Document 7O8okLJQXmK0wmqYe5obkkLdg

SunChemical a member of the DID'. group 12 Date: 08.09.2021 Kind attention: Mr. Martijn Beekman - Netherlands Dr. Mandy Lokaj - Germany Mrs. Jenny lvarsson - Sweden Mr. Toke Winther - Denmark Mr. Audun Heggelund - Norway Mr. Mark Blainey - ECHA iePFAS@rivm.nl Pbaua.bund.de lvarsson kemi.se Through: Pro-K Industrieverband Halbzeuge and Konsumprodukte aus Kunststoff e.V. (pro-K), Stadelstr. 10, 60596, Frankfurt am Main, Germany The members of pro-K mainly focus on processing of Fluoropolymers, part manufacturing and its applications, the involvement of downstream users in PEAS process. Subject: PFAS restriction proposal & request for exemption of FLUOROPOLYMERS Reference: PFAS - Registry of restriction intentions until outcome (Rol) dated 15th July 2021 Dear Sir/Madam, With regards to Registry of Intention (Rol) filed by 4 EU Member States (Germany, the Netherlands, Sweden, and Denmark) & Norway for the restriction of PFAS, we, a member of fluoropolymer downstream user industry, hereby, would like to share some salient facts related to the importance of fluoropolymers, critical functionalities, performance and benefits of its applications to society, while acknowledging concerns regarding PFAS emissions related to the use of fluoropolymers and their end of life. Registry of Intention for PFAS restriction was announced by ECHA on 15th July 2021, to prepare a restriction proposal for PFAS. Fluoropolymers are also included in the scope. The restriction proposal is intended to be submitted to ECHA by 15th July 2022. Fluoropolymers are a distinct subset of PFAS and are inherently safe, non-mobile, non-bio accumulative and non-toxic. Fluoropolymers are different from other PFAS as they do not share the toxicological and environmental profiles associated with PEAS of concern. Fluoropolymers have unique set of physicochemical properties, they meet OECD polymer of low concern criteria, and are considered to have insignificant environmental and human health impact. Ell Fluoropolymers ensure safety, reliability, durability and critical performance in numerous technologies industrial processes and everyday applications that are important for human health, safety, and th