardware and architecture requirements for safety-related parts of the control system Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 60 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO/TS 190145:2021 ISO 204742:2017 ISO 204743:2017 ISO 204744:2017 ISO 204748:2017 ISO 204749:2017 ISO 2047410:2017 ISO 218151:2022 ISO/TS 218152:2021 ISO/TR 25398:2006 ISO 5005:1977 ISO 6483:1980/ COR 1:1994 ISO 6484:1986 ISO 6485:1980 ISO 7464:1983 ISO 8643:2017 ISO 9246:1988 ISO 10532:1995/ AMD 1:2004 ISO 10532:1995/ AMD Title Earth-moving machinery -- Functional safety -- Part 5: Tables of performance levels Earth-moving machinery -- Safety -- Part 2: Requirements for dozers Earth-moving machinery -- Safety -- Part 3: Requirements for loaders Earth-moving machinery -- Safety -- Part 4: Requirements for backhoe loaders Earth-moving machinery -- Safety -- Part 8: Requirements for graders Earth-moving machinery -- Safety -- Part 9: Requirements for pipelayers Earth-moving machinery -- Safety -- Part 10: Requirements for trenchers Earth-moving machinery -- Collision warning and avoidance -- Part 1: General requirements Earth-moving machinery -- Collision warning and avoidance -- Part 2: On-board J1939 communication interface Earth-moving machinery -- Guidelines for assessment of exposure to whole-body vibration of ride-on machines -- Use of harmonized data measured by international institutes, organizations, and manufacturers Earth-moving machinery -- Method for locating the centre of gravity Earth-moving machinery -- Dumper bodies -- Volumetric rating -- Technical Corrigendum 1 Earth-moving machinery -- Elevating scrapers -- Volumetric ratings Earth-moving machinery -- Tractor-scraper -- Volumetric rating Earth-moving machinery -- Method of test for the measurement of drawbar pull Earth-moving machinery -- Hydraulic excavator and backhoe loader lowering control device -- Requirements and tests Earth-moving machinery -- Crawler and wheel tractor dozer blades -- Volumetric ratings Earth-moving machinery -- Machine-mounted retrieval device -- Performance requirements -- Amendment 1 ISO 10532:1995/AMD 1:2004/COR 1:2006 Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 61 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name 1:2004/COR 1:2006 ISO 10532:1995/ COR 1:2006 ISO 143971:2007/AMD 1:2019 ISO 143972:2007 ISO 16754:2008 ISO 67462:2003/COR 1:2004 ISO 6747:2013 ISO 7131:2009 ISO 7131:2009/ AMD 1:2017 ISO 7132:2003 ISO 7132:2003/ AMD 1:2018 ISO 7133:2013 ISO 7134:2013 ISO 7135:2009/ AMD 1:2019 ISO 7136:2006 ISO 8811:2000 ISO 8811:2000/ COR 1:2002 ISO 8812:2016 ISO 9245:1991 Title Earth-moving machinery -- Machine-mounted retrieval device -- Performance requirements -- Technical Corrigendum 1 Earth-moving machinery -- Loaders and backhoe loaders -- Part 1: Calculation of rated operating capacity and test method for verifying calculated tipping load -- Amendment 1 Earth-moving machinery -- Loaders and backhoe loaders -- Part 2: Test method for measuring breakout forces and lift capacity to maximum lift height Earth-moving machinery -- Determination of average ground contact pressure for crawler machines Earth-moving machinery -- Definitions of dimensions and codes -- Part 2: Equipment and attachments -- Technical Corrigendum 1 Earth-moving machinery -- Dozers -- Terminology and commercial specifications Earth-moving machinery -- Loaders -- Terminology and commercial specifications Earth-moving machinery -- Loaders -- Terminology and commercial specifications -- Amendment 1 Earth-moving machinery -- Dumpers -- Terminology and commercial specifications Earth-moving machinery -- Dumpers -- Terminology and commercial specifications -- Amendment 1 Earth-moving machinery -- Scrapers -- Terminology and commercial specifications Earth-moving machinery -- Graders -- Terminology and commercial specifications Earth-moving machinery -- Hydraulic excavators -- Terminology and commercial specifications -- Amendment 1 Earth-moving machinery -- Pipelayers -- Terminology and commercial specifications Earth-moving machinery -- Rollers and compactors -- Terminology and commercial specifications Earth-moving machinery -- Rollers and compactors -- Terminology and commercial specifications -- Technical Corrigendum 1 Earth-moving machinery -- Backhoe loaders -- Terminology and commercial specifications Earth-moving machinery -- Machine productivity -- Vocabulary, symbols, and units Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 62 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO/TS 92501:2012 ISO/TS 92502:2012 ISO 13539:1998 ISO/TR 67502:2022 ISO 6165:2022 ISO 12509:2023 EN ISO 251191:2018 EN 165902:2014 EN 6091:2017 EN 6092:1999+A1: 2009 EN 690:2013 EN 703:2004+A 1:2009 EN 706:1996+A 1:2009 EN 707:2018 Title Earth-moving machinery -- Multilingual listing of equivalent terms -- Part 1: General Earth-moving machinery -- Multilingual listing of equivalent terms -- Part 2: Performance and dimensions Earth-moving machinery -- Trenchers -- Definitions and commercial specifications Earth-moving machinery -- Operator's manual -- Part 2: List of references Earth-moving machinery -- Basic types -- Identification and vocabulary Earth-moving machinery and rough-terrain trucks -- Lighting, signalling, and marking lights, and reflex reflectors Tractors and machinery for agriculture and forestry - Safety-related parts of control systems - Part 1: General principles for design and development (ISO 25119-1:2018) Tractors and machinery for agriculture and forestry - Safety-related parts of control systems - Part 2: Concept phase (ISO 25119-2:2010 modified) Agricultural and forestry machinery - Safety of log splitters - Part 1: Wedge splitters Agricultural and forestry machinery - Safety of log splitters - Part 2: Screw splitters Agricultural machinery - Manure spreaders - Safety Agricultural machinery - Silage loading, mixing and/or chopping and distributing machines - Safety Agricultural machinery - Vine shoot tipping machines - Safety Agricultural machinery - Slurry tankers - Safety Technical Committee ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 127 Earth Moving Machinery ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 63 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name EN 709:1997+A 4:2009 EN 908:1999+A 1:2009 EN 909:1998+A 1:2009 EN 1374:2000+ A1:2010 EN 1853:2017+ AC:2019 EN ISO 42541:2015 EN ISO 42545:2018 EN ISO 42546:2009 EN ISO 42547:2017 EN ISO 42549:2018 EN ISO 425410:2009 Title Agricultural and forestry machinery - Pedestrian controlled tractors with mounted rotary cultivators, motor hoes, motor hoes with drive wheel(s) Safety Agricultural and forestry machinery - Reel machines for irrigation - Safety Agricultural and forestry machinery - Centre pivot and moving lateral types irrigation machines - Safety Agricultural machinery - Silos stationary unloaders for round silos - Safety Agricultural machinery - Trailers - Safety Agricultural machinery - Safety - Part 1: General requirements (ISO 42541:2013) Agricultural machinery - Safety - Part 5: Power-driven soil-working machines (ISO 4254-5:2018) Agricultural machinery - Safety - Part 6: Sprayers and liquid fertilizer distributors (ISO 4254-6:2009) Agricultural machinery - Safety - Part 7: Combine harvesters, forage harvesters, cotton harvesters and sugar cane harversters (ISO 42547:2017, Corrected version 2019-03) Agricultural machinery - Safety - Part 9: Seed drills (ISO 4254-9:2018) Agricultural machinery - Safety - Part 10: Rotary tedders and rakes (ISO 4254-10:2009) Technical Committee agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 64 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name EN ISO 425411:2010 EN ISO 425412:2012/A1: 2017 EN ISO 425414:2016 EN ISO 53951:2013 EN ISO 53952:2013 EN ISO 53953:2013 EN ISO 5674:2009 EN ISO 116801:2011 EN ISO 116802:2011 EN ISO 116811:2011 EN ISO 116812:2011/A1:2 017 Title Agricultural machinery - Safety - Part 11: Pick-up balers (ISO 425411:2010) Agricultural machinery - Safety - Part 12: Rotary disc and drum mowers and flail mowers (ISO 4254-12:2012/Amd 1:2017) Agricultural machinery - Safety - Part 14: Bale wrappers (ISO 425414:2016) Garden equipment - Safety requirements for combustion-engine-powered lawnmowers - Part 1: Terminology and common tests (ISO 5395-1:2013) Garden equipment - Safety requirements for combustion-engine-powered lawnmowers - Part 2: Pedestrian-controlled lawnmowers (ISO 53952:2013) Garden equipment - Safety requirements for combustion-engine-powered lawnmowers - Part 3: Ride-on lawnmowers with seated operator (ISO 5395-3:2013) Tractors and machinery for agriculture and forestry - Guards for power take-off (PTO) drive-shafts - Strength and wear tests and acceptance criteria (ISO 5674:2004, corrected version 2005-07-01) Machinery for forestry - Safety requirements and testing for pole-mounted powered pruners - Part 1: Machines fitted with an integral combustion engine (ISO 11680-1:2011) Machinery for forestry - Safety requirements and testing for pole-mounted powered pruners - Part 2: Machines for use with back-pack power source (ISO 11680-2:2011) Machinery for forestry - Portable chain-saw safety requirements and testing - Part 1: Chain-saws for forest service (ISO 11681-1:2011) Machinery for forestry - Portable chain-saw safety requirements and testing - Part 2: Chain-saws for tree service Technical Committee ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 65 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name EN ISO 118061:2011 Title Agricultural and forestry machinery - Safety requirements and testing for portable, hand-held, powered brush-cutters and grass-trimmers - Part 1: Machines fitted with an integral combustion engine (ISO 11806-1:2011) EN ISO 118062:2011 Agricultural and forestry machinery - Safety requirements and testing for portable, hand-held, powered brush-cutters and grass-trimmers - Part 2: Machines for use with back-pack power unit (ISO 11806-2:2011) EN ISO 11850:2011/ A1:2016 Machinery for forestry - General safety requirements (ISO 11850:2011/Amd 1:2016) EN 12525:2000 +A2:2010 Agricultural machinery - Front loaders - Safety EN 12733:2018 Agricultural and forestry machinery - Pedestrian controlled motor mowers - Safety EN 12965:2003 +A2:2009 Tractors and machinery for agriculture and forestry - Power take-off (PTO) drive shafts and their guards - Safety EN 13118:2000 +A1:2009 Agricultural machinery - Potato harvesting equipment - Safety EN 13140:2000 +A1:2009 Agricultural machinery - Sugar beet and fodder beet harvesting equipment - Safety EN 13448:2001 +A1:2009 Agricultural and forestry machinery - Inter-row mowing units - Safety EN 13525:2005 +A2:2009 Forestry machinery - Wood chippers - Safety EN 13684:2018 Garden equipment - Pedestrian controlled lawn aerators and scarifiers Safety EN 137391:2011 Agricultural machinery - Solid fertilizer broadcasters and full width distributors - Environmental protection - Part 1: Requirements Technical Committee ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 66 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title EN 137392:2011/AC:2 012 Agricultural machinery - Solid fertilizer broadcasters and full width distributors - Environmental protection - Part 2: Test methods EN 14017:2005 +A2:2009 Agricultural and forestry machinery - Solid fertilizer distributors - Safety EN 14910:2007 +A1:2009 Garden equipment - Walk-behind combustion engine powered trimmers Safety EN 14930:2007 +A1:2009 Agricultural and forestry machinery and gardening equipment Pedestrian controlled and hand-held machines - Determination of accessibility of hot surfaces EN ISO 14982:2009 Agricultural and forestry machinery - Electromagnetic compatibility - Test methods and acceptance criteria (ISO 14982:1998) EN 156951:2017 Agricultural tractors and self-propelled sprayers - Protection of the operator (driver) against hazardous substances - Part 1: Cab classification, requirements, and test procedures EN 156952:2017 Agricultural tractors and self-propelled sprayers - Protection of the operator (driver) against hazardous substances - Part 2: Filters, requirements, and test procedures EN 15811:2014 Agricultural machinery - Fixed guards and interlocked guards with or without guard locking for moving transmission parts (ISO/TS 28923:2012 modified) EN ISO 161191:2013 Agricultural and forestry machinery - Environmental requirements for sprayers - Part 1: General (ISO 16119-1:2013) EN ISO 161192:2013 EN ISO 161193:2013 Agricultural and forestry machinery - Environmental requirements for sprayers - Part 2: Horizontal boom sprayers (ISO 16119-2:2013, Corrected version 2017-03) Agricultural and forestry machinery - Environmental requirements for sprayers - Part 3: Sprayers for bush and tree crops (ISO 16119-3:2013) Technical Committee machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 67 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name EN ISO 161194:2014 EN ISO 162301:2015 EN ISO 162311:2013 EN ISO 162312:2015 EN 16246:2012 EN ISO 251193:2018 EN ISO 251194:2018 EN 16952:2018 EN ISO 22867:2011 EN/ISO 22868:2011 EN 13683:2003 +A2:2011 Title Agricultural and forestry machinery - Environmental requirements for sprayers - Part 4: Fixed and semi-mobile sprayers (ISO 16119-4:2014) Agricultural machinery and tractors - Safety of higher voltage electrical and electronic components and systems - Part 1: General requirements (ISO 16230-1:2015) Self-propelled agricultural machinery - Assessment of stability - Part 1: Principles (ISO 16231-1:2013) Self-propelled agricultural machinery - Assessment of stability - Part 2: Determination of static stability and test procedures (ISO 16231-2:2015) Agricultural machinery - Backhoes - Safety Tractors and machinery for agriculture and forestry - Safety-related parts of control systems - Part 3: Series development, hardware, and software (ISO 25119-3:2018) Tractors and machinery for agriculture and forestry - Safety-related parts of control systems - Part 4: Production, operation, modification and supporting processes (ISO 25119-4:2018) Agricultural machinery - Rough-terrain Work Platforms for Orchard's operations (WPO) - Safety Forestry and gardening machinery - Vibration test code for portable handheld machines with internal combustion engine - Vibration at the handles (ISO 22867:2011) Forestry and gardening machinery - Noise test code for portable handheld machines with internal combustion engine - Engineering method (Grade 2 accuracy) (ISO 22868:2011) Garden equipment - Integrally powered shredders/chippers - Safety Technical Committee agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry ISO TC 144 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 68 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 16369:2007 ISO 166531:2008 ISO 166532:2021 ISO 166533:2011 ISO 18878:2013 ISO 18893:2014 ISO 20381:2009 ISO 21455:2020 ISO 4305:2014 ISO 116621:1995 ISO 124801:1997 ISO 13200:1995 ISO 43061:2007 ISO 72961:1991 ISO 77522:2011 ISO 124881:2012 ISO 124781:1997 ISO 85661:2010 ISO 99271:2013 ISO 85664:1998 ISO 4302:2016 ISO 16715:2014 ISO 116601:2008 ISO 116602:2015 Title Elevating work platforms -- Mast-climbing work platforms Mobile elevating work platforms -- Design, calculations, safety requirements and test methods relative to special features -- Part 1: MEWPs with retractable guardrail systems Mobile elevating work platforms -- Design, calculations, safety requirements and test methods relative to special features -- Part 2: MEWPs with non-conductive (insulating) components Mobile elevating work platforms -- Design, calculations, safety requirements and test methods relative to special features -- Part 3: MEWPs for orchard operations Mobile elevating work platforms -- Operator (driver) training Mobile elevating work platforms -- Safety principles, inspection, maintenance, and operation Mobile elevating work platforms -- Symbols for operator controls and other displays Mobile elevating work platforms -- Operator's controls -- Actuation, displacement, location, and method of operation Mobile cranes -- Determination of stability Mobile cranes -- Experimental determination of crane performance -- Part 1: Tipping loads and radii Cranes -- Safe use -- Part 1: General Cranes -- Safety signs and hazard pictorials -- General principles Cranes -- Vocabulary -- Part 1: General Cranes -- Graphic symbols -- Part 1: General Cranes -- Control layout and characteristics -- Part 2: Basic arrangement and requirements for mobile cranes Cranes -- Tolerances for wheels and travel and traversing tracks -- Part 1: General Cranes -- Maintenance manual -- Part 1: General Cranes -- Cabins and control stations -- Part 1: General Cranes -- Inspections -- Part 1: General Cranes -- Cabins -- Part 4: Jib cranes Cranes -- Wind load assessment Cranes -- Hand signals used with cranes Cranes -- Access, guards, and restraints -- Part 1: General Cranes -- Access, guards, and restraints -- Part 2: Mobile cranes Technical Committee ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 214 Elevating Work Platforms ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 69 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 116603:2008 ISO 4310:2009 ISO 43012:2020 ISO 4305:2014/ AMD 1:2016 ISO 43062:2012 ISO 72961:1991/AMD 1:1996 ISO 72962:2020 ISO 85662:2016 ISO 86862:2018 ISO 99282:2014 ISO 102452:2014 ISO 102452:2014/AMD 1:2015 ISO 109722:2009 ISO 11661:2022 ISO 116622:2014 ISO 15442:2012 ISO 15442:2012/ AMD 1:2015 ISO/TR 19961:2010 ISO 43013:2021 ISO 43063:2016 ISO 72963:2006 ISO 77521:2010 ISO 77521:2010/AMD 1:2012 ISO 77523:2013 ISO 85663:2010 ISO 86863:2018 Title Cranes -- Access, guards, and restraints -- Part 3: Tower cranes Cranes -- Test code and procedures Cranes -- Classification -- Part 2: Mobile cranes Mobile cranes -- Determination of stability -- Amendment 1 Cranes -- Vocabulary -- Part 2: Mobile cranes Cranes -- Graphic symbols -- Part 1: General -- Amendment 1 Cranes -- Graphical symbols -- Part 2: Mobile cranes Cranes -- Cabins and control stations -- Part 2: Mobile cranes Cranes -- Design principles for loads and load combinations -- Part 2: Mobile cranes Cranes -- Crane operating manual -- Part 2: Mobile cranes Cranes -- Limiting and indicating devices -- Part 2: Mobile cranes Cranes -- Limiting and indicating devices -- Part 2: Mobile cranes -- Amendment 1 Cranes -- Requirements for mechanisms -- Part 2: Mobile cranes Mobile cranes -- Presentation of rated capacity charts Mobile cranes -- Experimental determination of crane performance -- Part 2: Structural competence under static loading Cranes -- Safety requirements for loader cranes Cranes -- Safety requirements for loader cranes -- Amendment 1 Cranes -- Safety code on mobile cranes Cranes -- Classification -- Part 3: Tower cranes Cranes -- Vocabulary -- Part 3: Tower cranes Cranes -- Graphical symbols -- Part 3: Tower cranes Cranes -- Control layout and characteristics -- Part 1: General principles Cranes -- Control layout and characteristics -- Part 1: General principles -- Amendment 1 Cranes -- Control layout and characteristics -- Part 3: Tower cranes Cranes -- Cabins and control stations -- Part 3: Tower cranes Cranes -- Design principles for loads and load combinations -- Part 3: Tower cranes Technical Committee ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 70 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 99263:2016 ISO 99273:2019 ISO 99423:2020 ISO 102453:2019 ISO 109723:2003 ISO 124803:2020 ISO/TR 27245:2007 ISO 2374:1983 ISO 11994:1997 ISO/TS 15696:2012 ISO 11629:2004 ISO 11630:1997 ISO 13202:2003 ISO 14518:2005 ISO 99261:1990 ISO 99281:2015 ISO 99421:2015 ISO 10973:1995 ISO 12482:2014 ISO 15513:2000 ISO 23813:2007 ISO 23814:2009 ISO 238151:2007 ISO 23853:2018 ISO 4309:2017 ISO 16625:2013 ISO/TS 23624:2021 ISO 43014:1989 Title Cranes -- Training of operators -- Part 3: Tower cranes Cranes -- Inspections -- Part 3: Tower cranes Cranes -- Information labels -- Part 3: Tower cranes Cranes -- Limiting and indicating devices -- Part 3: Tower cranes Cranes -- Requirements for mechanisms -- Part 3: Tower cranes Cranes -- Safe use -- Part 3: Tower cranes Cranes -- Tower cranes -- International Standards for design, manufacture, use and maintenance requirements and recommendations Lifting appliances -- Range of maximum capacities for basic models Cranes -- Availability -- Vocabulary Cranes -- List of equivalent terms Cranes -- Measurement of the mass of a crane and its components Cranes -- Measurement of wheel alignment Cranes -- Measurement of velocity and time parameters Cranes -- Requirements for test loads Cranes -- Training of drivers -- Part 1: General Cranes -- Crane operating manual -- Part 1: General Cranes -- Information labels -- Part 1: General Cranes -- Spare parts manual Cranes -- Monitoring for crane design working period Cranes -- Competency requirements for crane drivers (operators), slingers, signallers, and assessors Cranes -- Training of appointed persons Cranes -- Competency requirements for crane inspectors Cranes -- Maintenance -- Part 1: General Cranes -- Training of slingers and signallers Cranes -- Wire ropes -- Care and maintenance, inspection, and discard Cranes and hoists -- Selection of wire ropes, drums, and sheaves Cranes -- Safe use of high-performance fibre ropes in crane applications Cranes and related equipment -- Classification -- Part 4: Jib cranes Technical Committee ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 71 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 43064:2020 ISO 77524:1989 ISO 86864:2005 ISO 93741:1989 ISO 93744:1989 ISO 102451:2021 ISO 102454:2004 ISO 102454:2004/COR 1:2006 ISO 109724:2007 ISO 116604:2012 ISO 124804:2007 ISO 124884:2004 ISO/TR 25599:2005 ISO 43015:1991 ISO 43065:2005 ISO 77525:2021 ISO 85665:2017 ISO 86865:2017 ISO 93745:2021 ISO 99275:2017 ISO 102455:1995 ISO 109721:1998 ISO 109725:2006 ISO 116605:2001 ISO 12210:2021 ISO/TR 16880:2004 ISO 17096:2015 Title Cranes -- Vocabulary -- Part 4: Jib cranes Cranes -- Controls -- Layout and characteristics -- Part 4: Jib cranes Cranes -- Design principles for loads and load combinations -- Part 4: Jib cranes Cranes -- Information to be provided -- Part 1: General Cranes -- Information to be provided -- Part 4: Jib cranes Cranes -- Limiting and indicating devices -- Part 1: General Cranes -- Limiting and indicating devices -- Part 4: Jib cranes Cranes -- Limiting and indicating devices -- Part 4: Jib cranes -- Technical Corrigendum 1 Cranes -- Requirements for mechanisms -- Part 4: Jib cranes Cranes -- Access, guards, and restraints -- Part 4: Jib cranes Cranes -- Safe use -- Part 4: Jib cranes Cranes -- Tolerances for wheels and travel and traversing tracks -- Part 4: Jib cranes Cranes -- Jib cranes -- International Standards for design, manufacturing, use and maintenance requirements and recommendations Cranes -- Classification -- Part 5: Overhead travelling and portal bridge cranes Cranes -- Vocabulary -- Part 5: Bridge and gantry cranes Cranes -- Control layout and characteristics -- Part 5: Bridge and gantry cranes Cranes -- Cabins and control stations -- Part 5: Overhead travelling and portal bridge cranes Cranes -- Design principles for loads and load combinations -- Part 5: Overhead travelling and portal bridge cranes Cranes -- Information to be provided -- Part 5: Overhead travelling cranes and portal bridge cranes Cranes -- Inspections -- Part 5: Bridge and gantry cranes, including portal and semi-portal cranes and their supporting structures Cranes -- Limiting and indicating devices -- Part 5: Overhead travelling and portal bridge cranes Cranes -- Requirements for mechanisms -- Part 1: General Cranes -- Requirements for mechanisms -- Part 5: Bridge and gantry cranes Cranes -- Access, guards, and restraints -- Part 5: Bridge and gantry cranes Cranes -- Anchoring devices for in-service and out-of-service conditions Cranes -- Bridge and gantry cranes -- International Standards for design and manufacturing requirements and recommendations Cranes -- Safety -- Load lifting attachments Technical Committee ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 72 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 22986:2007 ISO 43011:2016 ISO 4304:1987 ISO 86861:2012 ISO 11031:2016 ISO 168811:2005 ISO 17440:2014 ISO 20332:2016 ISO 37672:2016 ISO 37671:2016 ISO 10975:2009 ISO 162311:2013 ISO 37761:2006 ISO 42541:2013 ISO 42545:2018 ISO 5687:2018 Title Cranes -- Stiffness -- Bridge and gantry cranes Cranes -- Classification -- Part 1: General Cranes other than mobile and floating cranes -- General requirements for stability Cranes -- Design principles for loads and load combinations -- Part 1: General Cranes -- Principles for seismically resistant design Cranes -- Design calculation for rail wheels and associated trolley track supporting structure -- Part 1: General Cranes -- General design -- Limit states and proof of competence of forged steel hooks Cranes -- Proof of competence of steel structures Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 2: Symbols for agricultural tractors and machinery Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 1: Common symbols Tractors and machinery for agriculture -- Auto-guidance systems for operator-controlled tractors and self-propelled machines -- Safety requirements Self-propelled agricultural machinery -- Assessment of stability -- Part 1: Principles Tractors and machinery for agriculture -- Seat belts -- Part 1: Anchorage location requirements Agricultural machinery -- Safety -- Part 1: General requirements Agricultural machinery -- Safety -- Part 5: Power-driven soil-working machines Equipment for harvesting -- Combine harvesters -- Determination and designation of grain tank capacity and unloading device performance Technical Committee ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 96 Cranes ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 73 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 42547:2017 ISO 171011:2012 ISO 171012:2012 ISO 17103:2009 ISO 425412:2012 ISO 9191:1991 ISO 9192:1991 ISO 56732:2005 GB 197261:2005 ISO 11839:2021 ISO 5718:2013 ISO 223681:2004 Title Agricultural machinery -- Safety -- Part 7: Combine harvesters, forage harvesters, cotton harvesters and sugar cane harvesters Agricultural machinery -- Thrown-object test and acceptance criteria -- Part 1: Rotary mowers Agricultural machinery -- Thrown-object test and acceptance criteria -- Part 2: Flail mowers Agricultural machinery -- Rotary disc mowers, rotary drum mowers and flail mowers -- Test methods and acceptance criteria for protective skirts Agricultural machinery -- Safety -- Part 12: Rotary disc and drum mowers and flail mowers Lawn and garden ride-on (riding) tractors -- Three-point hitch Lawn and garden ride-on (riding) tractors -- One-point tubular sleeve hitch Agricultural tractors and machinery -- Power take-off drive shafts and power-input connection -- Part 2: Specification for use of PTO drive shafts, and position and clearance of PTO drive line and PIC for various attachments Machinery for forestry -- Thrown object guard -- Test method and performance criteria Harvesting equipment -- Blades for agricultural rotary mowers -- Requirements Crop protection equipment -- Test methods for the evaluation of cleaning systems -- Part 1: Internal cleaning of complete sprayers Technical Committee ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 74 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name GB/T 5390:1995 ISO 425410:2009 ISO 42549:2018 ISO 162301:2015 ISO 162312:2015 ISO 425411:2010 ISO 425412:2012/AM D 1:2017 ISO 425414:2016 ISO 5674:2004 ISO 5001:2014 ISO 64895:2019 Title Agricultural machinery -- Safety -- Part 10: Rotary tedders and rakes Agricultural machinery -- Safety -- Part 9: Seed drills Agricultural machinery and tractors -- Safety of higher voltage electrical and electronic components and systems -- Part 1: General requirements Self-propelled agricultural machinery -- Assessment of stability -- Part 2: Determination of static stability and test procedures Agricultural machinery -- Safety -- Part 11: Pick-up balers Agricultural machinery -- Safety -- Part 12: Rotary disc and drum mowers and flail mowers -- Amendment 1 Agricultural machinery -- Safety -- Part 14: Bale wrappers Tractors and machinery for agriculture and forestry -- Guards for power take-off (PTO) drive-shafts -- Strength and wear tests and acceptance criteria Agricultural tractors -- Rear-mounted power take-off types 1, 2, 3 and 4 -- Part 1: General specifications, safety requirements, dimensions for master shield and clearance zone Agricultural vehicles -- Mechanical connections between towed and towing vehicles -- Part 5: Specifications for non-swivel clevis couplings Technical Committee machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 75 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 64891:2001 ISO 64892:2002 ISO 64893:2021 ISO 64894:2004 ISO 24347:2019 ISO 5002:2004 ISO 5003:2014 ISO 730:2009/A MD 1:2014 ISO 730:2009 ISO 2332:2009 ISO 110011:2016 Title Agricultural vehicles -- Mechanical connections between towed and towing vehicles -- Part 1: Dimensions of hitch-hooks Agricultural vehicles -- Mechanical connections between towed and towing vehicles -- Part 2: Specifications for clevis coupling 40 Agricultural vehicles -- Mechanical connections between towed and towing vehicles -- Part 3: Tractor drawbar Agricultural vehicles -- Mechanical connections between towed and towing vehicles -- Part 4: Dimensions of piton-type coupling Agricultural vehicles -- Mechanical connections between towed and towing vehicles -- Dimensions of ball coupling device (80 mm) Agricultural tractors -- Rear-mounted power take-off types 1, 2 and 3 -- Part 2: Narrow-track tractors, dimensions for master shield and clearance zone Agricultural tractors -- Rear-mounted power take-off types 1, 2, 3 and 4 -- Part 3: Main PTO dimensions and spline dimensions, location of PTO Agricultural wheeled tractors -- Rear-mounted three-point linkage -- Categories 1N, 1, 2N, 2, 3N, 3, 4N and 4 -- Amendment 1 Agricultural wheeled tractors -- Rear-mounted three-point linkage -- Categories 1N, 1, 2N, 2, 3N, 3, 4N and 4 Agricultural tractors and machinery -- Connection of implements via three-point linkage -- Clearance zone around implement Agricultural wheeled tractors -- Three-point hitch couplers -- Part 1: Uframe coupler Technical Committee agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 76 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 56731:2005 Title Agricultural tractors and machinery -- Power take-off drive shafts and power-input connection -- Part 1: General manufacturing and safety requirements ISO 56921:2004 Agricultural vehicles -- Mechanical connections on towed vehicles -- Part 1: Dimensions for hitch rings of 50/30 mm cross section ISO 56922:2002 Agricultural vehicles -- Mechanical connections on towed vehicles -- Part 2: Coupling ring 40 with socket ISO 56922:2002/COR 1:2004 Agricultural vehicles -- Mechanical connections on towed vehicles -- Part 2: Coupling ring 40 with socket -- Technical Corrigendum 1 ISO 56923:2011 Agricultural vehicles -- Mechanical connections on towed vehicles -- Part 3: Swivel hitch rings ISO 20019:2001 Agricultural vehicles -- Mechanical connections on towed vehicles -- Dimensions for hitch rings. ISO 7072:1993 Tractors and machinery for agriculture and forestry -- Linch pins and spring pins -- Dimensions and requirements ISO 87591:2018 Agricultural tractors -- Front-mounted equipment -- Part 1: Power takeoff: Safety requirements and clearance zone around PTO ISO 87592:1998 Agricultural wheeled tractors -- Front-mounted equipment -- Part 2: Stationary equipment connection ISO 87593:2018 Agricultural tractors -- Front-mounted equipment -- Part 3: Power takeoff: General specifications and location ISO 87594:2018 Agricultural tractors -- Front-mounted equipment -- Part 4: Three-point linkage ISO 110012:1993 Agricultural wheeled tractors and implements -- Three-point hitch couplers -- Part 2: A-frame coupler Technical Committee ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 77 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 110013:2009 ISO 110014:1994 ISO 17900:2002 ISO 20019:2001/ COR 1:2004 ISO 21244:2008 ISO 22471:2020 ISO 263221:2008 ISO 3463:2006 ISO 263222:2010 ISO 26402:2008 ISO 117831:2017 Title Agricultural wheeled tractors and implements -- Three-point hitch couplers -- Part 3: Link coupler Agricultural wheeled tractors and implements -- Three-point hitch couplers -- Part 4: Bar coupler Agricultural trailers -- Balanced and semi-mounted trailers -- Determination of payload, vertical static load, and axle load Agricultural vehicles -- Mechanical connections on towed vehicles -- Dimensions for hitch rings -- Technical Corrigendum 1 Agricultural equipment -- Mechanical connections between towed and towing vehicles -- Implement hitch rings and attachment to tractor drawbars Permissible mechanical connection combinations between towed and towing agricultural vehicles Tractors for agriculture and forestry -- Safety -- Part 1: Standard tractors Tractors for agriculture and forestry -- Roll-over protective structures (ROPS) -- Dynamic test method and acceptance conditions Tractors for agriculture and forestry -- Safety -- Part 2: Narrow-track and small tractors Agricultural vehicles -- Steering systems for agricultural trailers -- Interface for articulated steering device of semi-mounted trailers Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 1: General standard for mobile data communication Technical Committee machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 78 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 117832:2019 ISO 117835:2019 ISO 117837:2015 ISO 117833:2018 ISO 117839:2012 ISO 117834:2011 ISO 1178310:2015 ISO 1178312:2019 ISO 117838:2006 ISO 1178311:2011 ISO 1178313:2011 Title Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 2: Physical layer Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 5: Network management Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 7: Implement messages application layer Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 3: Data link layer Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 9: Tractor ECU Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 4: Network layer Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 10: Task controller and management information system data interchange Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 12: Diagnostics services Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 8: Power train messages Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 11: Mobile data element dictionary Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 13: File server Technical Committee agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 79 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 1178314:2013 Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 14: Sequence control ISO 17612:2004 Tractors and machinery for agriculture and forestry -- Auxiliary-powertransmission connector for the operator station ISO/OECD 78910:2006 Agricultural tractors -- Test procedures -- Part 10: Hydraulic power at tractor/implement interface ISO 2057:1981 Agricultural tractors -- Remote control hydraulic cylinders for trailed implements ISO 5675:2008 Agricultural tractors and machinery -- General purpose quick-action hydraulic couplers ISO 11471:1995 Agricultural tractors and machinery -- Coding of remote hydraulic power services and controls ISO 17567:2020 Agricultural and forestry tractors and implements -- Hydraulic power beyond ISO 425413:2012 Agricultural machinery -- Safety -- Part 13: Large rotary mowers ISO 5718:2013/ AMD 1:2019 Harvesting equipment -- Blades for agricultural rotary mowers -- Requirements -- Amendment 1 ISO 425411:2010/AM D 1:2020 Agricultural machinery -- Safety -- Part 11: Pick-up balers -- Amendment 1 ISO 66891:1997 ISO 5702:1983 Equipment for harvesting -- Combines and functional components -- Part 1: Vocabulary Equipment for harvesting -- Combine harvester component parts -- Equivalent terms Technical Committee ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 80 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 5715:1983 Equipment for harvesting -- Dimensional compatibility of forage harvesting machinery ISO 66892:1997 Equipment for harvesting -- Combines and functional components -- Part 2: Assessment of characteristics and performance defined in vocabulary ISO 8210:1989 Equipment for harvesting -- Combine harvesters -- Test procedure ISO 89091:2021 Equipment for harvesting -- Forage harvesters -- Part 1: Vocabulary ISO 89092:2021 Equipment for harvesting -- Forage harvesters -- Part 2: Specification of characteristics and performance ISO 89093:2021 Equipment for harvesting -- Forage harvesters -- Part 3: Test methods ISO 11450:1999 Equipment for harvesting and conservation -- Round balers -- Terminology and commercial specifications ISO 11450:1999/ AMD 1:2016 Equipment for harvesting and conservation -- Round balers -- Terminology and commercial specifications -- Amendment 1 ISO 121401:2020 Agricultural trailers and trailed equipment -- Drawbar jacks -- Part 1: Design safety, test methods and acceptance criteria ISO 121402:2020 Agricultural trailers and trailed equipment -- Drawbar jacks -- Part 2: Application safety, test methods and acceptance criteria ISO 42548:2018 Agricultural machinery -- Safety -- Part 8: Solid fertilizer distributors Technical Committee machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 81 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 425416:2018 ISO 15077:2020 ISO 120031:2021 ISO 120032:2021 ISO 37671:2016/AMD 1:2020 ISO 37672:2016/AMD 1:2020 ISO 37673:2016 ISO 37674:2016 ISO 37675:2016 ISO 17080:2005 ISO 11784:1996 Title Agricultural machinery -- Safety -- Part 16: Portable agricultural grain augers Tractors and self-propelled machinery for agriculture -- Operator controls -- Actuating forces, displacement, location, and method of operation Tractors for agriculture and forestry -- Roll-over protective structures on narrow tractors -- Part 1: Front-mounted ROPS Tractors for agriculture and forestry -- Roll-over protective structures on narrow tractors -- Part 2: Rear-mounted ROPS Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 1: Common symbols -- Amendment 1 Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 2: Symbols for agricultural tractors and machinery -- Amendment 1 Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 3: Symbols for powered lawn and garden equipment Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 4: Symbols for forestry machinery Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Symbols for operator controls and other displays -- Part 5: Symbols for manual portable forestry machines Manually portable agricultural and forestry machines and powered lawn and garden equipment -- Design principles for single-panel product safety labels Radio frequency identification of animals -- Code structure Technical Committee agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 82 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 11784:1996/ AMD 1:2004 Radio frequency identification of animals -- Code structure -- Amendment 1 ISO 11784:1996/ AMD 2:2010 Radio frequency identification of animals -- Code structure -- Amendment 2: Indication of an advanced transponder ISO 11785:1996 Radio frequency identification of animals -- Technical concept ISO 11785:1996/ COR 1:2008 Radio frequency identification of animals -- Technical concept -- Technical Corrigendum 1 ISO 11786:1995 Agricultural tractors and machinery -- Tractor-mounted sensor interface -- Specifications ISO 121881:2010 Tractors and machinery for agriculture and forestry -- Test procedures for positioning and guidance systems in agriculture -- Part 1: Dynamic testing of satellite-based positioning devices ISO 121882:2012 Tractors and machinery for agriculture and forestry -- Test procedures for positioning and guidance systems in agriculture -- Part 2: Testing of satellite-based auto-guidance systems during straight and level travel ISO 142231:2011 Radiofrequency identification of animals -- Advanced transponders -- Part 1: Air interface ISO 142232:2010 Radiofrequency identification of animals -- Advanced transponders -- Part 2: Code and command structure ISO 142233:2018 Radiofrequency identification of animals -- Advanced transponders -- Part 3: Applications ISO 15003:2019 Agricultural engineering -- Electrical and electronic equipment -- Testing resistance to environmental conditions Technical Committee ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 83 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 156391:2015 Radio frequency identification of animals -- Standardization of injection sites for different animal species -- Part 1: Companion animals (cats and dogs) ISO 156392:2021 Radio frequency identification of animals -- Standardization of injection sites for different animal species -- Part 2: Equine (horses, donkeys, and zebras) ISO 12934:2021 Tractors and machinery for agriculture and forestry -- Basic types -- Vocabulary ISO 3918:2007 Milking machine installations -- Vocabulary ISO 42546:2020 Agricultural machinery -- Safety -- Part 6: Sprayers and liquid fertilizer distributors ISO 5007:2003 Agricultural wheeled tractors -- Operator's seat -- Laboratory measurement of transmitted vibration ISO 5008:2002/ COR 1:2005 Agricultural wheeled tractors and field machinery -- Measurement of whole-body vibration of the operator -- Technical Corrigendum 1 ISO 5707:2007 Milking machine installations -- Construction and performance ISO 6690:2007 Milking machine installations -- Mechanical tests ISO 10448:2021 Agricultural tractors -- Hydraulic pressure for implements ISO 142691:1997 Tractors and self-propelled machines for agriculture and forestry -- Operator enclosure environment -- Part 1: Vocabulary Technical Committee ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 84 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 142693:1997 ISO 142692:1997 ISO 20966:2007 ISO 27850:2013 ISO/TS 28924:2007 ISO 21191:2021 ISO 56821:2017 ISO 56823:2017 ISO 3600:2022 ISO 117837:2022 ISO 11684:2023 ISO 241202:2023 Title Tractors and self-propelled machines for agriculture and forestry -- Operator enclosure environment -- Part 3: Determination of effect of solar heating Tractors and self-propelled machines for agriculture and forestry -- Operator enclosure environment -- Part 2: Heating, ventilation and airconditioning test method and performance Automatic milking installations -- Requirements and testing Tractors for agriculture and forestry -- Falling object protective structures -- Test procedures and performance requirements Agricultural machinery - Guards for moving parts of power transmission Guard opening without tool Equipment for crop protection -- Closed transfer systems (CTS) -- Performance specification Equipment for crop protection -- Spraying equipment -- Part 1: Test methods for sprayer nozzles Equipment for crop protection -- Spraying equipment -- Part 3: Test method to assess the performance of volume/area adjustment systems Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Operator's manuals -- Content and format Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 7: Implement messages application layer Tractors, machinery for agriculture and forestry, powered lawn, and garden equipment -- Safety labels -- General principles Agricultural irrigation equipment -- Guideline on the implementation of pressurized irrigation systems -- Part 2: Drip irrigation Technical Committee ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and machinery for agriculture and forestry ISO TC 23 Tractors and Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 85 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name Title ISO 202971:2017 ISO 108962:2016 ISO 2330:2002 ISO 2291514:2010 ISO 2291524:2015 ISO 36913:2016 ISO 117836:2018 ISO 115255:2015 ISO 108965 ISO 115252:2020 ISO 108964:2015 ISO 108965:2015 ISO 108966:2015/AMD 1:2019 ISO 108966:2015 ISO 184792:2016 ISO 184791:2015 ISO 50531:2020 ISO 6292:2020 ISO 108961:2020 ISO 108967:2016 ISO 180631:2016 ISO 2328:2011 ISO 23676:2020 ISO 115251:2020 Industrial trucks -- Lorry-mounted trucks -- Part 1: Safety requirements and verification Rough-terrain trucks -- Safety requirements and verification -- Part 2: Slewing trucks Fork-lift trucks -- Fork arms -- Technical characteristics and testing Industrial trucks -- Verification of stability -- Part 14: Rough-terrain variable-reach trucks Industrial trucks -- Verification of stability -- Part 24: Slewing variablereach rough-terrain trucks Industrial trucks -- Safety requirements and verification -- Part 3: Additional requirements for trucks with elevating operator position and trucks specifically designed to travel with elevated loads Tractors and machinery for agriculture and forestry -- Serial control and communications data network -- Part 6: Virtual terminal Rough-terrain trucks -- User requirements -- Part 5: Interface between rough-terrain truck and integrated personnel work platform Rough-terrain trucks -- Safety requirements and verification -- Part 5: Interface between rough-terrain truck and integrated personnel work platform Rough-terrain trucks -- Safe use requirements -- Part 2: Slewing variable-reach trucks Rough-terrain trucks -- Safety requirements and verification -- Part 4: Additional requirements for variable-reach trucks handling freely suspended loads Rough-terrain trucks -- Safety requirements and verification -- Part 5: Interface between rough-terrain truck and integrated personnel work platform Rough-terrain trucks -- Safety requirements and verification -- Part 6: Tilting operator's cabs -- Amendment 1 Rough-terrain trucks -- Safety requirements and verification -- Part 6: Tilting operator's cabs Rough-terrain trucks -- Non-integrated personnel work platforms -- Part 2: User requirements Rough-terrain trucks -- Non-integrated personnel work platforms -- Part 1: Design, safety requirements and verification Industrial trucks -- Vocabulary -- Part 1: Types of industrial trucks Powered industrial trucks and tractors -- Brake performance and component strength Rough-terrain trucks -- Safety requirements and verification -- Part 1: Variable-reach trucks Rough-terrain trucks -- Safety requirements and verification -- Part 7: Longitudinal load moment systems Rough-terrain trucks -- Visibility test methods and their verification -- Part 1: Variable-reach trucks Fork-lift trucks -- Hook-on type fork arms and fork arm carriages -- Mounting dimensions Rough-terrain trucks -- Operator training -- Content and methods Rough-terrain trucks -- Safe use requirements -- Part 1: Variable-reach trucks Technical Committee machinery for agriculture and forestry ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 86 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 2331:1974 ISO 115254:2016 ISO 229151:2016 ISO 5057:2022 ISO 13284:2022 ISO 180632:2021 ISO 2291513:2012 ISO 2291513:2012/CO R 1:2013 EN ISO 36912:2023 ISO 36913:2016/Amd 1:2023 ISO 19224:2017 ISO 19296:2018 ISO 610:1990 ISO 7101:1974 ISO 7102:1974 ISO 7103:1974 ISO 7104:1982 ISO 7105:1989 ISO 7106:1984 ISO 7107:1984 ISO 721:1991 ISO 722:1991 ISO 723:1991 ISO 1082:1990 ISO 20305:2020 ISO 217951:2021 Title Fork lift trucks -- Hook-on type fork arms -- Vocabulary Rough-terrain trucks -- User requirements -- Part 4: Additional requirements for variable-reach trucks handling freely suspended loads Industrial trucks -- Verification of stability -- Part 1: General Industrial trucks -- Inspection and repair of fork arms in service on fork-lift trucks Industrial trucks -- Fork arm extensions and telescopic fork arms -- Technical characteristics and strength requirements Rough-terrain trucks -- Visibility test methods and their verification -- Part 2: Slewing rough-terrain variable-reach trucks Industrial trucks -- Verification of stability -- Part 13: Rough-terrain trucks with mast Industrial trucks -- Verification of stability -- Part 13: Rough-terrain trucks with mast -- Technical Corrigendum 1 Industrial Trucks - Safety Industrial Trucks - Safety Requirements And Verification - Part 3: Additional Requirements For Trucks With Elevating Operator Position And Trucks Specifically Designed To Travel With Elevated Loads Continuous surface miners (CSM) -- Safety requirements Mining -- Mobile machines working underground -- Machine safety High-tensile steel chains (round link) for chain conveyors and coal ploughs Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 1: General rules of representation Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 2: Representation of sedimentary rocks Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 3: Representation of magmatic rocks Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 4: Representation of metamorphic rocks Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 5: Representation of minerals Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 6: Representation of contact rocks and rocks which have undergone metasomatic, pneumatolytic or hydrothermal transformation or transformation by weathering Graphical symbols for use on detailed maps, plans and geological crosssections -- Part 7: Tectonic symbols Rock drilling equipment -- Integral stems Rock drilling equipment -- Hollow drill steels in bar form, hexagonal and round Rock drilling equipment -- Forged collared shanks and corresponding chuck bushings for hollow hexagonal drill steels Mining -- Shackle type connector units for chain conveyors Mine closure and reclamation -- Vocabulary Mine closure and reclamation planning -- Part 1: Requirements Technical Committee ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 110 Industrial Trucks ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 87 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 217952:2021 ISO 1717:1974 ISO 1718:1991 ISO 1721:1974 ISO 1722:1974 ISO 3154:1988 ISO 3155:1976 ISO 3156:1976 ISO 35511:1992 ISO 35512:1992 ISO 35521:1992 ISO 35522:1992 ISO 5612:1990 ISO 5613:1984 ISO 5614:1988 ISO/TR 8865:1990 ISO 8866:1991 ISO 8866:1991/ COR 1:1991 ISO 8866:1991/ COR 2:1992 ISO 100971:1999 ISO 100972:1999 ISO 10098:1992 ISO 10207:1991 ISO 10207:1991/ COR 1:1991 ISO 10208:1991 ISO 187581:2018 Title Mine closure and reclamation planning -- Part 2: Guidance Rock drilling -- Rotary drill-rods and rotary drill-bits for dry drilling -- Connecting dimensions Rock drilling equipment -- Drill rods with tapered connection for percussive drilling Rock drilling -- Extension drill-steel equipment for percussive long-hole drilling -- Reverse-buttress-threaded equipments 1 1/16 and 1 1/4 in (27 and 32 mm) Rock drilling -- Extension drill-steel equipment for percussive long-hole drilling -- Reverse-buttress-threaded equipments 1 1/2 to 2 1/2 in (38 to 64 mm) Stranded wire ropes for mine hoisting -- Technical delivery requirements Stranded wire ropes for mine hoisting -- Fibre components -- Characteristics and tests Stranded wire ropes for mine hoisting -- Impregnating compounds, lubricants, and service dressings -- Characteristics and tests Rotary core diamond drilling equipment -- System A -- Part 1: Metric units Rotary core diamond drilling equipment -- System A -- Part 2: Inch units Rotary core diamond drilling equipment -- System B -- Part 1: Metric units Rotary core diamond drilling equipment -- System B -- Part 2: Inch units Mining -- Scraper bars for chain conveyors Mining -- Drive sprocket assemblies for chain conveyors Locked coil wire ropes for mine hoisting -- Technical delivery requirements Mining -- Guidance on methods of verifying dimensions of sprocket assemblies for chain conveyors Rotary core diamond drilling equipment -- System C Rotary core diamond drilling equipment -- System C -- Technical Corrigendum 1 Rotary core diamond drilling equipment -- System C -- Technical Corrigendum 2 Wireline diamond core drilling equipment -- System A -- Part 1: Metric units Wireline diamond core drilling equipment -- System A -- Part 2: Inch units Wireline diamond core drilling equipment -- System CSSK Rock drilling equipment -- Rope threaded drill steel equipment for percussive drilling, nominal sizes 22 mm to 38 mm Rock drilling equipment -- Rope threaded drill steel equipment for percussive drilling, nominal sizes 22 mm to 38 mm -- Technical Corrigendum 1 Rock drilling equipment -- Left-hand rope threads Mining and earth-moving machinery -- Rock drill rigs and rock reinforcement rigs -- Part 1: Vocabulary Technical Committee ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 88 of 90 The impact of a Potential PFAS Restriction on non-road equipment for AEM Members Name ISO 187582:2018 ISO 19225:2017/ AMD 1:2019 ISO 194261:2018 ISO 194262:2018 ISO 194263:2018 ISO 194264:2018 ISO 194265:2018 ISO 194267:2021 ISO 19434:2017 ISO 19434:2017/ AMD 1:2019 ISO 229321:2020 ISO 229322:2020 ISO 23872:2021 ISO 23875:2021 ISO 23875:2021/ AMD 1:2022 Title Mining and earth-moving machinery -- Rock drill rigs and rock reinforcement rigs -- Part 2: Safety requirements Underground mining machines -- Mobile extracting machines at the face -- Safety requirements for shearer loaders and plough systems -- Amendment 1 Structures for mine shafts -- Part 1: Vocabulary Structures for mine shafts -- Part 2: Headframe structures Structures for mine shafts -- Part 3: Sinking stages Structures for mine shafts -- Part 4: Conveyances Structures for mine shafts -- Part 5: Shaft system structures Structures for mine shafts -- Part 7: Rope guides Mining -- Classification of mine accidents Mining -- Classification of mine accidents -- Amendment 1 Mining -- Vocabulary -- Part 1: Planning and surveying Mining -- Vocabulary -- Part 2: Geology Mining structures -- Underground structures Mining -- Air quality control systems for operator enclosures -- Performance requirements and test methods Mining -- Air quality control systems for operator enclosures -- Performance requirements and test methods -- Amendment 1 Technical Committee ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining ISO TC 82 Mining Report No. 2023-0518 Rev. 0 RINA Tech UK Ltd Page 89 of 90 AEM:71 RIPq Association of Equipment Manufacturers RINA Tech UK Limited I 1 Springfield Drive, Leatherhead, Surrey, KT22 7AJ, United Kingdom I P. =@rina.org I www.rina.org I Company No. 07419599