Document JN98QgxLb4OqoOnkz7JgZ90ea

Updated Annex 3 to Japan 4EE input: Non-Exhaustive PFAS Essential Application list A: Explanation based on PFAS as chemical materials As of 7 September 2023 (Contents updated after 1st input are shown with underline and in yellow cells.) PFAS classification Fluoropolymers and Perfluoropolyethers RCehpermeisceanltMataivteerials Ref. No. PTFE 1 PFA FEP ETFE PVDF PCTFE FKM FFKM FEPM FFKO PFPE 2 Intended use in electrical and electronic equipment (EEE) [Derogations for EEE should be set at this level.] Sliding elements in mechanical section Optical elements 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 exhibit 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 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 4 Insulating material requiring flame-retardancy and/or heat- Cables, heat insulator, tubes, wire coating resistant, where the use is needed for safe functioning and safety of equipment 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 NonPFAS 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 Optical elements for LCD panels 6 Electronic circuit boards for high-frequency applications 7 Anti-dripping agent used for safety and to enhance flame retardancy Anti-fingerprint layer on panel surface and antireflection (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 property, thermal 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 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 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 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. 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 8 (Electronics); related derogation is not proposed. 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 protection purposes used in the article molding process Developer additives and resin additives used in electrical and electronics manufacturing processes Coating material (use as mold release agent) Fluorine compounds such as PFAS are the only materials that can simultaneously provide and exhibit multiple functions, such as low dielectric constant, low dielectric loss tangent, low refractive index, oil repellency, electrical insulation, water repellency, heat resistance, chemical resistance, weather resistance, mold releasability, flame resistance, separability, wear resistance, surface properties (friction coefficient), bending strength, stretching properties, non-flammability, 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 described in dossier extremely difficult. 4.Sliding function in mechanical section 6.Safety and safety functions 7.Functional surface 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 input from the battery industries, such as those from RECHARGE (Ref.No. 3925 in RCOM Part.2) or from Battery Association of Japan (BAJ) (Ref.No.4331 in RCOM part 14), for the concrete details. 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 have submitted the comment on this dossier (Ref.No.3925 in RCOM Part 2) 10.Energy supply (Battery) Battery All the EEE in RoHS categories 1- 11 would use batteries. Question 8 (Energy) ; related derogation is not proposed. 10 Film, sheet or membrane requiring surface performance which Film material, ensures multiple functions such as electrical insulation property, electrostatic adsorption belt, chemical resistance, heat resistance, flame resistance, flex Waste Powder Collection Filter, Friction resistance and excellent elongation followability at the same time 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 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 11 Hermetic sealant requiring low percentage of the compression set Gasket materials, sealing materials, rubber 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 4.Sliding function in mechanical section as well as simultaneously other functions such as excellent valves (umbrella valves, duckbill valves, etc.), compression set of hermetic sealant used in the facilities for manufacturing EEE and its components to function normally in various environments elongation followability, durability, flame resistance, heat and hot four-way reversing valve, check valve, ball must be low. And at the same time, sealant as EEE parts needs other functions such as excellent elongation followability, durability, flame water resistance, low water absorption, low moisture permeability, valve, O rings, buttons on the operating unit, resistance, heat and hot water resistance, low water absorption, low moisture permeability, chemical resistance (including resistance to chlorine chemical resistance and/or low outgassing. sealing materials, encapsulating materials and contained in tap water), low outgassing (to avoid contamination of impurities and to maintain the vacuum of instrument). Fluoropolymers are the tube element for various electronic component 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. 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, high cleanliness Chemical supply tubes, 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 exhibited. Therefore, it is impossible to substitute to those alternatives. 6.Safety and safety functions 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. 1 Updated Annex 3 to Japan 4EE input: Non-Exhaustive PFAS Essential Application list A: Explanation based on PFAS as chemical materials As of 7 September 2023 (Contents updated after 1st input are shown with underline and in yellow cells.) PFAS classification RCehpermeisceanltMataivteerials Ref. No. 13 Intended use in electrical and electronic equipment (EEE) [Derogations for EEE should be set at this level.] PFAS used for semiconductor manufacturing process, semiconductor manufacturing equipment, and semiconductor Non-exhaustive examples of uses Construction of polymer substrates and dielectric materials, manufacturing equipment for adhesives, underfills, filter, die bond resins, valve seals, etc., heat transfer fluids surface protection Reasons why PFASs are un-replaceable Fluorine compounds such as PFAS are the only materials that can simultaneously provide and exhibit multiple functions, such as low dielectric constant, low dielectric loss tangent, low refractive index, oil repellency, electrical insulation, water repellency, heat resistance, chemical resistance, weather resistance, mold releasability, flame resistance, separability, wear resistance, surface properties (friction coefficient), bending strength, stretching properties, non-flammability, etc. which are necessary for semiconductor manufacturing processes, semiconductor manufacturing 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-Sector04_14_2023.pdf Functions of EEE requiring the use of PFAS (Link to Column C of List B (Annex 4)) 8.Semiconductor Functions of EEE requiring the use of PFAS (Link to Column G of List B (Annex 4)) Semiconductor All the EEE in RoHS categories 1- 11 would use semiconductors. Corresponding question and related derogation proposal in the dossier Question 7; Similar to 5.ee 14 PFAS used for thin-film device (Micro Electro Mechanical System/ 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 MEMS, SAW device, Capacitor, etc) manufacturing process, thin- 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, PC film device manufacturing equipment, and thin-film device 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 thin-film device(Micro Electro Mechanical Systems/MEMS, SAW, Capacitor, Other products in RoHS categories 1- 11 may use thin-film surface protection etc) manufacturing processes, thin-film device manufacturing equipment and thin-film device to function normally under various environments, devices making 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 *Please refer to the input from the related industries, such as Japan Business Machine and Information System Industries Association (JBMIA), for the concrete details. Toner additives, Ink additives, Developer additives Fluoroalkyl compounds with functional PFHxA, PFBA, 16 groups (such as -OH, -COOH, N-R, etc.) and Side-chain fluorinated polymers PFBS, Polyfluoroalkyl (meth)acrylate High performance materials for mold release and protection purposes, which ensures multiple functions such as electrical insulation, heat resistance, chemical resistance or flame resistance, etc. at the same time 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, 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 simultaneously. 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 toner: 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 described in Dossier 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 Semiconductor 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, Photoacid generator Capacitor, etc) manufacturing process Photoresist The thin-film device (MEMS(Micro Electro Mechanical Systems), SAW, Capacitor, 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, PC Other products in RoHS categories 1- 11 may use thin-film devices 19 Functional material used in printing process *Please refer to the input from the related industries, such as Japan Business Machine and Information System Industries Association (JBMIA), for the concrete details. 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 simultaneously. 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 appliances such as those for Refrigerant is used in various refrigeration, air Fluorine-based refrigerant has excellent thermodynamic properties in a wide range and is also excellent in temperature followability. Moreover, 11.Cooling function (Refrigerant) Refrigeration, Air Conditioning and Heat Pump (RACHP) products conditioning and heat pump products. Such 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 RACHP products are not only used in are damaged by an earthquake or storm and then the refrigerant leaks. Natural refrigerants such as ammonia (NH3), hydrocarbon (propane, *Please also see the input from the related industries, such as refrigerators, freezers or air conditioners but isobutane, etc.) are not applicable to all the appliances as they are highly flammable or toxic. Please refer to the comments of the related Japan Refrigeration and Air Conditioning Industry Association also further incorporated into may other industries, such as Japan Refrigeration and Air Conditioning Industry Association (JRAIA) (the first input is Ref. No.4292 in RCOM part 13 and the (JRAIA) (the first input is Ref. No.4292 in RCOM part 13 and the products for medical, measurement, 2nd will be submitted soon.), for details on why fluorine-based coolants cannot be substituted. 2nd will be submitted soon.), About the details of the essentiality manufacturing, etc. of the PFAS refrigerants. Refrigerant All the EEE in RoHS categories 1- 11 may use refrigerant if needed. 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 toner: 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 21 Refrigerant, coolant, cleaning agent and solvent used for semiconductor process Cooling of manufacturing equipment 22 Refrigerant, coolant, cleaning agent and solvent used for thin-film Cooling of manufacturing equipment 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 semiconductor processes other than etching, please refer to the comments of the relevant industry associations. 8.Semiconductor Semiconductor All the EEE in RoHS categories 1- 11 would use semiconductors. Question 7 (F-Gas); 5.ee 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-film 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. 2 Updated Annex 3 to Japan 4EE input: Non-Exhaustive PFAS Essential Application list A: Explanation based on PFAS as chemical materials As of 7 September 2023 (Contents updated after 1st input are shown with underline and in yellow cells.) PFAS classification RCehpermeisceanltMataivteerials Ref. No. 23 Intended use in electrical and electronic equipment (EEE) [Derogations for EEE should be set at this level.] Chemicals for ultra-fine processing applications, as typified by semiconductor and MEMS manufacturing processes *HFC-23 (CHF 3), HFC-32 (CH 2 F 2), HFC-152 a (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 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) Non-exhaustive examples of uses Etching gas for semiconductor and glass substrates Equipment such as etching equipment/CVD equipment Substrate cleaning gas Reasons why PFASs are un-replaceable 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. Functions of EEE requiring the use of PFAS (Link to Column C of List B (Annex 4)) 8.Semiconductor 9.Thin-film device manufacturing process Functions of EEE requiring the use of PFAS (Link to Column G of List B (Annex 4)) 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. Corresponding question and related derogation proposal in the dossier 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 adding function) in production processes and laboratories Fluorinated 25 engineering plastic materials such as fluorinated polyimide and Liquid crystal materials. Ocotmheprofulunodrsinated 26 Transparent electronic circuit board and circuit Liquid crystal display (LCD) elements Test solvent for gross leak test, etc., highprecision temperature characteristic measurement, and voltage application medium for polarization of piezoelectric ceramic elements Fluorinated compounds are the only media that can maintain the quality of an object without leaving stress or contamination on the object in the process due to their extremely low surface tension and high volatility. Furthermore, fluorinated compounds simultaneously possess excellent functions such as excellent thermodynamic properties, electrical insulation, and inactivity, which ensure the stability and accuracy required in the process. 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. This application is described not in current Application List B (Annex 4) , but in current Application List C (Annex 7), under: 1. Immersion process. Car navigation system, Sphygmomanometer (blood pressure meters), Inkjet printer, Smartphone. Other products in RoHS categories 1- 11. 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 Liquid crystal substances (small molecules), Vertical alignment liquid crystal display device, Interlayer spacer to control the cell gap of LCD panels. "Fluorinatad Liquid Crystal substances (PFAS LC)" have low driving voltage, high response speed, and low temperature dependence of driving voltage, which are required for low power consumption video displays that require multiple functions simultaneously. Cyano-based crystal substances cannot meet these requirements simultaneously. So it was replaced by "PFAS LC" as a technological breakthrough. The power consumptions of other displays (e.g. OLED) are higher than LCDs using PFAS LC. Fluorinated polyimides with long-chain fluorinated alkyl groups in the side chains have high heat resistance and stable. For other LCD elements, fluorinated polyimides with long-chain fluorinated alkyl groups in the side chains have high heat resistance and stable vertical orientation over a wide temperature range. These properties cannot be replaced by polyimides with hydrocarbon side chains. The structural materials for maintaining uniform cell gap of a large-sized liquid crystal panels are required to have high precision thickness uniformity, no contamination in the manufacturing process, chemical resistance, no influence to optical system and heat resistance at the same time. These are not able to be replaced by silicone or acrylic resin. 5. Display function(Liquid crystal display / LCD) 7. Functional surface 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 elements 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 materials used in printing process *Please refer to the input from the related industries, such as Japan Business Machine and Information System Industries Association (JBMIA), for the concrete details. 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 simultaneously. 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 Functional coatings* (* "Functional coating" is a coating applied to an article in order to give it the required functions, such as low dielectric properties, low dielectric loss tangent, electrical insulation, heat resistance, UV resistance, chemical resistance, corrosion resistance, weather resistance, water repellency, oil repellency, slipperiness, low refractive index and so on. "Functional coating" includes, but not limited to, "conformal coating" used to protect electronic materials. In our input, 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, razor blade, 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, UV 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 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]." All the PFAS (fluoropolymers and others) PTFE, PFPE, PFHxA, PFBS 30 Lubricants where the use takes place under harsh conditions or Electronic cameras, lens systems for electronic To protect the mechanical properties of the moving parts of precision components in electrical and electronic equipment, the lubricant (e.g. grease) 4.Sliding function in mechanical section the use is needed for safe and intended functioning and/or safety cameras, moving parts of the helicoid of is given an autophobic property to prevent wetting and spreading. If the lubricating components applied to the operating parts of precision 6.Safety and safety functions of equipment projection lenses and moving ball frames, components become wetted and diffuse, the durability and performance of the product will be significantly reduced. To prevent this, fluorine driving parts of ultrasonic testing equipment, compounds are added which have good dispersibility in lubricants (e.g. grease) and can provide oil repellency due to their self-hydrophobic drives for optical discs, torque limiters for properties. scanners and other moving parts of precision Only fluorine compounds with low surface free energy can provide oil repellency and are difficult to replace. equipment in electrical and electronic 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. equipment. 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. 3