Document BRb4BDG9vN9qzxRzL1xmonVLk

CEIR CEIR Answer to Echa consultation on PFAS restriction: Annex Question 7. Potential derogations marked for reconsideration - Analysis of alternatives and socio-economic analysis: Paragraphs 5 and 6 of the proposed restriction entry text (see table starting on page 4 of the summary of the Annex XV restriction report) include several potential derogations for reconsideration after the consultation (in [square brackets]). These are uses of PFAS where the evidence underlying the assessment of the substitution potential was weak. The substitution potential is determined on the basis of i) whether technically and economically feasible alternatives have already been identified or alternative-based products are available on the market at the assumed entry into force of the proposed restriction, ii) whether known alternatives can be implemented before the transition period ends (taking into account time requirements for substitution and certification or regulatory approval), and iii) whether known alternatives are available in sufficient quantities on the market at the assumed entry into force to allow affected companies to substitute. A summary of the available evidence as well as the key aspects based on which a derogation is potentially warranted are presented in Table 8 in the Annex XV restriction report, with further details being provided in the respective sections in Annex E. To strengthen the justifications for a derogation for these uses, additional specific Application (no finished list) Valves in Oil and Gas Industry Valves in food industry Valves in other industries Use Gaskets, seals, wear parts in hydrocarbon upstream, midstream and downstream. Fastener coatings in offshore applications Coatings, seals, Seals, gaskets, diaphragms, cables, coatings, wear parts, bearings, ... Property PFAS Resistance against hydrocarbons Temperature resistance Low coefficient of friction Corrosion resistance and anti-galling properties Non-sticking properties Resistance against aggressive cleaning chemicals Resistance against chemicals, temperature, weather, or a combination thereof. Safety. FKM, FFKM PTFE, ETFE PTFE, PFA, FKM PTFE - Mining industry - Drinking water Sanitary faucets in private and public use Seals, gaskets, diaphragms, cables, coatings, wear parts, bearings, ... Sanitary faucets in private and public use - high performance lubrification grease High performance lubrification grease Use due to tribological functionality. energy efficiency, duration, safety Use due to hygienic aspects. health Use due to tribological functionality. energy efficiency, longevity, duration, sustainability Use due to tribological functionality. Low coefficient of friction energy efficiency, longevity, duration, sustainability FKM FFKM FPE (PFPE) ETFE ECTFE PVDF PFA PCTFE PTFE PTFE