Document 85Q9k6LEg9Mk709yMj25k7bxd

PFAS DM FUD Co.,Ltd. Samuel Park 01088908206 Phone: E-mail: @gmail.com Content: Request for exemption Org. name: FUD Co.,Ltd. General Comments: Our company is a terminal application of fluorinated fine chemicals, and we would like to greet the five countries that have proposed the ECHA and PFAS control draft. Our company has always made unremitting efforts to comply with domestic and international regulations, and continuously conducts strict self review of the compliance of products exported to the European Union. For a long time, our company has supported EU proposals aimed at reducing the risks caused by toxic and harmful substances, and has taken practical measures to meet EU chemical regulatory requirements, including REACH. Our company is an end user of electronic fluoride solutions, using electronic fluoride solutions such as hexafluoropropylene oligomers and hydrofluoroethers for immersion cooling. The company strictly follows environmental requirements for production activities, and the PFAS substances involved will not be discharged into the environment. The electronic fluoride liquid products used by our company do not belong to the chemicals listed in the "Catalogue of Hazardous Chemicals" (2015 version). The upstream manufacturer entrusted Zhongke Testing Technology Services (Jiaxing) Co., Ltd. for testing, with an ODP value of 0 (as required by environmental standards and ozone depleting room substitute HJ/T225-2005) and a GWP value of 120 (as climate change 2013-IPCC (100th year)). Due to the strong electronegativity of fluorine atoms and the extremely high bond energy of carbon fluorine bonds, their decomposition ability under harsh conditions is much lower than that of other liquid substances, and most fluorinated liquids do not have flash points. Compared to other insulation cooling media, it has better safety when used. As a heat transfer medium, fluorinated liquid has lower heat transfer parameters, surface energy, and viscosity compared to traditional coolants. In the data center, air-cooling and cooling powerful servers requires expensive costs, consumes a large amount of electricity, and is detrimental to the environment and economic budget. But immersive liquid cooling using electronic fluoride solution can significantly reduce energy consumption costs, while increasing server density and reducing data center size. In the field of semiconductor manufacturing, small temperature fluctuations may have a significant impact on yield due to their high precision requirements. Compared with traditional coolants, fluoride solution has a wider operating temperature and requires less maintenance. Even if there is a leak, it will not damage electronic devices or chips. Due to the characteristics of electronic fluoride solutions, many downstream applications cannot find products with the same effect to replace them. If forcibly prohibited, it will inevitably bring huge economic losses and a huge impact on high-end industries. Therefore, our company applies for an extension or exemption of electronic fluoride solution related products.