Document ExwrX2BQw664BwrBqMNxwKExn

Hydrogen Europe - Ref. Ares(2020)4211120 - 11/08/2020 To the Executive First Vice-President Frans Timmermans Energy Commissioner Kadri Simson Industry Commissioner Thierry Breton Environment Commmissioner Virginijus Sinkevicius Rue de la Loi 200 BE-1049 Brussels Brussels, July 2020 Subject: PFAs Call for Evidence and the Hydrogen Strategy Dear Executive First Vice-President Timmermans, Dear Commissioner Simson, Dear Commissioner Breton, Dear Commissioner Sinkevicius, On July 8th, the European Commission published its Hydrogen Strategy for a climate-neutral Europe, putting Europe at the forefront of climate action as well as hydrogen deployment. While the hydrogen sector is obviously thrilled about the Hydrogen Strategy and eager to implement it, we now learned about a policy initiative that could jeopardize it, if not enough attention is paid to its implications. This initiative is the EU call for evidence to restrict all chemical substances called "per- and polyfluorinated alkyl substances" (PFAs in short), including fluoropolymers. This EU PFAS Strategy is a proposal of five countries (Germany, the Netherlands, Denmark, Sweden and Norway) to restrict and ultimately ban the manufacture and use of all PFAs in Europe. While this is certainly not the intention of the promoters of the PFAs Strategy, it could seriously hamper the implementation of the Hydrogen Strategy. Indeed, the success of the Hydrogen Strategy relies essentially on two key technologies: electrolysers that transform renewable electricity into hydrogen and fuel cells which transform hydrogen into electricity and heat. The core of both technologies is an electro-chemical reaction through a membrane. A very large proportion of electrolysers and fuel cells (and in some applications 100%) are based on Polymer Electrolyte Membrane (PEM). The unintended impact of an insufficiently considered ban on all PFAs would be to severely inhibit the manufacture and use of PEM fuel cells and electrolysers, because at their heart they depend on gas-impermeable proton-conducting fluoropolymer membranes. Moreover, there are no alternatives. The danger of this PFAs Strategy is that it envisages a ban on all PFAs without distinction. Within the very large family of PFAs, which includes around 4700 susbtances, it is useful to distinghish some sub-categories. Among PFAs, fluoropolymers, which are used in PEM electrolysers and fuel cells, constitute a distinct category as they are solid, inert, stable, safe, Hydrogen Europe Secretariat, Avenue de la Toison d'Or 56, B 1- 050 Brussels, Belgium Tel:+32 2 540 87 75 I Fax:+32 2 513 05 77IEmail:secret ariat@hydrogeneurope.euIWebsite:www.hydrogeneurope.eu Hydrogen Europe durable, versatile, and don't degrade into other PFAs. They do not pose any significant threat to human life or to the environment. Moreover, for electrolysers and fuel cells there is an overwhelming economic imperative to recover PEM stacks at the end of the life-cycle in order to reclaim and recycle the expensive PGM catalysts contained within the membrane/electrode assemblies; hence it is very unlikely that any associated fluoropolymer component will enter the general waste stream. In plain language, fluoropolymers are simply a speciality plastic that underpins PEM electrolysers and fuel cells and could be put into the OECD "polymers of low concern" classification. Said fluoropolymers should be classed as such. Let's remember what is at stake. First, the European Hydrogen Strategy fixes the ambitious objective of 40GW electrolysers in 2030 and 10mt of renewable H2 by then, which requires a rapid scaling up. Second, Europe is the industrial leader in hydrogen technologies and the European Commission identified hydrogen as a strategic value chain. We must ensure consistency across different EU policies and avoid undue barriers to the uptake of electrolysers and fuel cells. For these reasons, Hydrogen Europe urges the European Commission and the promoters of the PFAs strategy to consider the impact that such initiative could have on the Hydrogen Strategy and analyse the possibility to distinguish the treatment of PFAs on the basis of their environmental impact and the availability of alternatives. Hydrogen Europe and its members are available to discuss further this complex topic. Sincerely, Secretary General Managing Director Hydrogen Europe Secretariat, Avenue de la Toison d'Or 56, B 1- 050 Brussels, Belgium Tel:+32 2 540 87 75 I Fax:+32 2 513 05 77IEmail:secret ariat@hydrogeneurope.euIWebsite:www.hydrogeneurope.eu