Document 8Re9z05KEymJx0BE8MR8aVOwB

EURATEX input to UBA Call for Information on short chain PFASs April 2018 Summary EURATEX, the European Clothing and Textile Confederation, wishes to thank the German Environmental Agency and kopol GmbH/Swerea IFV on the opportunity to provide input on the type of uses and products as well as socio-economic impacts that the possible restriction might have on the EU textile sector. PFASs are crucial for certain specialized textile applications such as personal protective equipment (PPE) and technical textiles. This has already been elaborated during the restriction process for PFOA, its salts and related substances, particularly in the context of justifying a need for a time-limited derogation that would provide for the industry to adapt and for research to advance in finding suitable alternatives while avoiding "regrettable substitution". Wise substitution takes time and synergy between chemical and textile expertise. As the initial steps of the restriction process for C6 and lower are in preparatory stage, EURATEX wishes to address the following concerns: Importance of fluorinated substances in EU textile and apparel industry The European textile and apparel industry does not only represent home textiles and clothing, but also specialized technical textiles and PPE. The European textile and apparel companies are fully supportive of more sustainable products and replacement of harmful chemicals when possible. It is important to highlight that certain applications such as technical textiles and PPE need performance chemistry to comply to safety standards and provide a certain function such as oil, water, and chemical repellence. In case of a restriction of all C6-C4 chemistry, the EU textile industry would experience serious challenges in meeting safety standard requirement with alternatives that are not suitable for certain applications. That might imply a possible modification in the standards for protective clothing--unless an exception will be granted. It should be highlighted that a change in the safety standards might imply lower levels of protection. Short chain PFASs as a last available alternative Nowadays, companies treat their textile materials with C6, the currently available and allowed alternative, in order to meet the requirements of different standards for PPE. Research has shown that even short chain fluorinated substances have certain limitation as opposed to C8 chemistry for certain applications: o Often times protective textiles finished with C-6 chemistry needs to be re-impregnated after each washing to meet the criteria required for testing. Repeated impregnation of C-6 also implies more usage of binders which has a negative effect on flame retardancy. This might cause issues to apply heat-sealable retro-reflective strips and logo's on textiles that require frequent washing. o A study performed at the request of a project group CEN/TC162 WG2, shows clearly that textiles that are treated with C-4 chemistry do NOT meet some of the minimum requirements that are requested by standards for protective clothing. o According to the ECO-DWOR project by Centexbel and Flik, fluorine free alternatives perform well with water repellence but not for oil and solvent repulsion. Some of these products for example silicon based impose limitations on labelling of textiles. Short chain fluorochemicals provide for oil and solvent repellence, but are less performant (less effective) than C-8 due to the lower number of carbon atoms. In that regard, C-4 chemistry offers a limited oil repellence and even in cases when C-4 provides a better oil repellence, water repellence is limited. C-6 chemistry offers good water and oil repellence but in specialized applications such as PPE Annex I requiring flame retardancy, there are limitations to achieving multifunctionality which also depends on the type of fabric. Possible residues (e.g. spin finish) remaining on the textile showed to decrease the performance of fluorine free alternatives and short-chain chemistry, which was less of a problem in C-8. o Preliminary results of the Life+ project MIDWOR researching alternatives to long-chain fluorocarbons used in textile industry show that silicone-based alternatives are not effective in oil repellence in certain applications particularly technical textiles due to its surface energy being higher than the surface energy of oil. EURATEX supports the work of this project as an Advisory Board Member and co-organizer of a workshop with researchers and textile and chemical companies to discuss "real life" application of tested alternatives and their limitations. DISCLAIMER: The above information is provided based on Membership consultation run by EURATEX and deems to properly describe the specificities of the European textile manufacturing. Due to the complex nature of textile manufacturing and high number of companies involved, the above information cannot claim to be exhaustive or rule out exceptions. More information can be provided at a later stage. Annex I Based on the currently available information, evidence suggest that the following standards might not be met without fluorinated substances: These are product standards by which gutter and spray need to be tested Spray test EN 24920:1992, ISO 4920:2012 EN 1486 (2007) EN 469 (2005) + A1(2006) EN 16689(2017) Gutter EN 368, ISO 6530 EN 13034 (2005) + A1 (2009) EN 659 (2003) + A1(2008) EN 469:2005 + A1:2006 Spraytest (light) EN ISO 17491-4A (2008) EN 13034 (2005) + A1 (2009) EN ISO 27065 (2017) Spraytest (full) EN ISO 17491-4B (2008) EN 14605 (2005)+A1 (2009) EN ISO 27065 (2017)