Document 7RDRN1VyRxEXoaQNQMMvZ4eRE

Fomicom Company overview We supply and manufacture low-pressure spray polyurethane (PU) foam and insulation pouring foam for a wide range of industrial niche markets and major construction projects: fast and simple insulation of objects, anticondensation, combatting corrosion problems, injection into moulds, making items airtight, etc Fomicom CMA FROTH-PAK INSTASTIK Private label Fomicom is a SME, employing 9 people with a distribution and OEM network, mainly in Europe, around it. Fomicom works in partnership with the Performance Building Solutions business of DuPont to develop the unique products with high efficiency requirements in niche end uses. FROTH-PAK distribution Global except USA & Canada Fomicom PFAS definition The current definition of PFAS includes hydrofluoroolefins (HFOs), HFO-1234ze(E) and HCFO-1233zd(E) in particular, that should not be in the scope of this restriction proposal. As noted in the REACH Registration dossiers, the REACH registration assessments concluded HFO-1234ze(E) and HCFO-1233zd(E) are not PBT/vPvB, and additional data shows the compounds do not break down into PBT/vPvB compounds. Fomicom Alternative blowing agents for low-pressure spray PU foam Fomicom Alternative products Low-pressure spray PU foam systems serve a niche market in building, industrial and construction uses where no equally efficient alternatives are available. These systems take care of several applications that would otherwise impact negatively energy efficiency, safety, environment or fire behaviour. Fomicom derogation As PU foam manufacturers, we do not develop new blowing agent molecules; we rely on the blowing agent industry and they do not have alternatives to the insulating, nonflammable HFO compounds at this time. Developing and registering new molecules, followed by testing and certifying a new low-pressure spray PU foam product for the industrial and construction market, requires at least 12 years. Eliminating the use of HFO blowing agent without valid alternatives would jeopardise heavily the activities of Fomicom and the network around it. This is a very small market with only 2 manufacturers in the EU and a very limited number of brand name products; there will be a small number of commentors (perhaps 3), and this should be seen as strong evidence. The use of HFO-1234ze(E) and HCFO-1233zd(E) as foam blowing agent in low-pressure spray PU foams for use in all industrial and construction applications should be given a full derogation.