Document B8XY2ywZ30VKOb82EXp9Zk38o

wNi=:e:.> PFAS restriction BCR stakeholders meeting 6/9/2023 um Embradngarion" .AGORIA .AGORIA PFAS within the technological industry Broad ranges ofuses within Agoria: Cooling/heating gases Sealings, gaskets, ... Semiconductor fabrication Filters for off-gas and waste water treatment, ... Electronics, cables, ... Foams, Lubrificants Batteries, Both in the products providedas well as in the production processes of our members Challenges: Identification ofall uses = impossible Alternatives = not existing/known for multiple uses Fear ofnegative impact ofsubstitution: Performance, Reliability, Environmental performance, Life time impact, Detailed information= need for in-depth analysis which is impossible in short timeframe Multiple companies Agoria will be affected. Proper designed exemptions/derogations will be needed!! A ill .AGORIA Some generic elements General exemption needed for repair (as produced),maintenance,re-use...: No drop in alternatives are existing for most of the specific identified uses Maintenance and repair will become impossible after the application of the restriction Clarity whether re-use is still possible... A clear, transparent procedure to define & review exemptions/derogations is needed: Only about 20 exemptions are foreseen for -io.000 substances and multiple uses ROHS directive with 239 exemptions for 6 substances Given multiple use cases with no clear alternatives in view-- need of proper exemption/derogation scheme integrated in the restriction process: Generic exemption 13,5 years include review clause (also for derogations) after 6,5 years PFAS & recycling= challenging with proposed low concentration values: The proposed concentration values are very low and could have a dramatic impact on plastic recycling -- with small traces of PFAS Include generic exemption for recycled material in order to avoid any supplementary burden for plastic recycling 3 .AGORIA PFAS: cooling& heatingapplications What is the issue? The low GWP F-gasses are PFAS substances falling under the scope of the restriction The F-gas regulation (under revision) with a gradual phase out of high GWP F-gasses pushes industry towards the use of PFAS given that natural gasses still have technological challenges/limitations Products are designed with a specific F-gas: No drop in alternative are existing for the product (impact on energy efficiency & ecodesign) Means that complete installations have to be replaced once restriction is in place and maintenance is needed Substitution ofPFAS in specific use case, will be challenging: Strong increasing market due to push towards climate neutrality Push to PFAS as cooling/heating gas through the F-gas regulation Product design has to comply with multiple regulatory frameworks (eco-design/ESPR) Timeline from design to product on the market is challenging: Impossible to achieve in a short time frame for large existing product portfolio: Push from F-gas regulation to lower GWP gasses (typical PFAS) and huge jump in short time to complete phase out due to restriction ! Potential impact on decarbonization targets due to potential negative impact on availability of certain products 4 MF 1.AGORIA PFAS: cooling& heatingapplications Potential emissions covered through stringent regulation on emissions ofF-gasses Only certified installers are allowed for maintenance, repair, ... Obligation of regular maintenance in order to avoid leakages Multiple leakage tests: during manufacturing, installation, etc... End-of-life F-gas/PFAS: Legal obligation to evacuate F-Gas at the end-of-life Recycling route (linked to purity): limiting the amount of new F-gasses put on the market= will be impossible through the restriction !!!! Destruction by incineration at high temperature in order to avoid negative impact on greenhouse gas effect = destruction PFAS Use of PFAS as F-gas should remain to be regulated through the F-gas regulation with a gradual phasing out: If under universal restriction proposal, need for a time-limited derogation (incl. review clause in line with FGas regulation) of the use of PFAS in cooling/ heating equipment 5 kl.AGORIA PFAS: sealing/gaskets/filters ... What is the issue? Due to technical features PFAS are used in multiple applications such as sealings, gaskets, filters, ... Substitution is mostly not straightforward and will have multiple undesired effects Leakage of hazardous substances, environmental impact, complete redesign of products, .... Products are designed takinginto account the characteristics ofthe PFAS containing sealing, gasket, filters,...: No drop in substitutes available = huge issue for maintenance, repair which is done on regular basis Substitution: Most products/installations have a long life time with regular maintenance & repair No maintenance/repair possible with original part = scrapping of product/installation = huge costs Substitution in filters will lead to unwanted effects: increased environmental pollution (BAT!) In almost all cases where PFAS is used for its technical performance: to date no known substitute is available --other applications are substituted (PFAS = higher cost) Timeline: lots ofuncertainties with other regulatory challenges such as ESPR/IED/... 6 kg .AGORIA PFAS: sealing/gaskets/filters ... Emissions During the production of the sealing/gasket/filter/..: emissions should be regulated through IED Typical no emissions during the integration & use phase End-of-life phase-- more complex situation/dependingon type ofproduct: Products falling under take-back obligations: Metallic recycling --mostly at high temperature = destruction of PFAS Plastic recycling-- mostly mechanical = problem with low concentration values for plastic recycling Recycling obligations (metallic & plastic fraction) Other products = industrial waste mostly with dedicated waste treatment Need for a proper exemption for use ofPFAS sealing/gaskets/filters in which the PFAS gives a specific properties: Dealing with corrosive substances, high fluctuating temperature, pressure, dust, water, oil, polluting substances, .... How to define this exemption properly? 7 al.AGORIA PFAS: batteries (binders) What is the issue? In batteries (cells) PFAS (fluoropolymers) are typical used as a binder Needed for the good functioning of the battery providing the properties of PFAS (e.g. heat resistance) Substitution: Challenging as PFAS provides specific functionalities for a higher efficiency to multiple batteries chemistries To date no real substitutes are know Timeline: lots ofuncertainties with challenges for testing,requalification,supply chain issues.... 8 a I .AGORIA PFAS: batteries (binders) Emissions During the production of the battery & application of PFAS: IED Once the battery is sealed: under normal conditions no PFAS (or other material) is released during the use-phase End-of-life phase - products falling under take-back obligations: Repair: how to deal with the complexity of battery packs with PFAS and repair once restriction is in place Re-use/remanufacturing: in principle with complete modules --no changes to the battery cell ST no emissions of PFAS to be expected-- not clear whether this will be possible with a PFAS restriction? Recycling--first step is dismantling (under development): always need for proper protection measures to avoid emissions (exposure) to PFAS and other hazardous materials Metal recycling: PyrometalIurgy -- high temperature recycling with destruction of PFAS HydrometalIurgy -- not clear Need for an exemption for the use ofPFAS as binder material in batteries 9 I .AGORIA Conclusions to date High uncertainties ofimpact ofthe PFAS restriction in multiple applications: Alternatives for several applications are not available to date Important impact on the circular economy: life-time extension (maintenance, repair, re-use, reman) + recycling Development to market will take several years Multiple crucial applications remain under the radar Need for proper derogations & exemptions General for the circular economy (life-time extension & recycling) Identified applications: derogation for avoiding double regulation & exemptions with proper timeline -13,5 years + review in 6,5 years to provide enough time for R&D on substitution (availability, technical feasibility, impact on energy efficiency, environment, etc...) No general process for exemption/derogation within REACH restriction process Important to integrate and avoid blanket restriction with huge effects on multiple Belgian companies 10 I .AGORIA How to avoid unwanted side effects? No general process for exemption/derogation within REACH restriction process Important to integrate and avoid blanket restriction with huge side effects Multiple contributions already with a link to the technological industry: Orgalim, Digital Europe, Recharge, EPEE, Applia, EISA, .... Including several impacted companies To date > 3.5oo comments (> so.000 pages ) already available & uploaded duringthe consultation and multiple yet to be (incl. Agoria) ...: Multiple questions for derogations/exemptions for specific use cases ... HOW WILL BE RESPONDED TO THOSE MULTIPLE QUESTIONS FOR DEROGATIONS/EXEMPTIONS ? 11 Thankyou Foryourattention Embracing technology Embracing ambition .AGORIA