Document B8oM4LZ3xjbBxG0y3DJX0V26o
Krkkinen Pauli (Tukes)
Lhettj: Lhetetty: Vastaanottaja: Kopio: Aihe:
Krkkinen Pauli (Tukes) perjantai 1. joulukuuta 2023 17.48 Max Drummond; Risnen Jouni (Tukes) Marie Gorkem; Maria Morera VS: Daikin - PFAS restriction proposal - Meeting request
Reg. no. Tukes 12807/04.00.00/2023
Dear Mr. Drummond,
thank you for contacting the Finnish Safety and Chemicals Agency (Tukes) and for your request for a meeting to discuss the restriction proposals for all per- and polyfluoroalkyl substances (PFASs).
We understand your concern and consider that stakeholder input and use-specific information is important for the regulatory process and outcome. As Tukes cannot affect to the proposal at this stage of the process, we advise you to use the formal mechanism for consulting stakeholders in order to make the information available for all the relevant bodies in a timely and effective manner. In order to do this, you can contribute to the consultation for the SEAC draft opinion. Please follow the ECHA websites at https://echa.europa.eu/fi/restrictions-under-consideration//substance-rev/72301/term for further details and information about the deadlines.
However, also the Finnish authorities will participate the decision-making process and will take a stance on the
proposed restriction at a later stage. Ministry of Social Affairs and Health is representing Finland in the REACH
Committee. If considered necessary, you can contact ministerial adviser Ms. Hanna Korhonen
(
@gov.fi) regarding this topic.
Best regards, Pauli Krkkinen Ryhmpllikk, Teollisuus- ja kuluttajakemikaalit I Head of Unit, Industrial and consumer chemicals
Turvallisuus- ja kemikaalivirasto (Tukes) I Finnish Safety and Chemicals Agency PL 66 (Opastinsilta 12 B), FI-00521 Helsinki, FINLAND Puh. 029 5052 074 I Tel. pauli.karkkainen (at) tukes.fi
Lhettj: Max Drummond <
@kreab.com>
Lhetetty: torstai 30. marraskuuta 2023 11.09
Vastaanottaja: Krkkinen Pauli (Tukes) <
@tukes.fi>; Risnen Jouni (Tukes)
@tukes.fi>
Kopio: Marie Gorkem <
@kreab.com>; Maria Morera <
@kreab.com>
Aihe: Daikin - PFAS restriction proposal - Meeting request
Dear Mr Krkkinen, dear Mr Risnen,
We are writing to you on behalf of Daikin, producer; of fluorochemicals, air conditioning and refrigeration equipment. AS you may recall, my former colleague Jurgita Skritaite was in contact with you in June regarding the possibility of a meeting on PFHxA. We are now reaching out to you regarding the possibility of a meeting on the restriction proposal of PFAS substances under the REACH Regulation.
In light of the concerns raised regarding the very large scope of the proposal for a restriction of PFAS substances and the resources and time required at ECHA to evaluate the public consultation, we would be pleased to share with you
our thoughts on an overall approach that could be taken, such as a more limited scope or stepwise approach, and the implementation of responsible manufacturing principles. On the latter, Daikin would be pleased to share with you its plan to phase out the use of a fluorinated polymerisation aid at its fluoroelastomer (sub-group of fluoropolymers) production plant in France. We would propose to hold such a meeting from December onwards and would be happy to send you or receive some proposed dates. We thank you in advance for your consideration and look forward to hearing from you. With kind regards, Max Drummond
KREAB
WORLDWIDE Max Drummond Associate 2/4, Rond-Point Schuman, BE-1040 Brussels, Belgium Mob
@kreab.com www.kreab.com
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