Document 6wL8QgvQYEzGOMmOj7E09Jk53

DIGITALEURUPE A DIGITAL view on the PFAS restriction We represent over 45,000 businesses across Europe The voice of digitally transforming industries platform services data analytics software & hardware cybersecurity telecoms semiconductors cloud technology Healthcare Manufacturing Finance Buildings Mobility 41 NATIONAL ASSOCIATIONS 100 COMPANIES 60+ Categories of uses identified in electronics* Application area Coatings *Excluding semiconductors, energy, medical, automotive, aerospace Printed circuit boards High voltage/power applications Cables and connectors Components Mechanical applications Displays Batteries Fire prevention Heat transfer Details Capacitors, dielectric films Electret films in microphones, sensors Gaskets, sealing Microphone/speaker vent membrane Piezo in acoustical equipment Rubber parts in image forming process in printers Chemical equipment Chemicals 3Others Complexity of electronics supply chain Even a simple circuit board contains dozens of different components A component consists of many articles A product contains thousands of articles Each article to be investigated for the use of PFAS 4 Annex XV report about electronics Elements contradicting circularity for electronics and twin transition objectives 1 Apart from proposed 12-year derogation for the semiconductor manufacturing process, no derogations for the electronics sector No computing / communications products will meet 18 months transition period Huge economic impact, business closures 2 No exemption for spare parts of existing products No spare parts can be made available despite the requirement to do so under the EU Ecodesign directive/regulation As is, restriction will lead to premature obsolescence of products on the market 3 No exemption for refurbished or pre-owned products / articles already on the market Use and emissions from electronics are less than 1% of the 5 total PFAS use and emission Towards PFAS-free electronics No drop-in alternatives for most applications; products must be re-designed In many cases, there is no alternative for PFAS yet (e.g., Li ion batteries) 18 months transition period is insufficient Significantly more time is required to gather information on the uses of PFAS in all components of complex electronic products, substitution analysis and product re-design Once alternative is available, product re-design normally takes minimum 24 months (selection, qualification, certification, etc.) Redesign of a complete portfolio takes longer Applications which have no alternatives will require timebound derogations like EU RoHS exemptions 6 Derogation needed | Spare parts & pre-owned products At least 7 years derogation needed to avoid premature obsolescence of existing consumer electronic products Precedents in other REACH substance restrictions Needed for compliance with Ecodesign, right-to-repair At least 15 years derogation needed to avoid premature obsolescence of existing professional b2b electronic products Lifetimes and contracted maintenance periods usually extends to 10 to 15 years Availability of spare parts is essential to realize the lifetime potential of such products Without an exemption for re-supply of pre-owned products, resale of pre-owned products will be banned Established practice under REACH, POPs Regulation, CE marking legislation Needed for compliance with future Ecodesign Regulation 7 Spare parts & pre-owned products - Support from 25 global industry associations 8 Conclusions & Way forward Current proposal will force most electronic products to be withdrawn from the market due to short transition period and no exemptions Elements are contradicting the Green Deal, Circular Electronics, and particularly Ecodesign objectives Digital/Green Transition objectives impossible No refurbishment, no repair; premature obsolescence Transition towards PFAS-free electronics will take time General 5-year derogation for EEE needed Time-bound exemptions for uses with no alternatives Derogations for spare parts and articles already on the market 9 #AStrongerDigitalEurope @DIGITALEUROPE linkedin.com/digitaleurope Thank you for your attention!