Document 994xwNq3d1mVNQxjperMn5Bme

PFAS & THE AUTOMOTIVE INDUSTRY TOOLS, PROJECTS AND CHALLENGES FPP4EU Collaboration Platform Workshop I CE a ce d THE COMPLEXITY OF SUPPLY CHAINS AND RESULTING BUSSINES IS STILL TOTALLY UNDERESTIMATED F 1]ama t1000e< ,200088 "1 T > = NOIRE TIE -mY ny 2 N9000 7, 0| oT AL oso ZT Ee TT ae md5003 ENGI Tp ra SE ig Nhe bi A = L Eh, EL 2 \ /k | oT =wienEg SeeY l 1= .0armE y = 8r ST0-}t! EaE eEi s A === 5 aa OO 5m -- ml = ---- a=s=s oTrnt [ |wd @ "20 . =wd E50e Tors LE) hm" oe. Lo REE we IE SSE TT oy i Twieers EgR ch HEwn 10 oth mC odet) te gH Lid se Ter cba De Lo wiboon [ISP IMDS - A GLOBAL ONLINE TOOL www.mdsystem.com THE GENERAL PROCESS OF SUBSTANCE REPORTING IN THE AI To protect CBI, Material Manufacturers are allowed to ,,hide" up to 10% of their recipe behind so called "Jokers", e.g. "Further Additives" BUT: If a substance is listed on GADSL (= prohibited or declarable), it must not be hidden behind a Joker but has to be uncovered / reported No CBI Protection for GADSL Listed Substances GADSL has to be absolutely correct to ensure CBI Protection and allow for proper compliance IMDS -- LESSONS LEARNED Data Quality Experiencebased costs many Bllns ctodevelop, maiandnoptitmizeatheitnem VI heen iolccmal drnafteu oaafcistd hnprteuesi traq,urnaohluiag ntyydts1oh6peBprirselslaohifaovnhaneectbheedenansmiivniveencsdtoeoudp,sesriantcieo2n0e0n0een 1 BEE von 2 @ Tn T= = Feemmn = = 3 So moroAa - =. IMDS - A Oct. 22: 200,000 Active Users TRULY GLOBAL Oct. 22: 96 Mio Datasheets SOLUTION Oct. 22: 194,000 Active Companies ONE OF THE MAJOR CHALLENGES... ShinShout or IMDS Data Quality Checks Yd [elo Data Input Quality: Acceptable X years vo Data Output Quality: Less Acceptable ... the update of existing data due to engineering changes on supplier side ... unintentional contaminants (e.g. PFAS, PAH, ...) AUTOMOTIVE INDUSTRY - PFAS Summary of our major challenges: + We don't know exactly where... + We don't know exactly why... Sometimesyouthinkyou LOT] + We don't know exactly by whom... + We don't know exactly how many and how much... ' Ee : * We don't know which essential... J ( + We don't know exactly which... we Aue in as vasmeses ensene cor TTT TN \ THM ATO ...PFAS are used in our supply chain But according to our current limited knowledge we understand, that the PFAS restriction is a majorthreat to our European business HOW TO "WHICH": PFAS IDENTIFICATION + The current approach (under testing) to reduce PFAS only to the commercially relevant ones. ~ Process not yet approved by the responsible committees ~ Discussion also including non-automotive associations (e.g. Aerospace and Defense) fF Fy a a `GlobalAinsdsuesstrsimaelnrteolfevance: Ll --= + Declaration threshold ~ Intentionally added including any degradation byproducts of PFAS ~ Triggered by the "US Maine Requirements" PEAS List HOW TO FURTHER REDUCE THE NUMBER OF PFAS CAS#? Focus on Fluorochemical Manufacturers & Commercially available PFAS + Globally 50 + chemical manufacturers of PFAS + What are the odds of 50+ global chemical manufacturers using 4000- 10,000 CAS numbers? + Chemical Manufacturers claim only a low percentage of CAS# are used = This is potentially credible!? + Study indicates that only 256 (5.4%) out of 4730 CAS# on OECD list were used commercially by three diversified fluorochemical manufacturers** + Actual CAS# not listed in published paper (may be intellectual property concern for chemical manufacturers) Fr How to further reduce number of relevant PFAS? Buy-in from other sectors appreciated! ) aBBEpuAocLkf,cortoc,abeosruirbcmaA atnocneasn(FcAaSs)WsiiOaor,BroEnfBvcirronmPAcscsAeassyM.alneaagn1t27g072r)1 i SUMMARY AND OUTLOOK ON PFAS IN IMDS Current: We will inform all >150,000 global suppliers about their duty to report PFAS > 25ppb per article We have updated our Global Automotive Declarable Substance List (GADSL) with >2000 PFAS Existing relevant data needs to be updated (hopefully) Coming Next: We may add a requirement for material manufacturers to actively confirm (checkbox) that their materials are within the legal thresholds Request to chemical industry and material manufacturers: Which PFAS test procedures and methods are available to be referenced? Are you interested in participation in this discussion? We have started with two external projects / studies... 13 How to "where", to "by whom", to "why" & to "how much"? Both CLEPA and ACEA are highly impacted by the coming PFAS restriction : Many fluoropolymers and fluoroelastomers used in car and automotive devices - joints, o-ring, wire etc. F-gas used as refrigerant Short chain PFAS used in many products - lubricants, cleaning products, surface treatment etc. ACEA and CLEPA commissionned Cetim, the French Technical Center for Mechanical Industry, on two studies to enhance their knowledge on PFAS and have relevant data to submit for the public consultation: A socio-economic analysis of the replacement of R-1234yf A PFAS inventory on 5 selected automotive parts, focusing on short chain PFAS The main objective of the study is to assess the presence (or not!) of short chain PFAS in the materials and manufacturing processes of the selected pieces : Chassis : Shock Absorber, strut assembly Traction Battery : Battery Cell scrim binder Fuel Line : Fuel injector sleeve and O-ring MAC : Compressor bearing shaft, rotor, filter Harness wire cable Automotive supply chain study : PFAS inventory > Forcach parts > Gathering suppliers contac formation rom CLEPA/ ACEA members JGonytuctng teriews wit fe | suppers, check her uses of PEAS, questionnaire vas developped wi > Reach forteI, tc. sppletroassess he uses > Try to cstabish hich PFAS are used, why he quaniis, the exposure, fc. > Data ar collected and displayed anonymously > Stil expecting feedbacks from suppliers > Fist resus wi bo avaiable in docombor : > Further resus and foadbacks il bo added on they ars avaiable fo further srenghiened he study 4Hl 15 Automotive supply chain study : PFAS inventory Quick results overview : case of the wire cable ACEA established the use of FEP and PTFE in the cable 3 tier I suppliers contacted and interviewed Thanks to 1 tier I supplier, 10 tier II suppliers responded, 16 expected to send some feedback soon Chemical companies responded to sollicitation and agreed for meetings General feedback : -Tier I suppliers are using fluoropolymers, no Tier I short chain PFAS in the processes Manufacturer Tier I Tier I x3 Tier II Tier II x10 Chemists x2 -Short chain PFAS used : 4,4'-[2,2,2-trifluoro-1- (trifluoromethyl)ethylidene]diphenol ~1,8% in rubber seal -Other fluoropolymers identified : PVDF-HFP (rubber seal) Modified ETFE (corrugated tubes) MFA (corrugated tubes) 17 Socio-economic analysis on replacement of R-1234yf in mobile air conditionning Mobile air conditionning is mainly using R-1234yf as a refrigerant. It is identified as a PFAS and thus face a possible ban according to the definition given for the restriction proposal. In Extenso Croissance Innovation (IEIC) has been commissionned to conduct a socio-economic analysis on the replacement of R-1234yf in MAC by alternative refrigerants, especially on R-744 The objective is to identify and structure relevant data on the challenges for the automotive industry suche as : Substitution Impact on supply chain of R-1234yf replacement Assessment of health impact for substitutes Benefits/disadvantages for current technology and substitutes A framework of the SEA was set-up to structure the data collected Focus on R-744 scenario 18 Socio-economic analysis on replacement of R-1234yf in mobile air conditionning The study is structured in two main phases : Analysis of available data and structuration of them Further analysis of relevant data and reports General schedule First phase done by September 2022 Health and environment reports deliver, commented and in revision Economic, trade and social reports to be delivered in the coming weeks Refrigerant producers Logistic of the refrigerant Auto-parts manufacturers Car manufacturers Maintenance and repairs Retail sales of auto-parts Car users Recycling of end-of-life vehicles 19 Socio-economic analysis on replacement of R-1234yf in mobile air conditionning During phase 2, IEIC managed to interview several key actors of the supply chain 16 interviews were conducted, including 3 auto-parts manufacturers Preliminary results R744 based systems are larger and not sufficient enough in hot weather Incompatibility between curent R-1234yf system and alternatives based systems Suppliers wouldn't be able to propose large-scale production of new systems on a mid-term schedule Impact on employment is limited if investments are made Mainly R&D, retrain of the labor force, aftermarket service personnel difficulties of deployment in short period of time EU car manufacturers already invested for last transition from R-134a : low benefits from their technological advance on this matter Technological advance gains through this new regulation is not guaranty to turn into a competitive advance on foreign markets if the latters won't make the transition (example: R134a is still used in several areas) 20 Difficulties and lessons Data are not readily available, many scientific publications focus on health and environment impact The whole supply chain for each industrial sector is affected, so they need to mobilize and share information Many suppliers are not fully aware of the extent the PFAS restriction will have There is a need to support your suppliers and customers Again, sharing data is a key point for such studies Timing is very short, especially on such a broad family of substances Industrial and professionnal association need to carry these studies ASAP, to have some hard data to provide for the public consultation Go It