Document JvmRDg3YyynbwjnXjmyZjGbY2

PFAS Application for exemption from the draft PFAS ETFE ETFE film Suzhou Hondol New Material Co., Ltd. :2023 8 23 Date: August 23,2023 Product description: ETFE, CAS NO.:65324-12-1 ETFE -ETFE ETFE "" ETFE Amhiem Hampshire "Moby Dlck" Masoala ETFE chemical name ethylene tetrafluoroethylene copolymer, is a fluorinecontaining polymer thermoplastic material, is an artificial high strength fluoropolymer, ETFE film directly from the material into a film. ETFE film has good durability, easy cleaning and stability, is a typical non-fabric film material, is the most advanced film material in the world. Because of its high light transmission, flame resistance, durability, easy cleaning and stability, it is widely used as a substitute for glass, commonly known as "soft glass". Buildings built with ETFE membranes include Amhiem Zoo in the Netherlands, Hampshire Tennis and Fitness Club in the United Kingdom, Eden in the United Kingdom, Moby Dlck swimming pool in Germany, Masoala Rainforest in Zurich, Switzerland, and so on. In the photovoltaic field, the demand and market share of double-sided modules have been increasing in recent years, and efficient and large-size and lightweight are also future development trends. As one of the two main packaging methods of doublesided components, double-sided glass packaging components have better weather resistance, but due to large weight, limited size, production line matching and other reasons, resulting in certain limitations in production capacity, construction, etc., so transparent backplane is a better choice. PVDFPVF ETFE ETFE ETFE Compared with the traditional PV backplane with PVDF, PVF and fluorine coating as the outer protective material, ETFE has better weather resistance, heat resistance, scratch resistance and hydrophobicity, and is a more ideal material as the outer material facing ultraviolet light. And portable photovoltaic energy storage is on the rise, ETFE has a unique advantage, it can be used as a packaging material for flexible photovoltaic modules, to achieve flexibility and portability. In the future, photovoltaic power generation will be rapidly applied in many scenarios with high requirements for lightweight, portability and application, such as RV, outdoor activities and disaster emergency, and ETFE materials are expected to open up more application scenarios. Request an exemption: We apply for the exclusion of the substances mentioned from the PFAS ban. ETFE PFAS Grounds for exemption: 1 [1] Photovoltaic power generation is an important way to achieve carbon neutrality 1 2021 284 Traditional fossil energy consumption will emit a lot of greenhouse gases, in order to achieve the goal of carbon neutrality, countries vigorously promote the development of new energy (see Table 1), the market application continues to expand. With the acceleration of the global response to climate change, the development of the photovoltaic industry has received policy support, and the market demand continues to increase, and China's photovoltaic products exports exceeded 28.4 billion US dollars in 2021. 1 Table 1 Carbon neutrality timelines and emission reduction targets for major countries or organizations nation Germany Carbon neutral time 2045 Emission reduction target 2030 1990 65% By 2030, greenhouse gas emissions will be 65% lower than  America Japan European Union France 2050 2050 2050 2050 in 1990 2030 2005 50%~52% By 2030, US greenhouse gas emissions will be reduced by 50 to 52 percent from 2005 levels 2030 2013 40% Greenhouse gas emissions by 2030 will be 40% lower than in 2013 2030 1990 55% By 2030, greenhouse gas emissions will be at least 55% lower than in 1990 It is proposed to triple the rate of emission reduction Britain 2050 2030 1990 68% By 2030, greenhouse gas emissions will be at least 68% lower than in 1990 China 2060 2030 GDP 2005 60%~65% 2030 By 2030, emissions per unit of GDP will be 60% to 65% lower than that of 2005.Carbon emissions peak in 2030 1990 2030 25%~30% Russia unspecified Reduce greenhouse gas emissions by 25% to 30% between 1990 and 2030 The double carbon target promotes the rapid growth of global photovoltaic installed capacity year by year, the price of raw materials is low, and the cost of photovoltaic modules is falling, which will also promote photovoltaic to become an energy alternative in a wider range of application scenarios, bringing a significant increase in demand. 2ETFE [2] ETFE film is irreplaceable in photovoltaic power generation PVFPVDF ETFE PVDF In the existing transparent backplane production technology, the outermost layer is mainly polyvinyl fluoride film (PVF) and polyvinylidene fluoride film (PVDF), which has obvious attenuation in various climatic conditions and lack of weather resistance. ETFE film material is used for transparent backplane products, with better weather resistance, heat resistance, scratch resistance and hydrophobicity, as the outer material facing ultraviolet light, is a more ideal material, effectively make up for the prior art PVDF plastic film due to low melting point and easy thermal shrinkage defects. 3ETFE [3] Ethylene and tetrafluoroethylene copolymer films (ETFE) have not been shown to be harmful 3.1 3.1 Toxicity data, human clinical data and physicochemical properties PLC ETFE CFDA MFDS PMDA ISO 10993 ETFE ETFE PFAS PLC PFAS PFAS Based on fluoropolymer toxicity data, human clinical data, and physical and chemical properties, fluoropolymers meet widely accepted regulatory assessment criteria and should be considered a polymer PLC of low concern. Fluoropolymers have high molecular weight, narrow molecular weight distribution, negligible oligomer content and organic and inorganic extractives. The data show that fluoropolymer has thermal stability, chemical stability, photochemical stability, hydrolytic stability and biological stability. ETFE has been extensively tested to comply with U.S. and European Union food contact and global medical device regulations (e.g., U.S. Food and Drug Administration, CFDA, Korean MFDS, Japanese PMDA), including ISO 10993 biocompatibility testing and preclinical animal testing. Toxicological studies of ETFE have shown no acute or subchronic systemic toxicity, irritation, sensitization, implantation local toxicity, in vitro and in vivo genotoxicity, hemolysis, complement activation, or thrombosis. The data presented indicate that PFAS in the fluoropolymer category are well defined, comply with PLC standards and should be considered significantly different from PFAS in other categories. Scientific data does not support grouping all PFAS together. 3.2 3.2 There is no relevant evidence to prove the harmfulness in the production process ETFE - ETFE ETFE chemical name ethylene tetrafluoroethylene copolymer, is a fluorine-containing polymer thermoplastic material, is made of ethylene, tetrafluoroethylene copolymerization of artificial high strength fluoropolymer, ETFE film directly from the copolymerization material cast or blow molding film. No harmful substances are produced in the copolymerization and forming process, and there is no relevant evidence to prove the harmfulness. 3.3 3.3 There is no relevant evidence to prove the harmfulness in the use process 485kJmol -1 ETFE The bond energy of fluorocarbon bond is 485kJ mol-1, the bond energy is large, and it is not easy to break, so that it has good acid resistance, alkali resistance and weather resistance. Therefore, the performance of ETFE film is stable during use, and it is not easy to decompose and oxidize. The product is only used in photovoltaic power generation components, does not produce direct contact with the human body, and as a building membrane structural material has been widely used, there is no relevant evidence to prove its harmful. 4 [4] Excellent product features:  ETFE ETFE 9600 ETFE Our company uses ETFE resin to make ETFE film products by casting and blowing film processes, and has achieved large-scale mass production with an annual capacity of 96 million square meters. The membrane products have good consistency and excellent performance, and overcome the technical problem that ETFE cannot block ultraviolet light. The formula is stable, the production process is mature, and the thickness, width, color and roughness can be customized according to customer needs. Technology iteration to achieve cost reduction and efficiency, improve power generation efficiency, reduce the weight of photovoltaic modules, and help the diversification of photovoltaic power generation applications, has a non-negligible role in promoting the development of photovoltaic power generation industry.