Document DMDmne0k4pM9a9vVZ7YBqkr9d

Annex 3 to Japan 4EE input: Non-Exaustive PFAS Essential Application list A: Explanation starting from PFAS as chemical materials As of 14 June 2023 PFAS classification Fluoropolymers Representative Chemical Materials Ref. No. PTFE 1 PFA FEP ETFE PVDF FKM FFKM FEPM FFKO PFPE PCTFE 2 Intended use in electrical and electronic equipment (EEE) [Derogations for EEE should be set at this level.] Sliding elements in mechanical section Optical element Non-exhaustive examples of uses Plain bearings Conductive plain bearings Sliding parts of various electric components (motors, connectors, switches, etc.) Sliding parts of various mechanical components (bearings, gears, winder, etc.) Fixing and photoconductive components, etc., in printing equipment Optical fiber materials, optical adhesives Reasons why PFASs are un-replaceable Fluoropolymers with multiple functions such as excellent self-lubrication (low coefficient of friction), electrical insulation property, chemical resistance, releasability, heat resistance and flame retardancy are used in sliding elements in mechanical section of EEE and its components to function normally in various environments. The Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT cannot be used as they exibit the worst performance. In addition, some components are required to maintain their indispensable sliding characteristics over a long period of time under severe conditions such as high temperature, high pressure, high voltage, and high friction. Fluoropolymers are the only materials that resist such severe conditions, and substituting other materials is impracticable. Functions of EEE requiring the use of PFAS (Link to Column C of List B (Annex 4)) 4.Sliding function in mechanical section Optical element used in EEE and its components requires fluorine materials with no absorption at specific wavelengths, high weather resistance, and low refractive index. Therefore, it is impossible to substitute to the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT. 1.Optical function 3 Piezoelectric elements 4 Insulating material requiring flame-retardancy and/or heat-resistant, where the use is needed for safe functioning and safety of equipment Piezoelectric elements pressure sensitive films, speakers, microphones, piezo pickups for acoustic guitar PVDF and its copolymers with unique dielectric and piezoelectric properties, which are also excellent in durability, electrical insulation property, and heat resistance are used in piezoelectric elements used in EEE and its components. Therefore, it is impossible to substitute to the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT. 3.Piezoelectric function Cables, heat insulator Insulating material used for product safety of EEE and its components requires multiple functions of fluoropolymers such as electrical insulation property, heat resistance, flame retardancy, and durability. Therefore, product safety of EEE and its components cannot be guaranteed if the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT are used singly or in combination. 6.Safety and safety functions Functions of EEE requiring the use of PFAS (Link to Column G of List B (Annex 4)) Motor, Printer, Industrial equipment, Camera All the EEE in RoHS categories 1- 11 would need this function. Corresponding question and related derogation proposal in the dossier Question 8 (Electronics); related derogation is not proposed. Camera, Lighting, Monitor/Panel, Optical cable, Smartphone Other products in RoHS categories 1- 11 would need this function if they use optical function in control panels for example. Touch panel, Speaker, Various sensor Other products in RoHS categories 1- 11 would need this function if they use touch panels or sounds for example. Question(Electronics); related derogation is not proposed. Question 8 (Electronics); related derogation is not proposed. Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment All the EEE in RoHS categories 1- 11 would need this function. Question(Electronics); related derogation is not proposed. 5 LCD panels 6 Electronic circuit board Anti-fingerprint layer on panel surface and unti reflection (high light transmittance) layer The fluoropolymer on the panel surface has a refractive index of 1.3, which is almost half the refractive index of 1.0 for air and 1.5 for TAC film of the polarizer, and suppresses surface reflection. This translates to a 3% increase in backlight utilization efficiency (i.e. energy efficiency). In addition, since the visibility of the panel is improved by preventing fingerprint stains on the surface, the brightness of the panel can be reduced. Only fluoropolymer has the above properties. It cannot be substituted with silicone or other resins that are considered substitutes. 1.Optical function Electronic substrate materials Electronic circuit board used in high-frequency applications requires low dielectric constant and low transmission loss. Additionally it needs functions such as electrical insulation property, high water and oil-repellent propertythermal and flame resistance. Fluoropolymers are the only materials that have those multiple functions, therefore it is impossible to substitute to other materials. 2.High speed communication and transmission function 7 Anti-dripping agent used for safety and to enhance flame Anti-dripping agent to enhance flame retardancy PTFE is used as anti-dripping agent to enhance flame retardancy, as it is flame-retardant and has an extremely high melt viscosity. Product safety 6.Safety and safety functions retardancy of EEE and its components cannot be guaranteed if the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT are used singly or in combination. Camera, Lighting, Monitor/Panel, Optical cable, Smartphone Other products in RoHS categories 1- 11 would need this function if they use optical function in control panels for example. Question 8 (Electronics); related derogation is not proposed. Smartphone, PC, Antenna, Base stations Other products in RoHS categories 1- 11 would need this function if they use communication function to operate or update it for example. Question(Electronics); related derogation is not proposed. Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment All the EEE in RoHS categories 1- 11 would need this function. Question 8 (Electronics); related derogation is not proposed. 8 High performance materials for mold release and Developer additives and resin additives used in Fluorine compounds such as PFAS are the only materials that can simultaneously provide and exhibit multiple functions, such as low dielectric 4.Sliding function in mechanical section protection purposes used in the article molding process electrical and electronics manufacturing constant, low dielectric loss tangent, low refractive index, oil repellency, electrical insulation, water repellency, heat resistance, chemical resistance, 6.Safety and safety functions processes weather resistance, mold releasability, flame resistance, separability, wear resistance, surface properties (friction coefficient), bending strength, 7.Functional surface stretching properties, non-flammability, etc. which are necessary for electrical and electronic devices as well as manufacturing equipment of Coating material (use as mold release agent) components for such devices to function normally under various environments, making substitution by other materials described in dossier extremely difficult. Motor, Printer, Industrial equipment, Camera Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment, Cooking appliance, Touch panel, Smartphone All the EEE in RoHS categories 1- 11 would need this function. Question 8 (Electronics); related derogation is not proposed. 9 Batteries Battery materials Please refer to the relevant industry association's comments for details on the reasons why substitution is not possible. For example, RECHARGE, the rechargeable and lithium batteries association in Europe. For example, RECHARGE, the rechargeable and lithium batteries association in Europe have submitted the comment on this dossier (The first input was 21 April 2023) 10.Energy supply (Battery) 10 Film, sheet, membrane requiring surface performance Film material, electrostatic adsorption belt, Waste Powder Collection Filter, Friction Reduction Tape, peeling tape, ventilation film, moisture permeable film, Dial (Polarizing plate, plastic raw material), protective film, release sheet Films for analytical testing Multiple functions such as electrical insulation property, chemical resistance, heat resistance, flame resistance, flex resistance and excellent elongation followability are also required for films, sheets, and membranes that require performance based on low surface free energy (water repellency, oil repellency, lubrication, non-adhesiveness) used in the facilities for manufacturing EEE and its components. Fluoropolymers are the only materials that have those multiple functions at the same time, therefore it is impossible to substitute to other materials. 6.Safety and safety functions 7.Functional surface 11 Hermetic sealant Gasket materials, sealing materials, rubber valves (umbrella valves, duckbill valves, etc.), four-way reversing valve, check valve, ball valve, O rings, buttons on the operating unit, sealing materials and tube element for various electronic component The compression set of a material is the permanent deformation remaining after removal of a force that was applied to it. The percentage of the compression set of hermetic sealant used in the facilities for manufacturing EEE and its components to function normally in various environments must be low. And at the same time, sealant as EEE parts needs other functions such as excellent elongation followability, durability, flame resistance, heat and hot water resistance, low water absorption, low moisture permeability, chemical resistance (including resistance to chlorine contained in tap water), low outgassing (to avoid contamination of impurities and to maintain the vacuum of instrument) . Fluoropolymers are the only materials that have those multiple functions at the same time. If the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT are used singly or in combination, the worst performance is exhibited. Therefore, it is impossible to substitute to those alternatives. 4.Sliding function in mechanical section Battery All the EEE in RoHS categories 1- 11 would use batteries. Question 8 (Energy) ; related derogation is not proposed. Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment Cooking appliance, Touch panel, Smartphone All the EEE in RoHS categories 1- 11 would need this function. Question; Similar a little to 5.cc, 5.ee, 6.m Motor, Printer, Industrial equipment, Camera, Display All the EEE in RoHS categories 1- 11 would need this function. Question 8 (Electronics); Similar to 6.a. 12 Fluid tubes and containers requiring chemical resistance, Chemical supply tubes, high cleanliness Tube for flow path of analytical equipment Air tubes used in air piping, etc. tube for a chemical supply system chemical-resistant containers Fluoropolymers with multiple functions such as chemical resistance, excellent fluid barrier properties, high cleanliness and low surface tension are used for fluid tubes and containers in the facilities for manufacturing EEE and its components. If the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT are used singly or in combination, the worst performance is exibited. Therefore, it is impossibe to substitute to those alternatives. 6.Safety and safety functions 13 PFAS used for semiconductor manufacturing process, Construction of polymer substrates and Fluorine compounds such as PFAS are the only materials that can simultaneously provide and exhibit multiple functions, such as low dielectric 8.Semiconductor semiconductor manufacturing equipment, and dielectric materials, manufacturing equipment constant, low dielectric loss tangent, low refractive index, oil repellency, electrical insulation, water repellency, heat resistance, chemical resistance, semiconductor for adhesives, underfills, filter, die bond resins, weather resistance, mold releasability, flame resistance, separability, wear resistance, surface properties (friction coefficient), bending strength, valve seals, etc., heat transfer fluids stretching properties, non-flammability, etc. which are necessary for semiconductor manufacturing processes, semiconductor manufacturing surface protection equipment and semiconductors to function normally under various environments, making substitution by other materials described in dossier extremely difficult. Additionally, for more information on why PFAS cannot be substituted in semiconductors, please refer to information from the Semiconductor Industry Association. For example, the following information from SIA PFAS Consortium of the Semiconductor Industry Association of America: "The Impact of a Potential PFAS Restriction on the Semiconductor Sector2" https://www.semiconductors.org/wp-content/uploads/2023/04/Impact-of-a-Potential-PFAS-Restriction-on-the-Semiconductor-Sector- 04_14_2023.pdf Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment All the EEE in RoHS categories 1- 11 would need this function. Question(Electronics); Similar a little to 6.c. Semiconductor All the EEE in RoHS categories 1- 11 would use semiconductors. Question 7; Similar to 5.ee 14 PFAS used for thin-film deivice (Micro Electro Construction of polymer substrates and Fluorine compounds such as PFAS are the only materials that can simultaneously provide and exhibit multiple functions, such as low dielectric 9.Thin-film device manufacturing process Car navigation system, Sphygmomanometer (blood pressure Mechanical System/MEMS, SAW device, etc) dielectric materials, manufacturing equipment constant, low dielectric loss tangent, low refractive index, oil repellency, electrical insulation, water repellency, heat resistance, chemical resistance, meters), Inkjet printer, Smartphone manufacturing process, thin-film deivice manufacturing for adhesives, underfills, filter, die bond resins, weather resistance, mold releasability, flame resistance, separability, wear resistance, surface properties (friction coefficient), bending strength, equipment, and thin-film deivice valve seals, etc., heat transfer fluids stretching properties, non-flammability, etc. which are necessary for thin-film device(Micro Electro Mechanical Systems/MEMS, SAW etc) Other products in RoHS categories 1- 11 may use thin-film surface protection manufacturing processes, thin-film device manufacturing equipment and thin-film device to function normally under various environments, making devices substitution by other materials described in dossier extremely difficult. Additionally, for more information on why PFAS cannot be substituted in thin-film devices, please refer to information from the Semiconductor Industry Association. For example, the following information from SIA PFAS Consortium of the Semiconductor Industry Association of America: "The Impact of a Potential PFAS Restriction on the Semiconductor Sector2" https://www.semiconductors.org/wp-content/uploads/2023/04/Impact-of-a-Potential-PFAS-Restriction-on-the-Semiconductor-Sector- 04_14_2023.pdf Question 7; related derogation is not proposed, but similar to 5.ee. 15 Functional material used in printing process Fluoroalkyl compounds with functional PFHxA, PFBA, 16 groups (such as -OH, -COOH, N-R, etc.) and Side-chain fluorinated polymers PFBS, Polyfluoroalkyl (meth)acrylate Mold release, protection Toner additives, Ink additives, Developer additives Resistive/Conductive Paste, Mold release agent, Antistatic agent, Solder flux, flame retardant Printing process need various functions such as electrical insulation, water repellency, oil repellency, chemical resistance, ase, surface activity, low surface tension, and high negative charge. These functions are achieved by adding fluorinated materials to toner, ink, developers, organic photoconductors etc. Only fluorinated-based materials can achieve above functions simaltaneously. It is impossible to achieve this with alternative materials in the dossier. Materials such as "Printing inks/Toner" used in "printing process". These would be separately covered by stakeholders such as printing industry, therefore our current Application list B (Annex 4) does not cover them. For the details on chemicals used in printing process, please see the input from the related industries. For ink and tonar: Question 6 (printing ink)/ for others: Question 8 (Electronics); related derogation is not proposed. Fluorine compounds such as PFAS are the only materials that can simultaneously provide and exhibit multiple functions, such as electrical insulation, heat resistance, chemical resistance, flame resistance, etc. which are necessary for electrical and electronic devices as well as manufacturing equipment of components for such devices to function normally under various environments, making substitution by other materials desctibed in Dossie extremely difficult. 6.Safety and safety functions 7.Functional surface Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment Cooking appliance, Touch panel, Smartphone All the EEE in RoHS categories 1- 11 would need this function. Question(Electronics) ; related derogation is not proposed. Fluoroalkanes and fluoroalkenes, and Fluoroethers and fluoro-ketones HFC, PFC, HFO, HFE 17 Semicondutor manufacturing process Photoacid generator Photoresist Various materials have been considered for the photoacid generators and photoresist needed for the semiconductor manufacturing process, but in the end only fluorine materials remained and are currently used. The alternative materials described in Dossier have been studied in the past and when they are used, their performance is poor and they are not practical. Additionally, for more information on why PFAS cannot be substituted in thin-film devices, please refer to information from the Semiconductor Industry Association. For example, the following information from SIA PFAS Consortium of the Semiconductor Industry Association of America: "The Impact of a Potential PFAS Restriction on the Semiconductor Sector" https://www.semiconductors.org/the-impact-of-a-potential-pfas-restriction-on-the-semiconductor-sector/ 8.Semiconductor Semiconductor All the EEE in RoHS categories 1- 11 would use semiconductors. 18 Thin-film device (Micro Electro Mechanical Systems/MEMS, SAW etc) manufacturing process Photoacid generator Photoresist The thin-film device (MEMS(Micro Electro Mechanical Systems), SAW, etc.) manufacturing process, which started by making mechanical components using semiconductor manufacturing technology, uses fluorinated materials for photoacid generators and photoresist for the same reason as the semiconductor manufacturing process. The alternative materials described in Dossier have been studied in the past and when they are used, their performance is poor and they are not practical. For more information on the reasons, please refer to information from the Semiconductor Industry Association. For example, the following information from SIA PFAS Consortium of the Semiconductor Industry Association of America: "The Impact of a Potential PFAS Restriction on the Semiconductor Sector" https://www.semiconductors.org/the-impact-of-a-potential-pfas-restriction-on-the-semiconductor-sector/ 9.Thin-film device manufacturing process Car navigation system, Sphygmomanometer (blood pressure meters), Inkjet printer, Smartphone Other products in RoHS categories 1- 11 may use thin-film devices 19 Functional material used in printing process Toner additives, Ink additives, Resin additives, Developer additives, Organic photoconductor additives Printing process need various functions such as water repellency, oil repellency, chemical resistance, releasability, surface activity, flame resistance (anti-drip function), low surface tension, and high negative charge. These functions are achieved by adding fluorinated materials to toner, ink, resin, developers, organic photoconductors etc. Only fluorinated-based materials can achieve above functions simaltaneously. It is impossible to achieve this with alternative materials in the dossier. Materials such as "Printing inks/Toner" used in "printing process". These would be separately covered by stakeholders such as printing industry, therefore our current Application list B (Annex 4) does not cover them. For the details on chemicals used in printing process, please see the input from the related industries. 20 Refrigerant used in various heat exchangers Refrigerant used in various heat exchangers 21 Refrigerant, coolant, cleaning agent and solvent used for Cooling of manufacturing equipment semiconductor process Fluorine-based refrigerant has excellent thermodynamic properties in a wide range and is also excellent in temperature followability. Moreover, because of its low flammability and low toxicity, it does not ignite the surroundings or cause harm to the human body, even if equipment or pipes are damaged by an earthquake or storm and then the refrigerant leaks. Natural refrigerants cannot ensure safety in emergencies as they are flammable and toxic. Please refer to the comments of the relevant industry associations for details on why fluorine-based coolants cannot be substituted. 11.Cooling function (Refrigerant) Fluorinated compounds such as PFAS are the only media that can be used over a wide range of operating temperatures for safe and efficient heat transfer, while simultaneously possessing excellent properties such as electrical insulation, inertness, and extremely low surface tension, along with excellent thermodynamic properties, making substitution by other materials extremely difficult. For more details on why fluorinated coolants cannot be substituted in semiconductor processes other than etching, please refer to the comments of the relevant industry associations. 8.Semiconductor Refrigerant All the EEE in RoHS categories 1- 11 may use refrigerant if needed. Semiconductor All the EEE in RoHS categories 1- 11 would use semiconductors. Question 7; Similar to 5.ee If proposed PFAS restriction covers also PFHxA, at least following derogation proposed in the final SEAC Opinion on PFHxA should be incorporated : "7. Paragraphs 1 and 2 shall not apply until XX XX XXXX [12 years after the entry into force] to: (b) semiconductors and semiconductor related equipment" Question 7; related derogation is not proposed, but similar to 5.ee. For ink and tonar: Question 6 (printing ink)/ for others: Question 8 (Electronics); related derogation is not proposed. Question 7 (F-Gas); Similar to 5.i, 5.j, 5.p, 5.q, 5.dd, 5.ee Question 7 (F-Gas); 5.ee 22 Refrigerant, coolant, cleaning agent and solvent used for Cooling of manufacturing equipment thin-film device (Micro Electro Mechanical Systems/MEMS, SAW etc) process Fluorinated compounds such as PFAS are the only media that can be used over a wide range of operating temperatures for safe and efficient heat transfer, while simultaneously possessing excellent properties such as electrical insulation, inertness, and extremely low surface tension, along with excellent thermodynamic properties, making substitution by other materials extremely difficult. For more details on why fluorinated coolants cannot be substituted in thin-fim device processes other than etching, please refer to the comments of the relevant industry associations. A similar exemption to Exemption 5.ee is needed for the thin-film device manufacturing process, since the thin-film device manufacturing process uses the same materials and technologies as the semiconductor manufacturing process. 9.Thin-film device manufacturing process Car navigation system, Sphygmomanometer (blood pressure meters), Inkjet printer, Smartphone Other products in RoHS categories 1- 11 may use thin-film devices Question 7 (F-Gas); related derogation is not proposed, but very similar to 5.ee. 23 Chemicals for ultra-fine processing applications, as Etching gas for semiconductor and glass typified by semiconductor and MEMS manufacturing substrates processes Equipment such as etching equipment/CVD *HFC-23 (CHF 3) HFC-32 (CH 2 F 2) HFC-152 a equipment (CHF 2-CH 3) HCFC-141 b (CCl 2 F-CH 3) HFO-1132 a (CH 2=CF 2) are outside the scope definition of this Substrate cleaning gas regulation (from Annex A Appendix A .3 .9 Applications of Fluorinated Gases). Minor uses; In the electronics and semiconductor industries, fluorinated gases are used in etching and chamber cleaning processes to form nano- level fine semiconductor integrated circuits, etc., including CHF 3, CF 4, perfluoroethane, perfluoroalkane, and cycloalkane (Annex A A.3.9.1.7) In the semiconductor industry, perfluorogas and polyfluorogas are used in etching and chamber cleaning processes to form nano-level fine semiconductor integrated circuits etc.. Although the amount used is small, today's electronics products require extremely complicated and delicate processing to realize various functions such as high performance, multi-function, and low power consumption. To achieve this, we combine various gases to perform processing with advanced and delicate control. There is no substitute for the gas currently in use in the semiconductor manufacturing process, which is highly and finely assembled. If its use is prohibited, all semiconductor manufacturing will be stopped. The semiconductor industry controls the chemical substances used at all stages of the manufacturing process. Most of the chemical substances used are decomposed during the manufacturing process, and equipment is installed to decompose and recover unreacted residual gases in order to reduce emissions. The continued use of PFAS in the semiconductor manufacturing process is an essential component of the supply of electronics products that support wide range of current and future daily necessities and social infrastructure and is a fundamental prerequisite for semiconductor production. For this reason, it is considered essential to exempt semiconductor manufacturing, the semiconductor itself, and related equipment from the scope of regulation as essential use. PFAS gases are always stable, easy to handle, and very reactive with the material to be etched (such as semiconductor or glass substrates) in reactive ion etching (RIE). Moreover, only fluorinated compounds such as PFAS gases can etch Si, and other materials gases have high volatility (high vapor pressure) of reaction products (such as SiF4), making it difficult to substitute them. 8.Semiconductor 9.Thin-film device manufacturing process Semiconductor Car navigation system, Sphygmomanometer (blood pressure meters), Inkjet printer, Smartphone All the EEE in RoHS categories 1- 11 would use semiconductors. Other products in RoHS categories 1- 11 may use thin-film device. Question 7 (F-Gas); For semiconductor, 5.ee. For thin-film devices, related derogation is not proposed, but very similar to 5.ee. Others (PFAS other than ones mentioned above) 24 Fluids for immersion processes (testing, measuring or Test solvent for gross leak test, etc., high- Fluorinated compounds are the only media that can maintain the quality of an object without leaving stress or contamination on the object in the Though current Application List B (Annex 4) Car navigation system, Sphygmomanometer (blood pressure adding function) in production processes and laboratorirs precision temperature characteristic process due to their extremely low surface tension and high volatility. does not describe about this application, we meters), Inkjet printer, Smartphone. measurement, and voltage application medium Furthermore, fluorinated compounds simultaneously possess excellent functions such as excellent thermodynamic properties, electrical insulation, will give explanation for it in our later input. Other products in RoHS categories 1- 11. for polarization of piezoelectric ceramic and inactivity, which ensure the stability and accuracy required in the process. elements The MIL standard (MIL-STD-883/750) specifies the use of hollow packages in airtight testing, which is essential to ensure their airtight performance. Therefore, it is difficult to substitute other substances. Fluorinated 25 engineering plastic materials such as fluorinated polyimide and Liquid crystal materials. Ocothmeprofulunodrsinated 26 Transparent electronic circuit board and circuit Liquid crystal display element (LCD) Transparent printed circuit board for touch panels Fluorinated polyimide has transparency, heat resistance, and low water absorption required for touch panels used in smartphones and tablets. The high water absorbency of transparent heat-resistant plastic (polyether sulfone) reduces low dimensional stability and impairs the linearity of touch panels, so it cannot be used. 1.Optical function vertical alignment liquid crystal display device Interlayer spacer to control the cell gap of LCD panels. Liquid crystal materials (small molecules) Fluorinated polyimides with long-chain fluorinated alkyl groups in the side chains have high heat resistance and stable orientation over a wide temperature range. This cannot be replaced by polyimides with hydrocarbon side chains. The structural materials for maintaining uniform cell gap of a large-sized liquid crystal panel are required to have leveling properties, no contamination of the optical system in the manufactureing process, chemical resistance, and heat resistance at the same time. These are not able to be replaced by silicone or acrylic resin. Fluorinatad Liquid Crystal materials have low-voltage driving, high-speed responce, and low temperature dependence of drive voltage, which are required for low power consumption video displays requireing multiple functions simultaneously. Cyano-based crystal materials do not meet those properties at the same time. 5.Display function(Liquid crystal display / LCD) Camera, Lighting, Monitor/Panel, Optical cable, Smartphone Other products in RoHS categories 1- 11 would need this function if they use optical function in control panels for example. Liquid crystal display panel (TV, Monitor for various device) Other products in RoHS categories 1- 11 would need this function if they use control panels or monitors for example. Question 8 (Electronics); related derogation is not proposed. Question 8 (Electronics); related derogation is not proposed. Question(Electronics); related derogation is not proposed. 27 Optical element Additives for polyamideimides, polyimides, and polyester tapes By introducing a trifluoromethyl group or the like into the polyimide, low refractive index, low dielectric constant, separation, light transmission, and flexibility can be imparted. In this way, the fluorinated material introduced with fluorine as a substituent in the engineer plastic material has excellent electrical properties, water and oil-repellency, surfactant resistance, flame retardancy (anti-drip function), low surface tension It can simultaneously impart and express multiple functions, and If the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT are used singly or in combination, the worst performance is exhibited. Therefore, it is impossible to substitute to those alternatives. 1.Optical function Camera, Lighting, Monitor/Panel, Optical cable, Smartphone Other products in RoHS categories 1- 11 would need this function if they use optical function in control panels for example. Question(Electronics); related derogation is not proposed. 28 Functional material used in printing process Toner additives, Ink additives, Developer additives, Organic photoconductor additives Printing process need various functions such as water repellency, oil repellency, chemical resistance, releasability, surface activity, low surface tension, and high negative charge. These functions are achieved by adding fluorinated materials to toner, ink, developers, organic photoconductors etc. Only fluorinated-based materials can achieve above functions simaltaneously. It is impossible to achieve this with alternative materials in the dossier. Materials such as "Printing inks/Toner" used in "printing process". These would be separately covered by stakeholders such as printing industry, therefore our current Application list B (Annex 4) does not cover them. For the details on chemicals used in printing process, please see the input from the related industries. For ink and tonar: Question 6 (printing ink)/ for others: Question 8 (Electronics); related derogation is not proposed. PTFE, PFA, FEP, 29 ETFE, PVDF,PFHxA Polyfluoroalkyl (meth)acrylate All the PFAS (flupropolymers and others) PTFE, PFPE, 30 PFHxA, PFBS Functional coatings* (*. "Functional coating" is a coating applied to an article in order to give it the required functions, as illustrated in the right cell (En). "Functional coating" includes, but not limited to, "conformal coating" used to protect electronic materials. In our response, we use the term "functional coating" because the required functions are not only to protect the objects.) Electronic circuit boards, semiconductors, small electronic components (e.g. capacitors, resistors, coils, diodes, transistors, switches, connectors and their electrical junction points), casing, motors, voice coils, parts to protect optical features (e.g. liquid crystal panels, touch panels, optical sensors, LED, Toslink, optical fibers, lenses for electronic cameras, projection lenses, polarizers), printing process (Toner/ink adhesion prevention, toner/developing carrier themselves), oil barrier, fan, and so on. Fluorine compounds are the only coating materials that can simultaneously provide and express multiple functions required for the proper functioning of electrical and electronic equipment in various environments, such as low refractive index, low dielectric constant and low dielectric loss tangent, electrical insulation, oil repellency, water repellency, heat resistance, chemical resistance, weather resistance, mold release and optical protection (i.e. for optical sensors, lenses and so on). In addition to the above, toner/development carriers are also required to be fluidity, charging characteristics, and durability. 1.Optical function 2.High speed communication and transmission function 4.Sliding function in mechanical section 6.Safety and safety functions 7.Functional surface Lubricants where the use takes place under harsh conditions or the use is needed for safe and intended functioning and/or safety of equipment Electronic cameras, lens systems for electronic cameras, moving parts of the helicoid of projection lenses and moving ball frames, driving parts of ultrasonic testing equipment, drives for optical discs, torque limiters for scanners and other moving parts of precision equipment in electrical and electronic equipment. To protect the mechanical properties of the moving parts of precision components in electrical and electronic equipment, the lubricant (e.g. grease) is given a autophobic property to prevent wetting and spreading. If the lubricating components applied to the operating parts of precision components become wetted and diffuse, the durability and performance of the product will be significantly reduced. To prevent this, fluorine compounds are added which have good dispersibility in lubricants (e.g. grease) and can provide oil repellency due to their self-hydrophobic properties. Only fluorine compounds with low surface free energy can provide oil repellency and are difficult to replace. In addition, due to the recent miniaturisation and high integration of components, it is difficult to avoid them due to the structure of the components. 4.Sliding function in mechanical section 6.Safety and safety functions Camera, Lighting, Monitor/Panel, Optical cable, Smartphone, PC, Antenna, Base stations Motor, Printer, Industrial equipment, Cable, Medical equipment, Electric appliance, Industrial control equipment, Cooking appliance, Touch panel, All the EEE in RoHS categories 1- 11 would need this function. Question 8 (Electronics); related derogation is not proposed. If proposed PFAS restriction covers also PFHxA, at least following derogation proposed in the final SEAC Opinion on PFHxA should be incorporated : "13. Paragraphs 1 and 2 shall not apply to functional coating used in electrical and electronic equipment until XX XX XXXX [7 years after entry into force]." Motor, Printer, Industrial equipment, Camera, Cable, Monitor, Medical equipment, Electric appliance, Industrial control equipment All the EEE in RoHS categories 1- 11 would need this function. Question(lubricant) ; related derogation is not proposed.