Document DMZE6pqDz0nZmgx23qMwgJY4Q
- Ref. Ares(2022)557 8121 - 04/08/2022
From: Sent: To: Cc:
Subject:
Attachments:
@kreab.com> vendredi 3 juin 2022 10:25
(GROW) (GROW);-- (GROW); (GROW);__;__; __ Archroma Letter/ C6 transported intermediates under PFOA POP regulation & C9-C14 REACH restriction Archroma-Letter_DG GROW_C6 transported intermediates.pdf; CONFIDENTIAL_C6 telomer products line_Archroma_June2022.pdf
Dea ..... ,
We're writing to you on behalf of Archroma, producer of speciality chemicals and notably the only European producer of C6 fluorinated telomer products, a sub-category of PFAS. Archroma's product ion facility is located in Germany (Gendorf, Bavaria) . As only European producer, Archroma has been regularly in contact with your colleagues, each time Archroma needed to raise specificities inherent to its production process. This, with the objective to allow continued production of C6 telomer chemistry according to state of the art techniques. The C6 telomer chemistry continues to remain necessary in a number of downstream sectors, as shown by the ongoing discussions on the REACH PFHxA restriction dossier.
Among the specificities inherent to a production process established in the EU, there are in particular the intermediate steps until delivery of "finished" chemical products to customers. In practice, our di alogue at the ti me has led to the definition of thresholds for C6 transported intermediates, which based on the knowledge available to Archroma at the time, seemed suitable.
Through the attached letter, and as already discussed with share with you the concern that
The only solution available to Archroma to reduce the C8 and C9-C14 levels below the thresholds is to
transport these two intermediates to
here the necessary equipment is
available. Our letter includes a proposal to amend the derogation on C6 transported intermediates,
specifically when an additional reduction step is required.
On a more positive note, Archroma would like to propose a -compared to 20 ppm currently in force) for PFOA-related substances in C6 transported intermediates (when no additional reduction treatment is required). This is the result of Archroma's significant investments in its analytical capacities in Gendorf. Similarly, Archroma is working on a lower threshold proposal for C9C14-related substances.
We would be grateful to discuss with you how these concerns and proposals may be taken into account
in the future discussions on the PFOA POP Regulation and the REACH C9-C14 Restriction.
--We thank you in
Kind regards,
advance
for
your
considerati
on
and
look
forward
to
hearing
from
you,
Kreab 2/4, RondPoint Schuman, BE1040 Brussels, Belgium Tel +32 Mob +32
@kreab.com www.kreab.com
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