Document K6xg5enm9EKzBNrEjzRLp7gYw

EU chemicals legislation: restriction of PFAS 09/2021 Objectives of the position paper The aim of the position paper is to present the significant impact on the entire industry of a comprehensive PFAS restriction. In order to ensure a uniform understanding, a practice-oriented classification of PFASs is first undertaken in Part1. On the basis of various overviews, we then explain in Part 2 which PFAS are used in which industrial sectors and branches, and present the significance of the group of substances for innovations and technological developments in industry. Finally, we will highlight a few application areas and explain the role that PFAS play in the implementation and achievement of efficiency and environmental goals as well as for future technologies. There is explicitly no classification into essential and less essential applications in which PFAS are used. The reason for this is that such a classification would represent an uncalculable challenge and would have far-reaching negative consequences both for society and for Europe as a business location. This will be demonstrated by means of the points mentioned above. Furthermore, this position paper (Part 1) deals with the fundamental aspects of the proposed regulatory approach. From the industry's point of view, it is particularly critical that the EU regulatory authorities want to combine and restrict all PFAS in one group in order to simplify and accelerate the regulatory processes. This ignores the fact that the PFAS definition covers substances with different properties and that neither all PFAS are equally persistent nor equally mobile or bioaccumulative. The planned concept of merging all PFAS into one group of substances to be regulated will lead to great regulatory complexity in the implementation phase. Furthermore, virtually risk-free chemicals will be equated with substances of very high concern ("SVHC") with properties requiring regulation. Instead, EU policy makers should ensure that a differentiated approach is taken between the various PFAS. This should take into account whether a PFAS substance poses an unacceptable risk to the environment or human health. Otherwise, there would be a risk, for example, of driving chemicals off the market that have a crucial role to play in helping our industries move towards a decarbonised economy. BDI is concerned that the restriction of PFAS as currently planned will be disproportionate and unworkable. Moreover, it is to be feared that this will hinder the achievement of both economic goals and goals of the EU Green Deal. In summary, the main concerns are as follows: General regulation of thousands of PFAS substances as a group has no sufficient scientific basis and would be disproportionate for that reason alone. The aggregation of thousands of PFAS substances carries the risk that regulation would be too complex for enforcement authorities and thus not feasible. The regulatory PFAS approach being planned is in contrast to generally accepted REACH principles, such as that there should only be restrictions in the case of unmanageable risks. The impact of a broad PFAS regulation on industry, but also on product diversity, would be significant. A ban on production and use across the board but also of specific 2 EU chemicals legislation: restriction of PFAS 09/2021 PFAS would considerably restrict the innovative capacity of German industry. Germany's and the EU's economic goals and the goals of the EU Green Deal would be hindered or jeopardised. A lack of viable alternatives to PFAS substances means high socio-economic costs in trying to replace them. Due to the often highly complex international supply chains and the associated difficulty in analysing and preparing for the exact impact of a ban on many thousands of substances, there is a great risk of unforeseen interruptions to supply chains with all the associated economic consequences. A precise impact analysis per substance therefore requires sufficient time, which unfortunately is not currently granted. Types, properties and uses of PFAS Due to their unique property profile, PFAS are used today in a wide range of mainly industrial products, often because of their high thermal and chemical resistance, the fact that they have a very low surface tension and are thus water and oil repellent at the same time, as well as their abrasion and wear resistance. Depending on the size of the molecule and the chemical structure, however, the chemical, physical and ecotoxicological properties and thus the hazard potential of the representatives of this very extensive group of substances differ considerably: PFAS can be gaseous, liquid or solid; some are water-soluble; some are mobile, others bioaccumulate, some are toxic, others are physiologically harmless and many are persistent in the environment. In the past, some PFAS have repeatedly been released into the environment, have accumulated in soil and water and can now also be detected in the human body. In recent years, the industry has already made considerable efforts and established comprehensive environmental protection measures in production. Toxic and particularly harmful substances from the PFAS group (e.g. PFOA and PFOS) have been substituted and production processes have been modified. As the Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU) reports on its website (www.bmu.bund.de) and as analyses of the federal environmental sample bank show for some compounds, the exposure of the population to PFOS (perfluorooctane sulfonic acid, C8) and PFOA (perfluorooctanoic acid, C8) has also decreased significantly in recent decades. The measured values were highest in 1986. Today they are about 10% for PFOS and about 30% for PFOA compared to the values at that time. This trend is mainly due to the success of the considerable investments made by companies in the EU. The primary sources of emissions to the environment (e.g. from aerosols in Teflon production, fire extinguishing foams or fire training areas, etc.) have already been recorded and controlled in the Member States and are largely eliminated (or are in the process of being eliminated) through continuous technological development and dynamic operator obligations to comply with the state of the art in the EU. However, there is no doubt that PFASs are needed for many high-tech applications (such as special protective clothing or essential innovations like fuel cells with suitable membrane technology). Furthermore, it is not foreseeable which future applications will rely on the unique properties of fluorochemical-based polymers. If PFASs are banned in the EU for many important applications, this will not change the extensive use of PFASs. 3 EU chemicals legislation: restriction of PFAS 09/2021 Demand for products with the advantageous properties of PFAS applications. Future innovations and further developments of PFAS technology will be important, but then no longer possible in the EU. For a better understanding of the diversity of substances and for differentiation purposes, PFAS are divided into the following subgroups (see Figure 1): Figure 1: Systematic presentation of the different PFAS categories (with exemplary substance examples) Source: BDI Fluoropolymers with the subgroup of fluoroelastomers comprise fully (per-) and partially (poly-)fluorinated plastics. These are generally high-performance plastics whose chemical backbone consists of carbon atoms and which have a high proportion of fluorine atoms in their chemical structure. Their high resistance to extreme temperatures, aggressive chemicals and wear, as well as the physiological harmlessness of fully fluorinated types define their areas of application, such as antistick coatings for products (e.g. plain bearings in the process industry) or medical products (e.g. catheter hoses or oil- and fuel-resistant seals). The basis of many high-performance lubricants are liquid perfluoropolyethers, which are also a class of compounds within the fluoropolymers. They are mainly used under extreme conditions (very high temperatures, chemically aggressive environment) and for the lubrication of machines in the food sector, as they are non-toxic. Side chain fluorinated polymers (SCFP), which have a comb-like structure and in which the fluorine atoms are located in the side arms of the polymers, also belong to the fluoropolymers. A frequent field of application for this class of polymers is oil, dirt, water and chemical resistance. 4 EU chemicals legislation: restriction of PFAS 09/2021 cially repellent finish of surfaces. Side-chain fluoropolymers are also used as coating materials for a variety of components in electrical and electronic devices. In addition, there is the large and extremely diverse group of gaseous and liquid low-molecular organic fluorine compounds. Here, too, a distinction is made between perfluorinated and polyfluorinated types. Gaseous representatives are used, among other things, as coolants (F-gases) and as insulating gases in electrical switch cabinets. Many liquid low-molecular PFAS are surfaceactive and therefore serve as surfactants and wetting agents (e.g. in fire extinguishing foams and as a component of release agents) but also as auxiliary chemicals in a wide variety of processes (e.g. in the semiconductor industry or fluoropolymer synthesis). The basic building blocks of fluoropolymers, the fluorinated monomers, also belong to this group of substances. Part 2 of the position paper explains which PFAS are currently used in which industries, why they are urgently needed and how they can be used safely. Evaluation of the proposed restriction approach Application of the group approach to the restriction of PFASs From the point of view of German industry, a blanket restriction of the entire PFAS substance group without a differentiated, substance- and application-specific risk assessment and solely due to the persistence of many PFAS is not appropriate. In order to ultimately achieve a sustainable overall balance of resource conservation and environmental impact, a restriction is only justified in cases where the risks to humans and the environment cannot be controlled. It should be taken into account that the PFAS definition covers substances with different properties and that not all PFAS are equally persistent, mobile or bioaccumulative. This puts almost risk-free chemicals on an equal footing with substances of very high concern ("SVHC") with properties that require regulation. A differentiated approach must urgently ensure that only substances whose use poses an unacceptable risk to the environment or human health are banned. Otherwise, there would be a risk, for example, that chemicals that play a crucial role in innovative technologies would be driven out of the market. In addition, legal regulations already exist for certain substances from the extensive family of fluorocarbon compounds in the POP Regulation and under REACH (e.g. PFOS, PFOA). In the context of the regulation of these compounds, their properties, restrictions and exemptions have already been discussed extensively. This discussion should not be repeated. In addition, there would be double regulation, e.g. in the area of refrigerants (F-gases), as their use is already regulated by the F-Gas Regulation (EU) No. 517/2014. 5 EU chemicals legislation: restriction of PFAS 09/2021 Application of the "essential uses" concept to PFASs The concept of "essential uses" will play a key role in the overall restriction process for PFAS. This concept is also an important element of the EU Commission's chemicals strategy. The PFAS restriction is to be the "model" for this within the framework of the chemicals strategy. According to the concept of "essential uses", only those uses that are indispensable - i.e. "essential uses" - are to be excluded from a group ban on the "most harmful chemicals". The specific criteria for "essential uses" are to be defined at EU level on the basis of the Montreal Protocol's definition of the ban on ozonedepleting substances1. According to the Montreal Protocol, a use is "essential" only if it is necessary for health or safety or critical for the functioning of society and there are no environmentally and health compatible alternatives. In addition to the concept of "essential use", the EU Commission announces in the Chemicals Strategy for Sustainability that it intends to accelerate restriction procedures to ban hazardous substances in consumer products and to apply the "generic approach to risk assessment" as a standard option. From BDI's point of view, both the concept of "essential use" and the "generic approach to risk assessment" are to be critically assessed. By extending the scope of restrictions based on the precautionary principle, the Commission would abandon the proven principle of substance-specific risk-based assessments. An extended application of the precautionary principle is not justified from an industry point of view and contradicts the regulatory system of the REACH Regulation, which is designed to regulate substance-specific uncontrollable risks. We therefore advocate the retention of the risk-based approach to assessment for the regulation of chemicals in the EU. It must continue to be possible to use hazardous substances in the future if they can be used safely and do not pose an uncontrollable risk. This is the only way to preserve the diversity of substances and thus the innovative strength and future viability of European industry. Furthermore, a discussion on "essential uses" is premature at this stage. Rather, the benefits to society as a whole of a risk-based approach should be discussed and highlighted. The fundamental question is whether the concept of "essential use", which was developed for a very limited group of substances with proven fatal global effects on the ozone layer, can be applied to such a large group of substances, only some of which have more precise knowledge of hazards and risks and some of which have no harmful properties at all. We also see the danger here that restrictions of entire groups of substances to "essential uses" violate the principle of proportionality. According to this principle, only those measures may be taken which are suitable and necessary for the achievement of the objective (in this case: health and environmental protection) and which do not lead to unreasonable effects. In any case, this excludes the prohibition of uses that do not lead to relevant exposures, even if they are not considered "essential". These include, for example, uses of PFASs as process chemicals, intermediates under strictly controlled conditions and substances in closed systems. 1 https://ozone.unep.org/treaties/montreal-protocol/meetings/fourth-meeting-parties/decisions/decision-iv25-essential-uses 6 EU chemicals legislation: restriction of PFAS 09/2021 that can be disposed of in a proper manner. Furthermore, it does not appear necessary to ban the entire group of PFAS in general, except for essential uses. Individual environmental protection measures and disposal strategies can be used to prevent their entry into the environment. Restricting the permitted use solely to uses that are necessary for the functioning of society (a term that is hardly tangible) would exclude uses that are of great benefit to society (e.g. by increasing the durability and energy efficiency of products and articles). In principle, the political restriction to essential applications also leads to an inhibition of future developments, as it is not an objective scientific method and does not allow for planning certainty. What is not considered essential today has no chance of being developed as an essential application at all at a later date, as this would subsequently undermine research and development in this area due to internal company compliance requirements. If the EU wants to continue to be a driver of innovation together with its industry, such a static concept cannot be effective. Importance of PFAS for innovative technologies and products In order to avoid misregulation and necessary amendments, restrictions on PFAS must be examined and implemented carefully and gradually. Complex chemical compounds for specific applications cannot be regulated simply and comprehensively without causing considerable obstacles and damage to Europe as a location for technology and business. It is imperative that regulation also assesses the risk and necessity of use and cannot be limited to intrinsic substance properties alone, which in some cases do not even apply to all PFAS. The industrial use of PFASs has significantly contributed to the further development of technologies and thereby z. The use of PFAS has also led to an improvement in climate protection, for example, as components have been designed to be more resource-efficient and with less mass, their service life has been increased and maintenance intervals have been reduced. PFASs are therefore an essential building block for the current innovative strength of industry, which will also be important in the future. This development would be set back by a broad ban on PFAS-based applications and products. NonEuropean manufacturers and their technological developments as well as sales and market shares would receive an unassailable boost and lead, as entire production chains would no longer be possible in Europe. Without the use of PFASs, new future-oriented and sustainable technologies for private and industrial applications are not possible according to current knowledge (see Part 2). The marketing of certain products containing PFASs with high safety relevance and key functions in industrial applications would also no longer be possible in the EU. In this respect, it should be emphasised once again that German industry supports regulations that prevent the release of PFASs into the environment. However, a general ban on all applications involving PFASs does not appear to be a suitable way of achieving the objective, as this would also jeopardise future technologies with high innovation potential in Europe as a location for technology and business, or make them impossible. 7 EU chemicals legislation: restriction of PFAS 09/2021 2. Examples from practice Affected industries and areas of application Per- and polyfluorinated substances are used in many industries primarily when increased ambient temperatures, reduction of frictional resistance or chemical inertness require it. PFAS are therefore often not replaceable by alternatives in many application areas due to the requirements. They are used for the efficient and resource-saving manufacture of products, as well as for increasing service life and reliability. PFAS thus make a decisive contribution to the longevity and safety of products. PFAS enable many innovative technologies that contribute to a sustainable European economic system. In many areas, PFAS are necessary for the fulfilment of official regulations, especially in safety-relevant areas in the plants. Only PFAS such as Teflon and PVDF are sufficiently pure and inert to enable the manufacture of high-tech products. Often it is the key components that are inconspicuous for the functionality of products, such as z. e.g. seals or membranes, in which PFAS are used. These "key components" are not only needed in products themselves, but also for the manufacture, transport or storage of other products, and this across all industries. In almost all industrial sectors, lubricants are used on moving parts to minimise friction and therefore minimise energy loss. These have to withstand extreme conditions and remain functional over the entire service life (e.g. of industrial plants), which is made possible by the use of PFAS. PFAS are also widely used in important future technologies such as lithium-ion batteries, fuel cells, hydrogen technologies or innovative medical devices, which will play a key role in achieving sustainability and environmental protection goals, as well as in healthcare. In the absence of suitable alternatives for these applications, PFAS are essential to achieve the goals of the EU Green Deal and to further increase the sustainability and efficiency of products and technologies. In the area of food contact and medicine, PFASs offer the prerequisite for the necessary hygiene by allowing the use of appropriate cleaners and minimizing residues on the material. The following table gives an overview of the affected industries and exemplary applications of PFAS. 8 EU chemicals legislation: restriction of PFAS 09/2021 Selected application examples Protective textiles in the field of personal protective equipment (PPE) for fire brigades, security and rescue forces and in medicine. Protective textiles for the protection of employees in action are used by the police, customs, the Federal Border Guard, the fire brigade and the Federal Armed Forces, but also in private institutions such as security services or aid organisations (e.g. the THW in Germany). Among other things, chemical protection suits are used to avert danger in the event of accidents and environmental damage. Special protective equipment is also necessary for workers in the chemical industry or fishermen. This requires numerous highly innovative special products with a combination of different properties: The textiles must often be simultaneously non-flammable, water-, oil-, chemical- and dirt-repellent. These properties must remain undiminished during the entire period of use and even after several industrial washes. The finish required for the longevity of the textiles makes an important contribution to sustainability. The combination of a water, oil, stain and chemical repellent finish can only be achieved with fluorinated polymers. No fluorine-free alternatives are yet available for the combination of an oil-, stain- and chemical-repellent finish. PFAS remain indispensable in many medical applications. Every operation in Europe must be performed covered. In Germany alone, more than 19 million patients are treated each year, of which approx. 40 % are operated on, according to Destatis. For example, membrane laminates are used for reusable medical products such as surgical gowns and drapes, as well as narrow-meshed microfilament fabrics, which must be equipped with PFAS to prevent the penetration of certain liquids that occur in the operating room. There is no adequate alternative to C6 or C8 textile auxiliaries to achieve the appropriate performance of these fabrics. Consequently, the entire sector of reusable surgical textile products in Europe is affected. Also plasters, which are offered as medical devices, are partially permitted with PFAS (C6 chemicals). This applies in particular to plasters and plaster fabrics that are offered rolled and must also function at warm ambient temperatures. Sun protection systems (e.g. awnings, sun sails, textile building envelopes) that are protected against weathering and biological infestation over the long term prevent rooms from heating up, they avoid the need for energy-intensive cooling and thus reduce energy consumption. They thus make a significant contribution to climate protection and to achieving the European climate targets. Filtration media (exhaust air and waste water treatment, clean rooms, pollen filters etc.) Filter media for dust separation in industrial processes are required for numerous important industries, from aluminum to cement production, from waste incineration to power generation and also in the food industry. The demands on the mechanical and chemical resistance of the filter media in particular are high, as they must provide their function undiminished over a long period of time in order to protect people and the environment from emissions. In order to maintain the filter effect even against different and changing pollutant flows, the filter is impregnated. A fluorine-free substitute for the impregnation is currently not available in the same quality, and the service life of alternatively impregnated systems is significantly shorter. 16 EU chemicals legislation: restriction of PFAS 09/2021 Semiconductor The use of PFAS-containing special formulations in the central process step of semiconductor manufacture, photolithography, is essential due to their high technical functionality and chemical properties. PFAS-containing process chemicals are, for example, photoresists and anti-reflective coatings, which are used in photolithography to create the structures on the silicon wafer. PFAS components are used in low concentrations (typically less than <1 %) are used in these special formulations. Photolithography processes are repeated several times (up to 60 times, depending on the technology) in the entire semiconductor manufacturing process, in order to create structures before applying further layers, which in total finally form the transistors and connections of the finished microchips on the silicon wafer. The use of fluoroalkylsilanes is essential for certain micromechanical semiconductor components (MEMS), in particular for MEMS acceleration sensors, due to their unique properties (formation of very thin layers with extremely low surface energy and correspondingly low adhesion forces combined with very high temperature stability). Anti-adhesion coatings based on fluoroalkyl silanes enable the fabrication of very precise sensors of small size with the required reliability. Such MEMS acceleration sensors are indispensable for automotive safety systems (airbag, ESP driving dynamics control) as well as for automated driving and other vehicle assistance systems. They are also used in a wide range of consumer electronics applications (smartphones, tablets, wearables). PFAS-containing process chemicals (PFHxA-related substances) remain in the finished product in some specific applications (MEMS, CMOS image sensors in automotive and medical technology, cameras, mobile phones, computers), but are encapsulated. Perfluorinated and polyfluorinated gases are used in the semiconductor industry for etching processes to structure wafers and for cleaning production equipment. The semiconductor industry has risk and safety management measures (e.g. closed production facilities) to prevent the release of chemicals at all stages of the manufacturing process. Waste from photolithography containing PFAS is usually collected on site and sent for proper disposal. There are no known alternatives for PFAS-containing special formulations in photolithography that have the same unique properties. Due to the high purity requirements in the production process, the use of fluoropolymers in the production equipment is necessary. The continued availability of PFAS in the production process is a fundamental prerequisite for the manufacture of semiconductors as a key technology and thus essential for the existing production supply chains (e.g. automotive) and the future innovation capability in Europe. lithium-ion batteries Rechargeable lithium-ion batteries, especially for use as traction batteries in vehicles, must meet high demands with regard to service life, charging speed, high energy density and permanent charging capacity. The materials used in lithium-ion batteries are therefore carefully selected so that they are stable at different ambient temperatures and high currents or energies. Fluorocarbon compounds are indispensable for meeting these requirements due to their stability. 17 EU chemicals legislation: restriction of PFAS 09/2021 A long service life of the lithium-ion batteries and thus the long-term stability of the materials used are also of decisive importance with regard to the secondary use of traction batteries as stationary energy storage systems, as envisaged in the Green Deal and the new EU Battery Regulation currently being drafted. The durability of the materials used also plays a decisive role for lithium primary batteries, which are often permanently installed in electrical devices and provide energy for operating times of up to 20 years. Currently, there are two main PFAS applications in modern Li-ion batteries: 1. PVDF (polyvinylidene fluoride) and PTFE (polytetrafluoroethylene) as binders for coating the cathode with active materials such as metal oxides. 2. Fluoro-organic additives in the electrolyte to improve the service life of the battery cell. Emissions of the PFAS compounds used into the environment are excluded during normal operation or when used as intended and are limited to malfunctions or accidents. The PFAS compounds are used in the manufacture of the battery cell in closed systems, are encapsulated in the battery cell during the use phase and are decomposed during recycling and the resulting fluorine compounds are removed via gas scrubbers. Fuel cells/electrolysis cells PFASs are used in various key components in fuel cells and electrolysis cells. This includes, for example, the proton exchange membrane, gas diffusion layer and sealing materials for gas, water and air paths. The proton exchange membrane consists mainly of PFSA-like ionomers with a reinforcement of PTFE. PFSA is the proton conducting material in the fuel cell membrane and electrode and enables the electrical transport of protons in the electrodes and membranes. This separates reactants and gases and ensures the electrical insulation of the half-cells. The proton membrane is the main functional unit and therefore mandatory for the functionality of a polymer electrolyte fuel cell. In the gas diffusion layer PTFE and FEP are used as hydrophobic agents to stabilize the water management and to separate the water circuits in the single cells of a fuel cell stack. PFAS are also used to seal the chambers within the fuel cell. Chemical and thermal stability are particularly important here. Currently, no alternatives are available for use in these key components, since, for example, only PFSA ionomers have reached technological maturity for use in proton exchange membranes for these functions in the harsh environment of a fuel cell. In gas diffusion layers, PTFE and FEP are required as electrochemically stable binders that can withstand the acidic conditions in the vicinity of the catalyst or the membrane of a fuel cell. The superior electrochemical stability of PTFE under different conditions in a fuel cell is of particular relevance here. There are currently no alternatives for this either. 18 EU chemicals legislation: restriction of PFAS 09/2021 Compressed gas metered dose inhalers for the treatment of lung diseases Compressed gas metered dose inhalers are used for the targeted administration of drugs via the lungs. For these highly effective drugs, precise dosing in the microgram range is necessary. In addition, this form of administration with propellant gas allows children and elderly patients to inhale life-saving drugs, among other things. Many patients would not be able to take other dosage forms due to their lung disease. In these pressurized gas metered dose inhalers PFAS are contained both as propellant gas and in the coating of the aluminum pressure container. During application, the propellant gas used must generate a pressure that allows fine distribution of the active substance and transports the active substance into the lungs. At the same time, the pressure must not cause any damage to the lungs. Only fluorinated propellants have this property. The inner coating of the aluminium pressure vessel must have as low a surface energy as possible in order to prevent the active pharmaceutical ingredient from adhering. Only in this way can a unfiorm dosage be achieved. This eliminates the risk of under- or overdosing for the patient. This can only be achieved by PTFE, FEP or PFA coatings. Food sector PFAS and especially PTFE are used in numerous components and assemblies in systems and equipment for the production and preparation of food. In most cases this is due to the special material property combination of high temperature resistance and approval for food contact. The combination of high temperature resistance/lubrication effect is the reason for its use in seals and plain bearings. An important application of PTFE is the use in hoses and pipes for the transport of liquids. These liquids are, for example, drinking water, coffee, milk and also steam. Some of these transported liquids are under a pressure of up to 12 bar in normal operation and must be able to withstand pressures of up to 20 bar in the event of a fault. The operating temperature can be assumed to be between 0 C and 160 C in normal operation. In case of need, temperatures of up to 200 C can occur. In some cases there is even a combination of 20 bar and 200 C. PTFE has proven to be an ideal material for such applications. But also in the area of food contact, PTFE materials are characterized by their very good compatibility in contact with food. At present, there are no alternative materials for safe use in contact with food. Switching to other materials would result in an earlier failure of the components. Heat pumps In order to achieve the European climate targets, the switch from fossil fuels to electrically driven heat pumps is one of the decisive measures. With the implementation of the F-Gas Regulation (EU 517/2014) in recent years, there has been an almost complete conversion of components and equipment concepts to new synthetic refrigerants (HFOs). Additional restrictions on the use of refrigerants via PFAS regulation would make it impossible to achieve the EU climate targets for 2030. 19 EU chemicals legislation: restriction of PFAS 09/2021 In Europe, a broad renovation wave is underway in the building sector. The focus is particularly on multifamily houses. The heat pump industry has just started to implement heat pumps in this sector and has adapted the necessary properties and performance sizes of the products for use in these buildings. To ensure safe and efficient operation of the heat pumps, the use of HFOs is necessary. A widespread use of natural refrigerants as an alternative cannot currently replace the use of HFOs for technical reasons due to safety requirements and the desired efficiency requirements. Paints and varnishes Fluoropolymers, especially PTFEs, are also used in paints, coatings and printing inks. They help to give the coatings important properties such as scratch and abrasion resistance as well as thermal and chemical resistance, which are essential for the specific end uses. In some cases, the compounds are only used in very small quantities, but are of great technical importance. This applies, among others, to the fields of powder coatings, industrial coatings, automotive, corrosion protection and printing inks. Safety-relevant fasteners (e.g. screws, nuts, washers, clips, etc.), whose functionality can only be guaranteed by coatings with fluoropolymers according to the current state of the art, are used, for example, in the assembly of chassis and tires. The coating ensures that the required defined assembly conditions (including pretensioning force and clamping force) are fulfilled so that the connection maintains its function and the necessary safety. Coatings containing fluoropolymer are also essential for the function of seat belt restraint systems in cars, for example. They prevent the belt from sticking to the components in the event of an accident due to the high thermal energy involved, thus guaranteeing that the belt remains functional. Furthermore, this coating ensures that the belt buckle can still be operated and opened under load after an accident. In the case of printed products, especially in offset printing, various problems and qualitative impairments can occur without suitable rub protection. On the one hand, there are visible rubbing problems in the printed product, for example scratches, "smearing" and depositing ink on surfaces that are actually unprinted. These rubbing problems can impair the quality of the printed product to such an extent that it can no longer be sold, which can result in considerable financial damage. On the other hand, contamination and deposits also occur in the press and in finishing, especially on chill rollers, formers and spiral bars, which lead to significantly more waste and result in increased cleaning effort, which is often very time- and solution-intensive. 20 Imprint Federation of German Industries (BDI) Breite Strae 29, 10178 Berlin www.bdi.eu T: +49 30 2028-0 Editorial Environment, Technology and Sustainability Officer T: BDI document number: D1443 EU chemicals legislation: restriction of PFAS 09/2021 21