Document EqxwQ9vkOqng1Mz5qaq4Kozqn

DRAFT MINUTES Meeting: Date & time: Place: Attendance Workplace FPP4EU Collaboration Platform 12 December 2022; 10.00-16.00 CET Hotel Thon EU, Rue de la Loi 75, 1000 Brussels, Belgium Virtual meeting via Microsoft Teams List of attendees on pages 6-9 Link to minutes and presentations is here 1. Welcome and Antitrust Guidelines P. Muoz welcomed the participants of the Collaboration Platform ("the Platform") and reminded them that the meeting should be conducted in respect of the Cefic antitrust guidelines. M. Mensink took the floor to give a welcome message. He underlined the importance of the upcoming wide EU PFAS restriction for future regulations and called on downstream users to bring their data to the table. He stated that collaboration is the only answer to come to a regulatory measure that is workable for all. G. Casella also took the floor to give his welcoming remarks. He highlighted that the European Commission is not yet involved in the PFAS wide restriction and urged participants of the meeting to participate in the upcoming public consultations. Noting the importance of case studies showcasing the different applications of PFAS. 2. Session 1: PFAS wider restriction proposal M. Pauwels gave some information on FPP4EU and started the first panel of the workshop titled `PFAS wider restriction proposal'. EU PFAS restrictions (Martijn Beekman, DG GROW) M. Beekman described process and the relation between PFHxA, PFAS in firefighting foams, the Universal PFAS and other restrictions. He gave an overview of the steps followed under the Stockholm Convention process as well as the PFAS restrictions under REACH. He highlighted the importance of avoiding double regulation and not having a REACH restriction entry if the substance is regulated through the POP (Persistent Organic Pollutant) regulation. M. Beekman also provided an overview of the most important aspects of the upcoming revision of REACH. During the discussion: The question was raised on the way that the universal PFAS restriction will deal with the essential uses concept. M. Beekman responded that the essential uses concept will not be there yet, but in the restriction, there will probably be an assessment of the alternatives where feasible, as well as an economic assessment, comparable with assessments carried out in previous REACH restriction dossiers 1 DRAFT MINUTES Procedure in SEAC and involvement of relevant stakeholders (Michael Gmeinder, ECHA) M. Gmeinder gave a presentation on the procedure followed by ECHA's Committee for Socio-Economic Analysis (SEAC) and the involvement of relevant stakeholders. He gave an overview of the REACH restriction process and the structured timeline followed by ECHA's expert Committees (RAC and SEAC). Mr. Gmeinder indicated the expected timeline for the procedure of the upcoming universal PFAS restriction in those two Committees and the consultations on the restriction proposal and on the SEAC draft opinion. M. Gmeinder highlighted the timing for stakeholders to provide feedback and the indicative evaluation schedule for ECHA expert Committees. During the discussion: Several questions were raised on extending the 6 months deadline for the consultation on the restriction proposal. M. Gmeinder responded that the 6-month period is defined in REACH (NB: Article 69(6)) and that in the past extensions were granted only in very specific cases due to exceptional circumstances (for example during the COVID-19 pandemic). ECHA is "prepublishing" the restriction proposal to provide more time for stakeholders. It was also clarified that stakeholders who are not following RAC and SEAC as regular observers can attend the meetings as occasional observers. The rules of procedure and the rules for participation are described on the ECHA website (NB: links provided in the presentation). Regulatory Management Option Analysis (RMOA) (Nicolas Robin, FPG) N. Robin gave a presentation on FPG's (Fluoropolymers Product Group) Regulatory Management Option Analysis (RMOA) on fluoropolymers (FPs). The methodology used to develop this RMOA is based on a variety of sources such as a tailored RMOA questionnaire delivered to manufacturers one-on-one calls with FPG Members, scientific literature review related to PFAS and FPs, and a Socio-Economic Analysis (SEA) on fluoropolymers (FPs), amongst others. The RMOA concludes that the preferred option is a mix between a REACH restriction that includes a broad derogation to allow continued manufacture and use of fluoropolymers (one type of PFAS), supplemented by a Voluntary Industry Initiative which guarantees that industry will address concerns related to their manufacture and use. This option also foresees an update of the existing EU rules on the recycling of fluoropolymer products and articles. V. Bertato asked whether FPG plans to produce more specific information on the uses of fluoropolymers in the upcoming public consultations, since the RMOA proposes to have a broad derogation covering all fluoropolymers without looking into specific uses. N. Robin responded that fluoropolymers are mainly used in industry and are mostly Polymers of Low Concern (PLC). Therefore, they should be exempted without going into different uses. On a question whether the RMOA was used in the RAC consultation on PFAS in firefighting foams restriction, N. Robin responded that fluoropolymers are not used in firefighting foams and argued against the grouping of PFAS. Q&A session M. Pauwels asked about derogations and how granular they are expected to be. M. Beekman responded that from a scientific perspective it is preferred to go as granular as possible, including detailed information whether there is an alternative available. From a practical perspective, the granularity should be limited. M. Gmeinder added that it is currently difficult to 2 DRAFT MINUTES be more concrete since the dossier has not been submitted yet. The lack of alternatives is typically used as an argument for the disproportionality of the restriction. Any assessment provided by stakeholders should be granular enough to justify that a restriction without derogation would indeed be disproportionate. M. Pauwels also asked how companies could prove that there are no alternatives. M. Beekman responded that most of the time alternatives are available but with (slightly) different properties. A compromise should be made between the product performance, the intended use of the product and pollution of the planet. M. Pauwels asked a question on whether there will be an opportunity for the industry to participate outside the public consultation system. M. Gmeinder responded that ECHA needed to operate within the limits of the established process and that the consultations are the key channels for stakeholders to provide input into the process. M. Gmeinder also responded to a question concerning the assessment of societal costs and societal benefits in the context of PFAS being used in zero-emission technologies, for example batteries for electric vehicles. He clarified that SEAC looks into the advantages and disadvantages of putting a restriction in place. If a restriction would mean that certain types of batteries are no longer available and CO2 emissions would increase as a result, then this would be considered a cost to society resulting from the regulatory action which needs to be contrasted with the benefits to society of reducing emissions of PFAS N. Robin questioned whether ECHA will be able to handle all the data provided by the different sectors, and what will happen if someone submits data at the end of the 6 months of the public consultation. M. Gmeinder responded that all comments will be considered and that both RAC and SEAC have experts to deal with the input provided by stakeholders. It is also possible to have additional ad hoc meetings focusing on specific sectors or specific uses. There was a request for guidance on proposals on concentration limits. M. Beekman responded that they should start by looking into the concentration limits of other PFAS restrictions. Questions coming from the chat and answered in written, following the meeting "On the discussion about the substitution, there is generally the idea that substitution may be possible with some performance restrictions, which means a reduction of the technical competitiveness. How is SEAC assessing the impact of this reduced technical competitiveness of EU products, knowing that there will be no way to avoid the import of products still using PFAs being imported in EU?" M. Gmeinder responded: "Restrictions on the placing on the market also apply to imported products. The enforceability of a proposed restriction is one of the aspects that will be evaluated by SEAC, taking into account the advice from the Forum for Exchange of Information on Enforcement. If SEAC identifies in its evaluation uncertainties related to the enforceability that might affect the effectiveness of the proposed restriction, this will be documented in the opinion." "Some sectors are regulated by other EU Agencies. Will those agencies be consulted as well during the restriction process?" M. Beekman responded: "The consultations organised by ECHA are generally open to all interested parties to submit comments and there is no barrier for other EU agencies to do so. There are no specific 3 DRAFT MINUTES parallel consultations with EU agencies. In addition, the Commission will have its regular inter-service consultation on the draft proposal for amendment of Annex XVII (after we have received the opinions from RAC and SEAC)." 3. Session 2: Case studies from key industries D. Sinnaeve introduced the speakers of the second session highlighting that sectors will present the impact of the PFAS restriction in their applications focusing on the socio-economic effect that such restriction will entail in their industries. PFAS & the Automotive Industry - Tools, Projects, and Challenges (Mathieu Ben Braham, Cetim and Timo Unger, Hyundai/Kia ACEA) T. Unger and M. Braham gave a presentation on PFAS and the automotive industry. T. Unger highlighted that the complexity of supply chains and resulting business is still totally underestimated since most manufacturers assemble cars, they do not manufacture them. ACEA (European Automobile Manufacturers Association) has implemented an ID system called the IMDS (International Material Data System), only for the automotive industry and suppliers can use it free of charge. He continued by explaining the general process of substance reporting within the system, the challenges involved and the outlook on PFAS in IMDS. M. Braham highlighted that both CLEPA (European Association of Automotive Suppliers) and ACEA are highly impacted by the coming PFAS restriction and thus have commissioned two studies to enhance their knowledge on PFAS and have relevant data to submit for the public consultation. He described some of the outcomes and the challenges of substituting PFAS used in applications within the automotive industry. The importance of fluoropolymers across the hydrogen value chain (Bastien BonnetCantalloube, Hydrogen Europe) B. Bonnet gave a presentation on the importance of fluoropolymers across the hydrogen value chain on behalf of Hydrogen Europe. The targets for hydrogen used have increased after the recent energy crisis, with huge changes to be implemented by 2030. Hydrogen Europe does not currently see any other solution to decarbonise the steel sector or any problem in using fluoropolymers if they are regulated in the right way. Without PFAS none of the Fit for 55 targets will be achieved and it is too risky to use alternatives since there is not enough time to test them. B. Bonnet also highlighted the importance of end-of-life and a take back system for the parts to be taken back to the manufacturer or a specific industry. V. Bertato asked about the take back system, saying that it is very difficult to recycle fluoropolymers because they are mixed with other polymers and materials. B. Bonnet answered that it depends on where they are used in the value chain and noted that many Hydrogen Europe members call for safe incineration and the recovery of the metals. PFAS in the Medical Technologies Sector (Roumiana Santos, MedTech) 4 DRAFT MINUTES R. Santos gave a presentation on PFAS in the medical technologies sector covering in Vitro Diagnostics (IVDs) and Medical Devices (MDs) and then provided some representative examples of PFAS found in those applications. She further explained why PFAS are used in these specific cases and the properties and functions fulfilled by them. R. Santos also showcased some of the challenges of substitution, availability, and the assessment of alternatives. PVDF essentiality in Water and Wastewater Treatment (Javier Villa, DuPont) J. Villa gave a presentation on PVDF (Polyvinylidene fluoride) essentiality in water and wastewater treatment. He first showcased some of the water challenges recently featured in the news, in terms of droughts reported in the summer and the EU policy strategy on water. Sharing a snapshot of DuPont's water solution portfolio and the applications where PVDF membranes are used. According to J. Villa there is no suitable substitution for PVDF in these applications, and the impact of a potential restriction could create many challenges for water treatment. The triple challenge for Refrigeration, Air conditioning and Heat pump (RACHP) Sector (Federica Rizzo, EPEE) F. Rizzo gave a presentation on behalf of the European Partnership for Energy and the Environment (EPEE) which represents the refrigeration, air-conditioning and heat pump (RACHP) industry in Europe. She highlighted that the RACHP sector relies on refrigerants that are safe and energy efficient, such as HFCs and HFOs, and are key for the decarbonization of the sector. The state-of-the-art alternatives for fluoropolymers are lacking in functionality, performance and will endanger the efficiency, longevity, and reliability of RACHP systems. F. Rizzo also provided an overview of the principles of the F-gas regulation and its timeline in parallel with the universal PFAS restriction. V. Bertato asked F. Rizzo on whether EPEE will be more specific in the upcoming consultations of the universal PFAS restriction on which uses are essential, since there are for example some heat pumps that use hydrocarbons. F. Rizzo responded that this type of equipment must be handled very carefully in specific circumstances, since they are affected by climate conditions, pressure, and many other factors. At this point, she continued, the sector also does not know on which refrigerants it can count on and which products will still be on the market. 4. Closure P. Muoz gave some final remarks on the completed objectives of the workshop, thanked all participants and speakers for their attendance and closed the meeting at 16:00 CET. 5 DRAFT MINUTES LIST OF PARTICIPANTS Meeting: FPP4EU Collaboration Platform Date: Place: 12 December 2022; 10.00-16.00 CET Hotel Thon EU, Rue de la Loi 75, 1000 Brussels, Belgium Virtual meeting via Microsoft Teams Abbruzzese Gianni Acua Alberto Aixas Martinez Pol Alonso Raquel Antal Marton Arbaoui Abde Averbeck Frauke Baert Annelies Baljevic Katija Barbu Luminita Baty John Baumgrtel Stephan Beauchet Sverine Bedry Samantha Beekman Martijn Belinchn Irene Berbner Thomas Bernheim Teresa Bertato Valentina Berthet Florence Bertolino Maud Bonnet-Cantalloube Bastien Borg Daniel Braham Mathieu Ben Bureau Maxime Byskata Jonna Candido Angelica Canepa Simone Casella Giuseppe Cattoor Tine Chanson Claude Chitalia Suhani Clemens Rosenmayr Bracco Imaging EFCG VS FOCUM Cefic Spanish Ministry of Industry Hydrogen Europe FEC Federation of European manufacturers of Cookware and cutlery Bundesanstalt fr Arbeitsschutz und Arbeitsmedizin (BAuA) Belgium Vlaamse Overheid Environment Departement Cefic EDANA Preservation Technologies Verband Schmierstoff-Industrie Arkema UK government Defra European Commission, DG Grow FEIQUE Federacin Empresarial de la Industria Qumica Espaola Merck KGaA LANXESS Deutschland GmbH EFCG European Commission, DG ENV ACEA European Automobile Manufacturers' Association Cefic Hydrogen Europe KEMI The Swedish Chemicals Agency Cetim 3M Kingspan Cefic European Fine Chemicals Group EFCG European Commission, DG Grow Essenscia RECHARGE IPC Austrian Federal Economic Chamber WK - Industry Division 6 Cognat Flore Colomer Jaume Conrad Silke Consoli Elisa Copel Laure-Anne Crozier Jonathan Davidson Christel de Cornulier Marine de Kort Thijs Deves Valerie Di Caprio Elisabetta Eichler Antje Gerding Anna Duvielguerbigny Arnaud Eddleston Mark Entner Marcello Evans Benedict Famulok Tobias Garca Gonzlez Ana Gauge Gabrielle Geros Stefanos Gharsalli Sara Gehrke Thorsten Gmeinder Michael Goeller Juergen Gomes Susana Griffin Matthew Grootheus Herbert Greaves Tim Gurin Agns Gunasekar Priyanga Gustin Christophe Gwaba Yolanthe Hannebaum Peter Heggelund Audun Holzwarth Michael Ildefonso Beatriz Irean Robert Ivarsson Jenny James Alison Jansen Kim Johansson Tommy Jubault Sverine DRAFT MINUTES ExxonMobil AnimalhealthEurope Daimler Trucks AG Cefic Euromcontact FPP4EU Chair of Advocacy and Communications Committee CEPE European Council of Paint, Printing Ink and Artists' Colours Industry EHI Association of the European Heating Industry The Netherlands RIVM / Bureau REACH Inventec Performance Chemicals Eni ATIEL Gesamtverband Textil- und Mode e.V. Bayer AG PU Europe Contamac Ltd Euromcontact FCIO Fachverband der. Chemischen Industrie sterreichs MedTech Europe Synthomer/Omnova Spanish Ministerio para la Transicin Ecolgica y el Reto Demogrfico Renault ACEA CEFIC Orgalim, T&D Europe VDMA ECHA Carrier Refrigeration EPEE APQUIMICA Jaguar Land Rover ACEA Roehm GmbH ExxonMobil Climalife EPEE Gujarat Fluorochemicals GmbH Bayer AG Bausch Health Euromcontact Johnson Controls Norwegian Environment Agency Parker Hannifin - Prdifa Technology Division CLEPA Vitesco Technologies Swedish Chemicals Agency IPC DIGITALEUROPE / Canon KEMI The Swedish Chemicals Agency TotalEnergies Lubrifiants ATIEL 7 Jrgens Saskia Kapoor Deepak Kateman Erik Kaup Triin Knauz Alena Koring Andre Kraenzler Thomas Lance Julien Lekatos Stylianos Leonhardt Thomas Leopoldo Paul Anthony Lequime Catherine Lilaj Arnola Lots Charlotte Malvasi Marco Marc Naomi Martins Lilia Matsa Sandra Mauri Valentina McPike Sean Medori Lucia Mensink Marco Merz Mirjam Metz Kirsten Minne Francoise Mller Guido Moody Andrew Mulder Ellen Munoz Patricia Nakamura Takayuki Nicolle Darcy Oger Laurent Oledzka Gosia Pauwels Marleen Perez Simbor Laia Perfetti Marco Poli Federico Popielarz Wojtek Redon Sophie Renner Kofi Rizzo Federica Robin Nicolas Rodriguez Rodriguez Paula DRAFT MINUTES Cefic Gujarat Fluorochemicals Aspen Oss EFCG EURATEX VDMA VDMA Europump Serge Ferrari Chemours EUROFEU Lear CLEPA SICOS EFCG Cefic Daikin Europe Solvay APPLiA Home Appliance Europe Portugese Environment Agency Latvian Environment, Geology and Meteorology Centre Chemours Eli Lilly EFPIA European Safety Federation Cefic Federation of German Industries BDI ZVEI Zentralverband Elektrotechnik- und Elektronikindustrie e.V. Cefic Daikin Chemical Europe GmbH AGC Cefic Cefic Daikin Chemical Europe GmbH EPEE CropLife Europe ExxonMobil Cefic ETRMA Chemours Bracco Imaging EFCG WL Gore & Associates IOGP UK Environment Agency EPEE Fluoropolymers Product Group VS FOCUM 8 DRAFT MINUTES Romero Juan Rossi Alessia Ruiz Claire Russell Patten Sahnoune Farid Sanders Marion Santos Roumiana Sbrizaj Natasa Skarlatos Panos Scharnecchia Severina Scherf Lavinia Schlipf Michael Simpson David Sinnaeve Dietrich Sollberger Tim Sornais Xavier Strehl Gernot Theurer Marc Turnbull Aidan Unger Timo Van den Eede Chris van den Noort Marcel van Driel Marlies Van Well Dirk van Wely Eric Vanderstraeten Stefaan Vasques Goncalves Serra Alexandra Sofia Vaz Santos Laginha Isabel Maria Veith Susanne Veithen Xavier Vermeulen Peter Villa Javier Vogel Ralf Weemaes Michiel Westphal Helle Wiebke Drost Whittingham Andy Yada Makiko Yasushi Yamaki Spanish Ministry for the Ecological Transition and the Demographic Challenge Olon S.p.A Smiths Group EPEE Serge Ferrari Group The Netherlands RVIM MedTech 3M Hellenic Association Chemical Industries Eastman Chemical BV ABB FPS GmbH (pro-K Industrieverband Halbzeuge und Konsumprodukte aus Kunststoff e.V.) ExxonMobil FPP4EU Chair of Management Committee DigitalEurope EVOLIS FEC Federation of European manufacturers of Cookware and cutlery W.L. Gore Apple Hyundai/Kia; ACEA AnimalhealthEurope Gujarat Fluorochemicals Ltd Sherwin Williams ACEA Chemours DuPont Daikin Europe N.V. IAPMEI Portuguese Agency for Competitiveness and Innovation IAPMEI Portuguese Agency for Competitiveness and Innovation DuPont Institut Scientifique de Service Public (ISSeP) 3M DuPont Water & Protection European Sealing Association Parker Hannifin Manufacturing Belgium Confederation of Danish Industry German Environment Agency BP ATIEL Cefic AGC 9