Document 91mqvvLz5dnkJpJQzrBq3v4Vp
i Chemours
RReef..AArreess(22002243))23514140917410-0083//0054//22002234
Wilmington, DE 19801
Thierry Breton Industry Commissioner, Growth Sustainability and the Internal Market
European Commission Rue de la Loi 200, B-1049 Brussels, Belgium
Commissioner,
Wilmington, 3rd May 2023
In January this year, our group announced a 200 million investment in ViIIers-Saint-Paul (Oise) to produce the membranes needed for the European hydrogen industry, which is in full development. This decision to invest in Europe in the hydrogen economy is due to the strong fit between our vision of sustainable growth and the desire of the European and French public authorities to develop a reliable and solid hydrogen economy to help decarbonise industry.
Since then, however, we have been surprised to discover that this production could be banned in the next few years because of moves to ban so-called 'PFAS' products altogether. The regulations currently being prepared on PFAS substances use a very broad definition and include more than 10,000 compounds. The proposal submitted by five Member States to ECHA provides for a wide-ranging ban, without distinguishing between the toxicological profiles of the substances, and without solid data on technical feasibility. This simplistic approach jeopardises sectors that are essential to building a sovereign, sustainable, low-carbon economy.
We would like to stress that this proposed restriction could have harmful consequences for Europe's industrial ambitions in the fields of batteries, semi-conductors, electric vehicles, renewable energies, hydrogen, water treatment, building insulation, heat pumps, electronics and digital technology, as well as for all the basic industries such as the chemical industry and the production of industrial equipment. It is highly likely that all investment in Europe will be impacted (halted or put on hold) until this uncertainty is resolved.
Fluoropolymers and fluorinated gases are widely used in many industries for their advantages in terms of performance, reliability and safety. They are found in electrical cables, chemical production, nuclear reactors, renewable energy production, electronic appliances, refrigeration and air conditioning, high-performance insulation, corrosion protection, high-tech non-invasive surgical equipment, green hydrogen production and high-performance lubricants.
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We propose that you rellect on a suspension of this process in order to take into account the consequences of such a restriction, and seriously consider the possibility of immediately excluding the industrial and professional uses of Tluoropolymers and fluorinated gases from the scope. A more nuanced and dilfrenciated approach, taking into account the specificities of the various compounds, is needed to ensure a sustainable and environmentally friendly transition without compromising Europe's economic and industrial development. We understand that the proposal is intended to be amended during the procedure, however the uncertainty created by the broad scope of this proposal will have immediate consequences for European industry. We thank you for your attention to this issue and look forward to discussing Yes issues and possible solutions. Yours sincerely
1007 Market Street Wilmington, DE 19801