Document KGJpjGjOQ7nG3KgXY9VV7mMBN

 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Applica on for deroga ons from PFAS REACH restric on for specific uses in railways Contents 1) Introduc on .................................................................................................................................... 4 The European rail sector ..................................................................................................................... 4 Preliminary statement and structure of the document ...................................................................... 7 List of abbrevia ons and chemicals .................................................................................................... 9 2) Where are PFAS used in railways and why?.................................................................................. 10 2.1) PFAS used in applica ons affec ng the proper func oning related to the safety of transport 18 2.1.1) Sliding and guiding applica ons..........................................................................................18 2.1.2) Sealing applica ons ............................................................................................................19 2.1.3) Coa ngs, adhesives and finishing .......................................................................................21 2.1.4) Noise dampening components ...........................................................................................22 2.1.5) Detailed applica ons per main system ...............................................................................22 2.2) Fluorinated gases used ..............................................................................................................32 2.3) PFAS used in electronics and semiconductors ........................................................................... 33 2.4) PFAS used in the energy sector..................................................................................................35 2.5) PFAS used in lubricants .............................................................................................................. 37 2.6) PFAS used in TULAC (Tex le, upholstery, leather, apparel and carpets)....................................38 3) Analysis of alterna ves .................................................................................................................39 3.1) Alterna ves to PFAS used in applica ons affec ng the proper func oning related to the safety of transport .......................................................................................................................................39 3.1.1) Sliding and guiding applica ons..........................................................................................39 3.1.2) Sealing applica ons ............................................................................................................40 3.1.3) Coa ngs, adhesives and finishing .......................................................................................42 3.1.4) Detailed applica on per main system.................................................................................42 3.2) Alterna ves to fluorinated gases ...............................................................................................45 3.2.1) Air condi oning and heat pumps........................................................................................45 3.2.2) Refrigera on .......................................................................................................................46 3.2.3) Fire suppressants ................................................................................................................46 3.2.4) Electrical switchgear ...........................................................................................................46 3.3) Alterna ves to PFAS used in electronics and semiconductors ..................................................47 3.3.1) Wires and cables .................................................................................................................47 3.3.2) Electronic components, semiconductors and coa ngs ......................................................48 1 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.3.3) Various electronic assemblies (capacitors, plugs, transducers...) in the brake control....... 48 3.3.4) Cables for magne c coil, used in valves for pressure control of the hydraulic brake.........48 3.4) Alterna ves to PFAS used in the energy sector .........................................................................49 3.4.1) Alterna ves to PFAS used in ba eries ................................................................................49 3.4.2) Proton exchange membrane (PEM) fuel cells.....................................................................51 3.5) Alterna ves to PFAS used in lubricants......................................................................................52 3.6) Alterna ves to PFAS used in TULAC (Tex le, upholstery, leather, apparel and carpets) ...........52 4) Possible consequences: socio-economic impact assessment of the proposed PFAS restric on for railways value chain ..............................................................................................................................53 Scenario 1: No deroga on at all........................................................................................................53 Scenario 2: Proposed deroga ons are confirmed, but no other specific deroga ons .....................53 Scenario 3: No deroga on for spare parts and maintenance ac vi es............................................54 Possible consequences: environmental and human health consequences......................................55 5) Requests for deroga ons and for a review clause ........................................................................56 5.1) Applica ons affec ng the proper func oning related to the safety of transport .....................56 5.1.1) Sliding and guiding elements ..............................................................................................56 5.1.2) Sealing applica ons ............................................................................................................57 5.1.3) Coa ng, adhesives and finishings .......................................................................................57 5.1.4) Noise dampening components ...........................................................................................58 5.1.5) Detailed applica on per main system.................................................................................58 5.1.6) Electrical engineering & informa on technology ...............................................................58 5.1.7) Safety equipment (including fire preven on and protec on) ............................................59 5.2) Applica on of fluorinated gases ................................................................................................60 5.3) Electronics and semiconductors ................................................................................................61 5.3.1) Coa ng, solvents and cleaning ...........................................................................................61 5.3.2) Electronic components .......................................................................................................61 5.3.3) Semiconductors ..................................................................................................................61 5.3.4) Wires and cables .................................................................................................................62 5.3.5) Various electronic assemblies (capacitors, plugs, transducers...) in the brake control....... 62 5.3.6) Cables for magne c coil, used in valves for pressure control of the hydraulic brake.........62 5.4) Energy sector .............................................................................................................................63 5.4.1) Ba eries ..............................................................................................................................63 5.4.2) Proton exchange membrane (PEM) fuel cells.....................................................................63 5.5) Lubricants...................................................................................................................................64 5.5.1) Greases ...............................................................................................................................64 2 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.5.2) Low-viscosity lubricants ...................................................................................................... 64 5.6) TULAC (Tex le, upholstery, leather, apparel and carpets) .........................................................65 5.7) Request for a review clause and summary of deroga on requests ..........................................66 6) Annex ............................................................................................................................................68 3 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 1) Introduc on The European rail sector The following associa ons have jointly prepared this contribu on: Associa on of European Rail Rolling Stock Lessors (AERRL), Alliance of Passenger Rail New Entrants (ALLRAIL), Community of the European Railways and Infrastructure Companies (CER), European Rail Infrastructure Managers (EIM), European Rail Freight Associa on (ERFA), Interna onal Union of Wagon Keepers (UIP), Interna onal Union for Road-Rail Combined Transport (UIRR), Interna onal Associa on of Public Transport (UITP) and European Rail Supply Industry (UNIFE), hereina er "the European rail sector''. Founded in 2021, the Associa on of European Rail Rolling Stock Lessors (AERRL) is a representa ve body from the railway sector ac ng at Union level. Our mission is to promote interoperable and safe European rail rolling stock (passenger trains and cargo/passenger locomo ves) by addressing technical, opera onal, economic, legal and scien fic issues and ma ers rela ng, directly or indirectly, to locomo ves, passenger trains, (mul ple-units and coaches) operated in the European Union and Switzerland. ALLRAIL, the Alliance of Passenger Rail New Entrants in Europe, is a recognised associa on that represents independent passenger companies, including rail operators, cket vendors and rolling stock lessors since 2017. We advocate for faster and effec ve market opening in passenger rail in Europe in order to accelerate modal shi to rail. The Community of European Railway and Infrastructure Companies (CER) brings together railway undertakings, their na onal associa ons as well as infrastructure managers and vehicle leasing companies. The membership is made up of long-established bodies, new entrants and both private and public enterprises, represen ng 78% of the rail network length, 81% of the rail freight business and about 94% of rail passenger opera ons in EU, EFTA and EU accession countries. CER represents the interests of its members towards EU policy makers and transport stakeholders, advoca ng rail as the backbone of a compe ve and sustainable transport system in Europe. 4 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 EIM, the Associa on of European Rail Infrastructure Managers, was established in 2002 to promote the interests of the infrastructure managers in Europe. EIM's primary goal is to promote the growth of rail traffic and the development of an open, sustainable, efficient, customer-oriented rail network in Europe. ERFA, is the European Associa on represen ng European private and independent railway companies. ERFA members share a commitment to work towards a non-discriminatory, compe ve and innova ve Single European Railway Area. Founded in 1950, the UIP - Interna onal Union of Wagon Keepers - is the umbrella associa on of na onal associa ons from 14 European countries, thus represen ng more than 250 freight wagon keepers and En es in Charge of Maintenance (ECMs). As the voice for more than 234,000 rail freight wagons which perform 50 % of the rail freight tons-kilometres throughout Europe, UIP represents half of the whole European wagon fleet and one of the most important resources for rail freight transporta on in Europe. Founded in 1970, the Interna onal Union for Road-Rail Combined Transport represents the interests of European road-rail Combined Transport Operators and Transhipment Terminal Managers. Road-Rail Combined Transport (CT) is a system of freight forwarding which is based on efficiently and economically inser ng electric rail into long-distance (road) transport chains through the use of intermodal loading units (ILU). 5 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 UITP is the interna onal associa on represen ng public transport stakeholders. In the European Union, UITP brings together more than 450 urban, suburban and regional public transport operators and authori es from all Member States. We represent the perspec ve of short distance passenger transport services by all sustainable modes: bus, regional and suburban rail, metro, light rail, tram and waterborne. Visit our website: uitp.eu Opera ng in Brussels since 1992, UNIFE represents European train builders and rail equipment suppliers. The associa on advocates for more than 110 of Europe's leading rail supply companies - from SMEs to major industrial champions - ac ve in designing, manufacturing, maintaining and refurbishing rail transport systems (trains, metros, trams, freight wagons), subsystems and related equipment. UNIFE also brings together na onal rail industry associa ons from 12 European countries. UNIFE members have an 84% market share in Europe and supply 46% of the worldwide rail produc on, represen ng more than 400,000 jobs in Europe. 6 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Preliminary statement and structure of the document The European railway sector supports the European Commission's Chemicals Strategy for Sustainability. The sector supports efforts to restrict PFAS (Per and polyfluoroalkyl substances), which pose unacceptable risks to human health or the environment, such as perfluorooctanoic acid (PFOA). The rail sector is committed to continuously improving its products and services' environmental compatibility and safety. However, the PFAS restriction proposal, submitted by the five dossier submitters to ECHA and aiming at amending the REACH Regulation, would significantly impact the European railway sector. Failure to grant exemptions or derogations would mean an immediate (18 months after entry into force) and total ban of PFAS for crucial rail applications. As these applications are critical for various essential rail components and are also required for spare parts and maintenance activities, the ban will trigger a cascade of far-reaching consequences. Without the use of some key PFAS, the rail sector would not be able to operate or be at least significantly less efficient. It can lead to serious adverse effects on the life of Europeans and the European economy. In addition, more expensive technologies would have to be used, drastically reducing competitiveness in non-EU markets and increasing the cost of transitioning to more sustainable transport within the EU. The high cost due to a universal PFAS ban may negatively impact the deployment of rail solutions. Ultimately, this could hamper the crucial importance rail has to play in achieving the ambitious decarbonisation goals of the Sustainable and Smart Mobility Strategy and of the EU Climate Law. For these reasons, the European rail sector supports the following improvements to the PFAS restriction proposal: - The current list of derogations should be extended to consider the relevance of PFAS for a wide range of non-replaceable and indispensable applications in the railway industry. - Risk-based and substance-based approaches should be preferred for banning the most harmful PFAS instead of a universal restriction, regardless of their toxicity and risk profile. - The European rail sector supports the idea of introducing an information obligation for PFAS before the introduction of targeted restrictions. As PFAS are currently non-declarable substances, this legal requirement will include all relevant uses in the assessment and apply any necessary exemptions. - A longer transition period should help to develop durable and safe PFAS-free alternatives and to verify and certify such options to fulfil all other applicable legislation. - A clearly defined procedure for applying, reviewing, and extending derogations should be determined. - The use of PFAS should remain possible as long as there is no full-scale availability of suitable and technically developed substitutes. There should be a long-term general derogation with review clauses before the expiration of the derogation for the use of risk-free PFAS. - The "repair-as-produced" principle should be applied, with indefinite derogations for spare parts, refurbished parts, equipment, and products already placed on the market. - Ensuring effective enforcement through the market surveillance system should be central to guarantee a level playing field between competitors, especially from third parties nonaffected by the PFAS restriction. 7 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 The European rail sector's contribution provides feedback to the public consultation on the latest restriction proposal of 22 March 2023. It is essential to note that the specific usage of PFAS products in the railway industry may vary depending on regions' specific railway systems, regulations, and engineering requirements. After this introduction (Section 1), the contribution details what types of PFAS are used in the railway sector and why they are essential, with illustrations (Section 2). Then, the European rail sector focuses on whether non-PFAS alternatives are available, but few are compatible with the safety standards of its products and services (Section 3). In Section 4, the contribution provides a socio-economic impact assessment of the proposed PFAS restriction for the railway value chain. Three scenarios have been identified: - Scenario 1: No derogation at all, - Scenario 2: Proposed derogations are confirmed, but no other specific derogations, - Scenario 3: No derogation for spare parts and maintenance activities. In these three scenarios, the financial and social consequences would be catastrophic for the mobility of people and goods in Europe.1 The European rail sector could not continue to operate trains without some crucial PFAS listed in Section 5. The current PFAS restriction proposal lacks several derogations for essential PFAS applications. The European rail sector requests derogations with review clauses for specific applications where PFAS are non-replaceable and indispensable in the railway industry. These review clauses will provide sufficient time for the railway industry to identify and implement alternative non-PFAS solutions if such alternatives can be found. The list of derogations requested is summarised in Table 1 in section 5.8. 1 More details on the economic impacts of the ban on PFAS could be provided on request - contact UNIFE. 8 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 List of abbrevia ons and chemicals ETCS ETFE FC-72 FC-3284 FEP F-gases FKM FPM HFO HNBR HVAC OEM PA PEM PFAS PFPE PFSA PFOA PI-FEP POM PTFE PVDF NBR Novec 649 REACH R-290 R-744 European Train Control System Ethylene tetrafluoroethylene 1,1,1,2,2,3,3,4,4,5,5,6,6,6-Tetradecafluorohexan Perfluor(N-methylmorpholin) Tetrafluorethylen-Hexafluorpropylen-Copolymer Fluorinated greenhouse gases Fluorocarbon-based elastomers / rubbers Fluorocarbon-based elastomers / rubbers Hydrofluoroolefin Hydrogenated nitrile butadiene rubber Heating, ventilation and air-conditioning Original equipment manufacturer Polyamide Proton exchange membrane Per- and polyfluoroalkyl substances Perfluoropolyether Perfluoro sulfonic acid Perfluorooctanoic acid Thermoplastic polyimide (PI) fluorinated ethylene propylene (FEP) Polyoxymethylene Polytetrafluoroethylene Polyvinylidene fluoride Nitrile butadiene rubber 1,1,1,2,2,4,5,5,5-Nonafluor-4- (trifluormethyl)-3-pentanon Regulation 1907/2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals Propane refrigerant number (ASHRAE number) CO2 refrigerant number (ASHRAE number) 9 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2) Where are PFAS used in railways and why? Different PFAS are used in the railway sector: x For passenger rolling stock (see Figures 1 and 2) x For freight rolling stock (see Figures 3 and 4) x For the infrastructure and signalling (see Figures 5, 6 and 7) Image: Knorr-Bremse Figure 1: Schema c of a rolling stock with its main components - circled in red where PFAS are present. 10 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Image: Alstom Figure 2: Schema c of a rolling stock with its main components - circled in red where PFAS are present, in yellow poten al presence. 11 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Image: VTG Figure 3: Example of a chemical tank wagon and its sealing assemblies with PFAS (circled in red). 12 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Image: Ermewa Figure 4: Example of a gas tank wagon and its sealing assemblies with PFAS (circled in red). 13 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Image: Alstom Figure 5: Schema c of rolling stock with its on-board signalling components, wayside train monitoring system and the control centre - circled in red where PFAS are present. 14 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Image: Alstom Figure 6: Schema c of rolling stock with onboard electronic components - circled in red where PFAS are present. 15 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Switch cabinet for trailing repor ng unit, turnout diagnos cs and end posi on detector Trailing repor ng unit Hydraulic pressure equaliza on Electrical distributors Turnout diagnos cs End posi on detector 16 Posi oning cylinder Point machine Cables European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Image: voestalpine Railway Systems GmbH Figure 7: Exemplary schema c of signalling and infrastructure - circled in red where PFAS are present. Figure 7 shows components of an exemplary turnout system for which PFAS are necessary, including safety and performance-related monitoring. It should be noted that different signalling and monitoring systems may differ in look. In some cases, not all components and systems are directly visible in the track like in the exemplary picture. Nevertheless, the use of PFAS is the same and cri cal for the different included signalling components. In the infrastructure, PFAS are associated with and vital for signalling components. This includes electronics like sensors, cables and point machines (also electrohydraulic systems), which are necessary for monitoring and opera ng turnouts. They operate the turnout system (point machine, posi oning cylinder, hydraulic pressure equalisa on), detect the correct posi oning of the turnout and the train (end posi on detector, trailing repor ng unit) and monitor the turnout (turnout diagnos cs). Those safety and monitoring cri cal components are vital for a safe and efficient railway network. Failures could lead to safetycri cal situa ons and heavy accidents. Please refer to the later chapters where such uses are described together with similar uses in rolling stock and why PFAS are essen al due to their sealing and gliding characteris cs. 17 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1) PFAS used in applica ons affec ng the proper func oning related to the safety of transport One of the main characteris cs of the railway sector is that it is requested to comply with the highest safety and reliability standards. As a mass transport system for people and goods, the safe opera on of the railway system under all environmental condi ons must always be ensured. Certain essen al elements used to guarantee the safety of the train are based on the use of materials containing PFAS due to their excep onal characteris cs under extreme condi ons. In some PFAS applica ons listed below, there is no permanent exposure to the environment throughout their useful life, as the components men oned above are contained within enclosures that are opened only during planned maintenance inspec ons and overhauls. The generic applica ons are detailed in sec ons 2.1.1 to 2.1.4, and specific applica ons per main system are presented in sec on 2.1.5. 2.1.1) Sliding and guiding applica ons 2.1.1.1) Sliding elements made from polytetrafluoroethylene (PTFE) for rubber sealing extrusions, technical gangway fabrics, and flexible tubes Using this fluoropolymer allows several func ons, such as the safe passage of passengers between vehicles during the opera on of the trains guiding and protec ng a rope or cable. Sliding parts such as flexible PTFE tubes They are used in several systems to guide and protect a rope or cable. Sliding plates inside bogies connect couplers, sliding steps, or sliding plates in air spring systems. They are used because of their low fric on values. As an essen al part of an air spring system, PTFE sliding plates ensure low fric on values in deflated opera on mode. This is necessary for safety against derailment of the train. Thus, PTFE sliding plates are crucial for all products equipped with air spring systems. Slide plates PTFE slide plates are commonly employed in railway infrastructure. These materials possess excellent self-lubrica ng proper es and low fric on coefficients, making them suitable for sliding applica ons. Slide plates are u lised in rail expansion joints, bridge bearings, and other components to facilitate smooth movement and reduce fric on between surfaces. 2.1.1.2) Guiding segments They are used in the dampers at the rod guide level and around the piston. They ensure good guidance and, therefore, good alignment of moving parts. The guiding segment contains PTFE, which guarantees a good fric on coefficient between the rod guide, the piston rod and the working tube/piston. Guiding segments in PTFE withstand severe constraints like the high-speed movement of the piston and the piston rod, the temperature in service from -50C to + 70C. Moreover, PTFE substance leads to an increase in the expected lifespan. Guiding segments work in the specific oil for dampers. 18 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Wear pads PTFE wear pads are employed in railway systems to reduce fric on and wear between moving parts. These materials have high durability and low fric on characteris cs, making them suitable for applica ons such as bogie systems, couplers, and suspension components. Wear pads help prolong the lifespan of these parts and minimise maintenance requirements. 2.1.2) Sealing applica ons 2.1.2.1) Applications in the bogie and transmission Seals containing fluoroelastomers (par cularly Fluorocarbon-based elastomers, FKM and FVMQ) have been used for years to guarantee the sta c and dynamic sealing of railway gearboxes fi ed to bogies. These gearboxes ensure the transmission of the trac ve effort of the bogie generated by the electric motor in both opera on direc ons and are directly connected to the axle and wheels. Subject to high torques to be transmi ed and high rota onal speeds, as well as very severe reliability and availability constraints, these railway gearboxes use synthe c and semi-synthe c extreme-pressure oils with several addi ves to lubricate the gears and bearings and ensure the dissipa on of calories. The opera ng temperature of these oils can vary from -50C to +120C for the most severe applica ons. 2.1.2.2) Applications in the traction motors Sealing gaskets made of FKM, FVMQ or FPM (fluoroelastomers) seal bearings have excellent chemical stability in contact with lubrica ng greases and oils, las ng ten years. 2.1.2.3) Applications in the dampers Seals containing PFAS (FKM or FPM) are used on dampers to ensure good sealing. Seals containing PFAS work under severe constraints like the high-speed movement of the piston and then the piston rod, with temperature in service from -50C to + 70C. They are in contact with specific oil for dampers. Dampers ensure good dynamic behaviour of the trainsets, the filtering of vibra ons rising in the structure, and good comfort for the passengers. The dampers are designed to work for ten years before the first maintenance step. Un l now, with PFAS substances included in the composi on of the seal material, ten years or 3.6 million kilometres without any maintenance have been reached. Moreover, FKM materials are the only known materials that ensure compliance with legisla on (e.g. Rolling Stock Noise: Direc ve 1304/2014/EU; Pressure Safety: Direc ve 2014/68/EU) and relevant specifica ons regarding e.g. withstanding low and high opera ng temperatures (> 260C), resistance to aggressive fluids (e.g. oils, diesel, ethanol, etc.), vibra on fric on, and abrasion resistance. 2.1.2.4) Applications in the traction transformer The trac on transformer is filled with dielectric-type mineral oil (according to EN 60296) or synthe c ester oil (according to EN 61099). Seals containing fluoroelastomers (FKM or FVMQ) have been used for many years to guarantee sta c sealing in the transformer. The seals have been tested and validated for their resistance and compa bility with the different types of oil used and to be suitable for a temperature range of -50C to +150C. The seals must maintain a perfect seal for 15-20 years and be replaced at the transformer's mid-life. 2.1.2.5) Applications in the doors Rubber-based sealings ensure the proper ghtness of train coaches and driving cabs. 19 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1.2.6) Applications in the cooling system Cooling system for air condi oning system or clima c chamber, such as the materials of the func onal and sealing components of the refrigerant circuit and the refrigerants. 2.1.2.7) Applications in rail tank wagons PFAS is used in sealing elements within the metallic valves and equipment that are fi ed to the tank opera onal openings and are crucial to the containment of the cargo of liquids and liquefied gases, most of which are regulated as dangerous goods (RID). S ll, other substances, including food-grade and non-regulated, are transported in tank wagons. The primary sealing materials are PTFE, FKM, FEP and PFA in solid form and PTFE/PFA envelope on an elastomer core. Seals and O-rings are of PTFE, FEP, and PFA and fi ed within the body of the valve and access hatch. Sealing elements can be found in the airline assembly's bo om valve assembly and access hatch seals. Sealing elements of tank wagons are made of PFAS because of their high thermal and chemical resistance and the fact that they have very low surface tension and are thus water and oil-repellent as well as abrasion and wear-resistant at the same me. It is es mated that the materials used for tank wagons are an average of 82% non-PFAS and 18% PFAS. UIP es mates that up to 8,500 kg of PFAS material is used per annum for sealing elements on tanks of rail tank wagons in Europe.2 The solid form does not allow the materials to shred or degrade to par cles, as with other industries, such as food packaging, clothing, and fire-figh ng foams. Furthermore, the sealing element is incorporated into the tank and cannot enter the environment. During the mandatory RID maintenance check, sealings are replaced at least every eight years (complete check-up) or even earlier if needed during the intermediate check-up a er four years. As regards the end of the life-cycle phase, maintenance facili es dispose of the sealing materials as industrial waste since there is no recycling requirement. The percentage that is disposed of in landfills or municipal incinera on is unknown. Given that sealing elements are solid materials and their persistence, they could be separated by our workshops for disposal of approved facili es if required. For a more detailed presenta on, please refer to the contribu on of UIP (ECHA's consulta on reference number 6213). 2 Explanation of calculation: the European rail sector assumes that a tank wagon has around 0.5 kg of PFAS per wagon which needs to be replaced every 6 years (average of the mandatory periodic revision time of 4 and 8 years for tank wagons) of the current tank wagon fleet of 82,477, 0.5 kg x 82,477/ 6= 6,873 kg) + (sealings in new built per year: 3,000 new tank wagons x 0.5 kg= 1,500 kg. 20 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1.2.8) Applications in hose assemblies, joint heads, couplers, threads, and related applications They depend on PTFE and PVDF as they are components that come in contact with aggressive media. Using per fluoropolymers reduces the risk of degrada on or corrosion, thus cracking of materials or safety-relevant parts due to their inertness to aggressive fluids (e.g. hydraulic oils, gear oils, brake fluids, coolants, refrigerants) or because of their applicability in extremely low/high or changing temperature ranges. 2.1.3) Coa ngs, adhesives and finishing 2.1.3.1) Applications in the liner on ball joints, rods and bearings PTFE is a liner on ball joints, rods and bearings. The rod aims to transfer movement between two components, avoid system rupture by allowing more degrees of freedom, such as linear rota on and conical movement through ball joints and bearings, and carry the mechanical and angular load of the structure. The defini on of the ball joints, rods and bearings considers the maintenance requirements, life cycle cost and passengers' comfort and security requirements: ten years of service life and no noise during the service me. To avoid rupture of the ball joint and rod, a lubrica on of the surface between the inner ball and the outer ring/ball is required. Liners and seals PTFE liners and seals are u lised in railway equipment, such as valves and pumps, to provide chemical resistance and reduce fric on. These materials have excellent resistance to abrasion, chemicals, and high temperatures. They help ensure the reliable and efficient opera on of various fluid handling systems in railways. 2.1.3.2) Applications in the painting and corrosion protection in the air supply unit Different parts in the air supply unit require specific surface protec ons. PFAS are used to guarantee highly durable and weatherable surface treatments, an s ck and an corrosive coa ngs, the ability to form a second coat on a first coat and weather resistance paint. 2.1.3.3) Applications in the surface treatments (zinc flake coating) PFAS are used in different surface treatments. One necessary surface treatment for corrosion protec on is the zinc flake coa ng. A topcoat containing PVDF is applied onto a base coat in this applica on. Compared to electropla ng, hydrogen embri lement is avoided, which would occur during the treatment. Furthermore, the PVDF in the topcoat ensures a defined fric on coefficient of fasteners. It is essen al to keep the installa ons fixed on the train, especially underframe-mounted devices, to avoid falling onto the tracks. This is a safety-cri cal point for which there is currently no alterna ve known. 2.1.3.4) Applications in the plain bearings Plain bearings used in lubrica on-free applica ons depend on PTFE and PVDF, e.g. to ensure emergency running proper es because of their unique low fric on values. Thus, the sliding proper es of the lubrica on-free bearings rely on the polymer materials themselves. 21 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1.4) Noise dampening components PTFE products are u lised to develop noise-dampening components for railways. Their low fric on proper es and ability to absorb vibra ons and dampen noise make them suitable for rail pads, bushings, and vibra on isolators. These components contribute to reducing noise pollu on associated with train opera ons. 2.1.5) Detailed applica ons per main system 2.1.5.1) Applications in the air supply unit Knorr-Bremse Figure 8: loca on of the air supply unit in a train. Relief valve used in the air supply unit It supplies a train's brake system with compressed air, a func oning sanding system, suspension, etc. Within the compressor, as part of the air supply system, the func on of the relief valve is to protect the compressor against impermissibly high pressure. The protec ve valve is screwed into the pressure chamber of the compressor. PFAS is present as FPM/FKM Seal on surfaces where high-temperature and ageing resistance are needed, e.g. NBR is unsuitable. Piston ring/piston They are used in the compressor within the oil-free air supply unit, which supplies the train with compressed air for brakes, a func oning sanding system, suspension, etc. The movement of the piston, including the piston ring within the cylinder of an oil-free compressor, provides the compressed air by suc oning and compressing the air. To ensure the system's func on, the fric on between the cylinder and piston/piston ring must be as low as possible. This is key to obtaining a reliable system with reduced waste by the high durability of the components and high energy efficiency provided by low fric on within the system. In conven onal oil-lubricated compressors, oil is excreted into the environment. The idea of an oil-free compressor is to avoid this. Therefore, the oil lubrica on of the fric on pairing piston/cylinder must be replaced. In the environmentally friendly oil-free compressor, PTFE is present in piston rings and surfaces. The oil-free compressor technology is a milestone in environmental protec on. PFAS, par cularly PTFE, is the central key to replacing oil lubrica on. 22 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 An extremely low fric on coefficient in combina on with high-temperature resistance and mechanical strength is needed. Simultaneously, the coa ng must not have an abrasive effect on the counterpart. Here, PTFE piston rings and PTFE-coated pistons are used. Knorr-Bremse Figure 9: Le : Piston with piston ring in a cylinder of an oil-free compressor, Right: Screws of an oil-lubricated screw-compressor. Knorr-Bremse Figure 10: Oil free compressor. Knorr-Bremse Figure 11: oil-lubricated screw compressor. 23 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Oil pipe, screw fi ngs in the air supply unit PFAS is used as FPM/FKM Seal on surfaces where (high and low) temperature resistance, ageing resistance, oil, grease and water resistance are needed. The func on of the oil pipe is to transport the oil with high temperature and pressure through the oil flow system. Screw fi ngs are required to ensure the system's ghtness, i.e., to prevent leakages of oil/compressed air, as the case may be. One well-known fluoroelastomer, FKM or VitonTM, is commonly used across all industries. These rubber compounds produce one of the best chemical and high-temperature resistance materials of all the rubber families. Casing in the air supply unit FPM/FKM in the casings and wires and cables are explicitly used in the electromechanics installa on of an air supply unit. The PFAS provides high-temperature resistance in some counter connectors on the sealing area. Needle bearings in the air supply unit They are used in air supply units. For oil-free piston compressors, PFAS are present as PFPE/PTFE in the grease, which is used to lubricate the rolling bearings of the compressor. Without grease bearings, the compressor is not able to operate. As a long life me is claimed for railway equipment, aging-resistant greases are needed. Also, high temperatures can occur in the applica on, so high-temperature greases are required. PFPE grease fulfils requirements for ageing resistance and high-temperature usage. Sha sealing Rings/O-rings in the air supply unit Both items are used in air supply units. For the oil-free piston compressor, PFAS are present in the sealing rings used to seal the compressor's rolling bearings. Without sha sealing rings, bearings/compressors are not able to operate. As a long life me is claimed for railway equipment, wear-resistant materials are needed. Also, high temperatures can occur in the applica on, so hightemperature materials are required. FPM/FKM fulfils requirements for wear resistance and hightemperature usage. In the case of the O-rings, PFAS is present and used as an FPM/FKM seal on surfaces where hightemperature resistance and ageing resistance are needed, e.g., NBR is not applicable. Valve cones in the air supply unit This is a check valve for air dryer units. The func on is to restrict backflow from the system and from one reservoir to another during opera on. Without this valve, the unit is not working. The valve is made from FKM/FPM to fulfil the following requirements: cold and high temperature (excellent thermal proper es) stability, good resistance against chemicals and oils (due to oil-lubricated systems, the oil resistance is a must) and good impact and wear resistance (check valve shall endure at least one million cycles before overhaul). Safety valve, minimum pressure valve in the air supply unit The valve seat of the minimum pressure valve is made of FPM/FKM. Its func on is to ensure that a system has a minimum opera on pressure. The safety valve is a safety-relevant product and shall comply with regula ons and laws such as 2014/68/EU (Pressure Equipment Direc ve). The valve seat is made of FKM (Vi 899), and an O-ring in the assembly is made of PTFE. These PFASs are used to comply with the following requirements: - Cold and high temperatures (excellent thermal proper es), 24 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 - Good resistance against chemicals and oils. Due to oil-lubricated systems, oil resistance is essen al, - Addi onally, for the safety valve: good impact and wear resistance. The safety valve may open rapidly, which shall be endured by the valve seat. 2.1.5.2) Applications in the brake control Knorr-Bremse Figure 12: loca on of the brake control in a train. O-rings in switching cylinders O-rings consis ng of FPM/FKM are used in changing cylinders. The switching cylinder switches the shun ng (reversing) modes for the locomo ve (normal opera on or locomo ve is trailed). The O-ring is located inside the housing of the switching cylinder, and its func on is to seal the equipment to avoid pressure loss. Guides (solenoid valves) Guides (solenoid valves) coated with PTFE are used in magnet valves and pistons. The PTFE coa ng allows low fric on guidance. 25 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1.5.3) Applications in the bogie equipment Knorr-Bremse Figure 13: loca on of the bogie equipment in a train. Slide bands, bushes, bandages, gaskets, swivel bearings, and different rings (spacing ring, thread seal ring, etc.) in the bogie equipment Slide bands, bushes, swivel bearings and rings are used in brake calliper units and tread brake units, and bandages in brake cylinders, gaskets, and track brake units. These items are made of PTFE in different variants (pure PTFE, PTFE with Carbon, PTFE with bronze, etc.), and some of them (e.g. Orings in brake calliper units and tread brake units) are made of FPM/FKM to reduce fric on and wear between internal components of brake mechanic products. Knorr-Bremse Figure 14: brake calliper units. 26 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1.5.4) Applications in the HVAC Knorr-Bremse Figure 15: loca on of the HVAC system in a train. Washers, bushings, gaskets, and suppor ng plates in the HVAC These ar cles are used in different parts of air condi oning units. PTFE is the material used for these ar cles. Its molecular structure gives PTFE its characteris c proper es, such as a high mel ng point, excellent chemical resistance and low surface tension, and allows for very low fric on coefficients. Valves in the HVAC For HVAC systems, specific valves, such as closing valves for discharge, suc on, tanks, pressure gauges, purge, etc., are needed to operate the system. These valves are used in the refrigerant circuit and serve essen al purposes at different circuit points. To fulfil their func on, PTFE is used within these valves and is needed to provide the following func ons: x Sealing: PTFE gaskets provide effec ve sealing proper es in solenoid valves, ensuring a reliable and ght seal between the valve components. The PTFE material's excellent chemical resistance and low fric on characteris cs make it suitable for maintaining a leak-free connec on, preven ng refrigerant or fluid leakage in the system. x Compa bility: PTFE is highly compa ble with various refrigerants and fluids in refrigera on circuits. The material's resistance to chemical a ack and non-reac ve nature make PTFE gaskets suitable for maintaining integrity and performance in solenoid valves. They can withstand the harsh condi ons and corrosive nature of refrigerants, ensuring long-las ng and reliable opera on. x High-Temperature stability: Solenoid valves in refrigera on circuits may be exposed to high temperatures, especially during compressor opera on or in specific system components. PTFE gaskets offer excep onal thermal stability, enabling them to withstand elevated temperatures without compromising their sealing effec veness. This characteris c ensures reliable performance and minimises the risk of leaks or system failures. 27 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 x Low fric on: PTFE gaskets exhibit low fric on proper es, reducing the resistance to movement within the solenoid valve. This feature allows for smooth valve opera on, minimising wear and extending the valve's lifespan. The low fric on proper es also contribute to energy efficiency by reducing energy losses associated with fric onal resistance. x Longevity and reliability: PTFE gaskets are known for their durability and long service life. They can withstand repeated compression and decompression cycles without losing their sealing capabili es or mechanical integrity. This reliability ensures consistent performance and minimises the need for frequent maintenance or replacement of gaskets in solenoid valves. Its molecular structure gives PTFE its characteris c proper es, such as a high mel ng point, excellent chemical resistance and low surface tension, and allows for very low fric on coefficients. Fans in the HVAC In an air condi oning unit, fan motors drive the fans that move air across the evaporator and condenser coils, enabling heat transfer between the refrigerant and the air. By drawing warm air from the room and blowing it over the cold evaporator coils, the fan motor aids in the cooling process. Similarly, during condensa on, the motor helps reject the heat the refrigerant absorbs into the outside environment. PTFE seals in fan motors serve several vital purposes. Firstly, they provide an effec ve barrier between the moving and sta onary parts, ensuring a ght seal and preven ng the leakage of liquids or gases. This is crucial for maintaining the desired pressure within the motor. Secondly, PTFE's low fric on proper es reduce wear and heat genera on between the motor sha and housing, contribu ng to prolonged motor life. Addi onally, PTFE is chemically inert and highly resistant to corrosion, protec ng the motor's internal components from damage caused by corrosive substances. Lastly, PTFE's temperature resistance suits fan motors opera ng in high-temperature condi ons. In summary, PTFE seals in fan motors offer effec ve sealing, wear protec on, corrosion resistance, and stability in adverse condi ons, contribu ng to reliable performance and extended motor life. Compressor in the HVAC Compressors are used in the refrigerant circuit to circulate and compress the refrigerant gas in the system. It receives low-pressure, low-temperature refrigerant vapour from the evaporator coil and significantly raises its pressure and temperature before sending it to the condenser. PFAS are present in PTFE joints and bearings of both scroll and piston compressors and are needed to provide the following func ons: x Sealing func on: PTFE joints are primarily u lised for sealing purposes in scroll compressors. These joints are designed to prevent leaks and maintain the integrity of the compression chamber. The PTFE material, known for its high chemical resistance, ensures a reliable seal even when exposed to various refrigerants and opera ng condi ons. x Durability: Scroll compressors undergo repeated compression cycles, subjec ng the joints to significant mechanical stress. PTFE joints are known for their excep onal durability and resistance to wear, making them suitable for long-term use in scroll compressors. The material's low fric on proper es also reduce wear and tear, ensuring extended service life. 28 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 x Chemical compa bility: Refrigera on systems employ various refrigerants, some of which can be chemically aggressive or reac ve. PTFE is highly resistant to chemical a ack, making it an ideal choice for sealing joints in scroll compressors. The material's resistance to corrosive substances helps maintain the compressor's integrity and ensures efficient and reliable opera on. x Temperature stability: Scroll compressors operate under varying temperatures, including high discharge temperatures. PTFE joints exhibit excellent thermal stability, allowing them to withstand elevated temperatures without compromising their sealing proper es. This characteris c ensures that the joints maintain their integrity and sealing effec veness even during demanding opera ng condi ons. x Low fric on and efficiency: PTFE's low coefficient of fric on contributes to the overall efficiency of scroll compressors. The reduced fric on between the moving parts, including the PTFE joints, minimises energy losses and enhances the compressor's performance. This feature allows for smooth opera on and improved energy efficiency of the air condi oning equipment. 2.1.5.5) Applications in the hydraulics Knorr-Bremse Figure 16: loca on of the hydraulic system in a train. Hydraulic Magnet and Propor onal valves are used to control the hydraulic brake pressure. PFAS are used for sealing between coils and valve bodies in high-temperature areas, as other materials (e.g., NBR) cannot withstand the temperature generated due to magne c coils' heat genera on. Today, there are no known alterna ves. Other materials (like NBR) cannot be used in high temperatures without losing their sealing func onality. The failure of sealing func onality will lead to loss of availability of the complete vehicle -> shortening of life me by 90% or more is expected to compensate for the reduced reliability. Sliding sealing rings in mechanical pressure switches or pressure limi ng valves in the hydraulics PTFE is used in sliding sealings, which secure the main func onality of the assemblies. Sliding sealings in these applica ons need a high resistance against mechanical wear and pressures and need to resist hydraulic fluids. Using other improper materials may result in a loss of func on of the part. 29 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 In the case of the pressure switch, it means that the use of unsuitable material may lead to a wrong pressure signal, which leads to dragging brake poten al (fire incident on the train), whilst for pressure limi ng valves, it may lead to wrong pressure adjustment, which leads to a train without enough braking force. 2.1.5.6) Applications in the power electrics Knorr-Bremse Figure 17: loca on of the power electrics system in a train. PFAS are used in the following parts for wear resistance at high temperatures: - Contactor core, - Bushing, - Adhesive tape, - Humidity valve, - Insula ng pipe, - Insulator, - And various mechanical parts. PTFE is typically used, but ETFE in tubes and insulators is used for the same reason. 30 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.1.5.7) Applications in the sanitary systems Knorr-Bremse Figure 18: loca on of the sanitary system in a train. PTFE is used as a surface coa ng for the func onal area in the following parts: - Ball valves, - Control boards and panels - Gaskets, - Line strainers, - Hoses, - Pipes, - Sealing rings, - Resolvable screw connec ons, - And other parts of the sanitary systems. 31 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.2) Fluorinated gases used In the rail sector, and in par cular in rolling stock manufacturing, the use of fluorinated greenhouse gases (F-gases) is present in different applica ons: Fire suppressants In automa c fire systems, fluorinated gases (hydrofluorocarbons) are common. Air condi oning and heat pumps All current HVAC systems rely on fluorinated gases (hydrofluorocarbons), except in a few cases where natural gases have been used since 2022. The transforma on from fluorinated gases to natural gases (R-290 - Propane, R-744 - CO2) has been started and is accelera ng. Train projects using only natural refrigerants in HVAC systems are in place. This will also allow the rail sector to align with the future revised F-Gases regula on. Refrigera on Fluorinated gases (hydrofluorocarbons) are used to refrigerate the catering equipment in the restaurant vehicle and refrigerate the trac on ba ery using lithium technology. During the manufacturing and tes ng, fluorinated gases are used for the burn-in test of the electronic board and the valida on of the rolling stock in a clima c chamber. Also, natural refrigerants can be used for this applica on and are in first serial applica ons. Electrical switchgear The voltage switchgear uses fluorinated gases (perfluorinated compounds) in the power sta on. The use of fluorinated gases is already regulated by the EU regula on 517/2014. This regula on imposes quota reduc on, prohibi ng the placing on the market for several applica ons. This regula on is ongoing and revised, and the new regula on will be published in 2023 with addi onal quotas reduc on to achieve the 2016 Kigali Amendment to the Montreal Protocol and new prohibi ons on the placing on the market. The leak checks will be applicable for rolling stock to prevent environmental leakage. The restric on proposal on PFAS generates double restric ons for the same applica on with different deadlines. HVAC units are also part of the rolling stock used by rail operators and used in control-command and signalling devices. Due to the long life me of rolling stock, the par culari es of the rail sector have to be taken into account, and the HVAC units are designed for a long opera on dura on, averaging 30 years. Replacing all these exis ng units would cause high costs of several billion euros and huge amounts of waste for rail operators and significantly weaken their compe veness as the most sustainable mode of transport. These costs for operators must be weighted with the con nuously reduced and already small amount of f-gas for maintenance. In addi on, the HVAC industry, just like EVU, is affected by the shortage of skilled workers and thus does not have the engineering and manufacturing capacity for a complete replacement within the given meframe of PFAS restric ons. 32 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.3) PFAS used in electronics and semiconductors In the rail sector, the use of PFAS in electronics and semiconductors is present in different applica ons: Wires and cables For railway trac on motors, PFAS are present in the wires' insula on used to manufacture the winding. The rectangular copper wire used in trac on motors is insulated with a Polyimide tape (PI) with one side coated with fluorinated ethylene propylene (FEP). The layer of FEP is necessary to ensure good adhesion of the Polyimide film on the copper during the wrapping opera on. There is no alterna ve to allow good adhesion of the Polyimide film on the copper wire. With this insulated copper wire, with excellent sealing of the Polyimide film on the copper wire, it is possible to form trac on motors' coils to the final geometry (form-wound winding) in deforming the copper wire in all direc ons without damaging the insula on. The coil-forming process is very stressful for the insulated copper wire. Without a good adhesion of the Polyimide film/FEP on the copper, obtaining the coils for form-wound winding is impossible. Lastly, form-wound winding (using PI-FEP film on copper wire) is the only way to make trac on motors winding able to support high temperature (240C), high voltage (between 900 V to 5000 V), harsh environmental condi ons (pollu on and humidity), mechanical stresses due to vibra ons during a very long life me (40 years). This use is generalised to all railway trac on motors and for all train applica ons combined (tram, metros, regional, high speed and locomo ves). Moreover, a er manufacturing the trac on motor, the PI-FEP is included and maintained inside the insula on system with no possible emissions outside the motor and a limited environmental pollu on risk. A failure in the insula on system may lead, in combina on with an unlikely malfunc on of the used shut-off device, to fire and can therefore be considered safety-relevant. Other materials such as sheath and heat shrinkable tubes are also made with a fluoropolymer (polyvinylidene fluoride (PVDF), or polytetrafluoroethylene) and used in formwound winding of a trac on motor to meet the same technical constraints. Cable insula on Signalling equipment installed along the wayside (balise, encoder, field device control) is developed to work in a harsh environment in an extensive temperature range. Cables using PTFE tapes have been selected for their ability to support high temperature, high voltage, extreme environmental condi ons (pollu on and humidity), and mechanical stresses due to vibra ons during a very long life me (40 years). Cables for magne c coil, used in valves for pressure control of the hydraulic brake PTFE is used in cable insula on to fulfil fire protec on requirements set by European norms (e.g., EN 45545). Electric func ons without proper insula on will lead to an immobilisa on of the complete train. In case of unsuitable alterna ve material usage, there is a risk to human health due to releasing toxic substances in case of fire. Electronic components, semiconductors and coa ngs All railway products (rolling stocks, signalling equipment, infrastructure) need circuit boards with components to ensure opera on and safety. Most components used on these circuit boards use PFAS and fluoropolymers. 33 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Two-phase cooling for power semiconductors PFAS-based heat transfer and semiconductor cooling substances such as FC-3284, FC-72, or Novec 649 are non-conduc ve, thermally, and chemically stable fluids with low boiling points and high latent heat, which are ideal for use in single- and two-phase heat transfer fluid applica ons, such as semiconductor package tes ng, power electronics and computer cooling. While there is no longer a need for those substances in state-of-the-art rail products and components, exis ng, e.g., metros that are well established in many European ci es, s ll rely on these substances for maintenance purposes, e.g., two-phase cooling systems for power semiconductor modules in power converters. The main reason for regular re-filling or replacement is contamina on of the substances, which thus requires cleaning or filtering. Power semiconductors They are also an essen al element of electric trains, as these devices control the electric power used for the trac on system. PFAS substances are extensively used in the fabrica on process of semiconductors because of their unique proper es. For a more detailed presenta on, please refer to the contribu ons of Orgalim, SEMI (ECHA's consulta on reference number 4304) and ESIA (ECHA's consulta on reference number 4449). RF (Radio Frequency) connectors They are used in PFAS fabrica on and as insulator PTFE because of low power loss. For instance, they are used in Tag Reader to connect radio frequency antenna to ETCS. Cooling systems These systems need specific components to ensure opera on and resistance, which is only possible using PFAS materials, allowing energy efficiency as a compressor, control valve or sensors. Various electronic assemblies in the Brake Control (capacitors, plugs, transducers...) These items are used in the electronics of the brake control systems and indoor control systems. Commonly used is FPM/FKM, e. g. in plugs for specific cabling. Furthermore, various fluoropolymers are used in capacitors as dielectric films and occasionally as liquid impregnates. They are used for their high dielectric strength, heat resistance, and ability to be produced into thin films. Insula on materials or cable insula on in power converters of trains PTFE and PVDF are ideal materials as they show the highest possible tracking resistance (i.e. the resistance against the forma on of conduc ve paths on the surface of an insulator) and, at the same me, withstand extreme working temperatures and high electric fields, which is both a safety and a func onal requirement. The materials provide a unique mixture of proper es to ensure safe opera ons of the converters over a typical 30-year life me. 34 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.4) PFAS used in the energy sector 2.4.1) Batteries In the rail sector, ba eries containing PFAS are used for rolling stock, signalling equipment or infrastructure. Their func ons are mainly onboard backup, engine star ng, regenera ve trac on, and trackside applica ons. Ba eries are also found in defibrillators present today in many trains. For instance, the on-board ba func ons, including: - braking, - smoke detec on, - emergency ligh ng, - door opening. ery systems provide backup power to support vital safety and control Trac on ba eries are already used onboard tramways to provide trac on energy when catenaries or third rail are to be avoided (e.g. historical centres, tunnels, bridges). Also, they will allow replacing Diesel propulsion to reach the European Green Deal's targets. The goal is to replace Diesel propulsion on lines where electrifica on is not done, typically lines with lower traffic that did not sa sfy the economic equa on to amor se catenary infrastructure investment costs. Examples of ba eries for trackside applica ons are uninterrup ble power supply for sta on or traffic control, to allow passengers to leave the sta on in case of grid power loss, or trackside signalisa on to con nue to issue orders to train drivers (e.g. Diesel operated, thus not impacted by grid loss) when main power has collapsed. They also support railway crossings to ensure the safety of ci zens when they want to cross a rail track or switch to con nue to let trains follow their intended route. As chemical resistance and tolerance to a high range of working temperatures are crucial for ba eries, PFAS, mainly fluoropolymers, are cri cal components for all high-performance and lithium ba ery technologies. As depicted in Figure 19, PFAS are used in essen al components of: - Cathode, - Anode, - Separator, - Gasket, - Electrolyte, - Insula ng washer. 35 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 SAFT Figure 19: where PFAS are used in a ba ery. At the ba ery system level, some cri cal components like connectors, contactors, relays, self-welder sleeves, LHD (Linear Heat Detec on) cables, cable es and vents use PFAS (mainly PTFE, PVDF, ETFE and fluorosilicone). For a more detailed presenta on, please refer to the second contribu on of RECHARGE. 2.4.2) Proton exchange membrane (PEM) fuel cells Hydrogen fuel cells are electrochemical devices fi ed in modules and deployed for heavy-duty transporta on applica ons. In the rail sector, hydrogen fuel cells are well suited to replace heavy diesel engines (no tailpipe emissions) wherever catenary infrastructure or ba ery storage is inappropriate. In short, fuel cells are the device that generate electricity from on-board hydrogen. Fuel cells consist of individual cells piled up in series, also called a "stack". The voltage of all the cells adds up to provide the required tension in the system. Breaking down the individual cell further reveals three significant components for the opera on: The hydrogen compartment, a proton exchange membrane (or solid electrolyte) and its catalyst layers, and the air compartment. The proton exchange membrane (PEM) is used as the electrolyte. The PEM is vital to the opera on and works op mally based on perfluoro sulfonic acid (PFSA) fluoropolymer. The cells operate at rela vely low temperatures and can quickly vary their output to meet shi ing power demands. Whilst protons flow through the membrane, electrons follow the external circuit pathway to generate electric power. When the loop is completed, water and electric current are generated, and heat is dissipated. For a more detailed presenta on, please refer to the contribu on of Hydrogen Europe (ECHA's consulta on reference number 4144). 36 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.5) PFAS used in lubricants Trac on motors Lubrica ng grease using PTFE is used for lubrica on of the bearings of the trac on motors for hightemperature applica ons. PTFE has excellent thermal resistance, which gives the perfect stability of the lubrica ng grease without performance losses and does not need to be replaced regularly. Very high-performance greases based on PFPE oils are used in railway vehicles because of their excellent lubrica on proper es at a wide temperature range and the high protec on corrosion level they provide for a long me. The trac on motor bearings use these greases due to the outstanding characteris cs for oil reten on at high permanent temperatures and good corrosion protec on and water resistance, offering an extremely long service life. For turnout systems in the railway infrastructure, some slide chairs for switching the switch rails to the desired direc on must be regularly lubricated with PFAS lubricants. For a more detailed presenta on, please refer to the contribu on of ATIEL (ECHA's consulta on reference number 4423). 37 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 2.6) PFAS used in TULAC (Tex le, upholstery, leather, apparel and carpets) In the rail sector, technical tex les such as membranes/filters in valves/ven ng are widely used in different applica ons for transport, the energy sector (ba ery), electronics and semiconductors. Energy sector (ba ery) A fragile permeable membrane of PTFE is used in ven ng valves for cell, module or ba ery system casing. The purpose of these ven ng valves is to evacuate pressure and gases associated with the poten al thermal runaway of a single cell or module. At the same me, due to the unique proper es of PTFE, these valves prevent the ingress of moisture, water, dirt and dust into the ba eries, which is par cularly important for ba eries that operate outdoors in harsh environmental condi ons. Electronics and semiconductors The infrastructure systems use electronic products deployed along the tracks. In this configura on, electronic devices must be maintained in a water-free environment. The product is placed in a waterproof envelope with an IP68 sealing protec on level, i.e., a device can survive against dust and up to 1.5 metres of water for 30 minutes. This solu on is sensi ve to the phenomenon called "pumping": temperature varia ons of the environment or the product changes the air enclosed in the product pressure. These changes make the seals work excessively and do not guarantee the water ghtness of the product over a long period. The solu on to the pumping effect is to use a protec ve vent, which uses a membrane made with PTFE. The microporous structure of the membrane allows the free passage of gases while at the same me preven ng water, dust and salt crystals from entering the enclosure. 38 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3) Analysis of alterna ves 3.1) Alterna ves to PFAS used in applica ons affec ng the proper func oning related to the safety of transport As fluoropolymers or fluoroelastomers are widely used in the rail sector to ensure products' safety, the maturity and availability of alterna ves depend on the applica on. 3.1.1) Sliding and guiding applica ons 3.1.1.1) Sliding elements and parts The rope will have poor guiding performances without a flexible PTFE tube. This can cause opera onal issues, leading to train down me. New solu ons must be qualified to check their compa bility with the subframe environment. Alterna ves covering the full range of applica ons of PTFE and PVDF in sliding and emergency running applica ons are not yet on the market. Other op ons, if available, would require extensive tes ng, recer fica on, and, in many cases, re-design of equipment or products. In applica ons such as flexible PTFE tubes to guide and protect a rope or cable., the PTFE ban will result in poor guiding performances in non-PTFE tubes. This can cause opera onal issues, leading to train down me. New solu ons must be qualified to check their compa bility with the subframe environment. For sliding element applica ons made from PTFE, the non-PFAS alterna ve material ultra-high molecular weight polyethylene (UHMW-PE), as proposed in the restric on dossier (Annex E.2.10), is not applicable for rolling stock product sliding applica ons as they need to comply with special requirements regarding tolerance values, service temperature, life me, or chemical resistance, etc. according to the respec ve homologa on. PTFE-made fric on and compression rings Used in oil-free compressors, they are a crucial component in opera ng motor compressors with this technology. They required years of fine-tuning to ensure the durability and reliability of previous technologies based on lubrica ng oil, which is much more pollu ng and dangerous. There are currently no known alterna ve materials with comparable durability and reliability. 3.1.1.2) Guiding segments The PTFE used for guiding segments leads to a good fric on coefficient and lifespan and withstand the severe condi ons met during running service. Currently, PTFE is used and fully compliant with safety requirements. Today, no alterna ve is known to replace PTFE material. Alterna ve materials must be validated in every detail to fulfil the requirements. An extensive valida on requires many engineering hours, substan al financial resources for valida on tests (on the test bench and track tests), and customer support. It will take several months, and it is uncertain whether to reach the expected results with the first mixture. 3.1.1.3) Pneumatic valves of brake control devices PTFE is used for both sta c and dynamic func ons when subject to fric on. Other commercially available materials can more easily replace these applica ons in the case of low-duty cycle func ons. 39 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 It should be noted that these materials are generally present in small quan es, tens of grams at most, remain on the train for even ten years or more and do not release par cles directly into the environment. Teflon-based lubricants are widely used for these func ons. These very high-performance products have been introduced in the design for at least a couple of decades by significantly improving the sliding of the moving parts, ensuring more excellent durability and reliability, which can remain in opera on for very long before being disposed of. Currently, no known alterna ves can guarantee the benefits obtained with these products. In this case, a few grams of PFAS per valve are generally enclosed within the device and almost negligible release into the environment. 3.1.1.4) Plain bearings For emergency running proper es of lubrica on-free bearings, the alterna ves proposed in the restric on dossier (such as PA, PBT, PEEK, PP and Silicones; Annex E.2.10) are mechanically unsuitable for the applica ons, except for polyamide (PA). However, PA is only suitable if the temperature range is suitable and if environmental influences or aggressive media are kept within certain limits. Without emergency running proper es of specific plain bearing applica ons, it would be necessary to revert to conven onal technology with roller bearings and lubricants, thereby abandoning the low maintenance and environmentally friendly oil-free design. In some plain bearing applica ons, no real alterna ves would last typical 30 years of safe opera on. 3.1.1.5) Hose assemblies, joint heads, couplers, threads, and related applications They require protec on or resistance to aggressive media and extreme opera ng temperatures, or both, highly depending on the availability of PTFE and PVDF. Thus, even the restric on dossier does not propose alterna ve materials. This is because such materials do not exist at present. The relevant suppliers of these materials also confirm and warn that suitable subs tutes will not be available soon. 3.1.2) Sealing applica ons 3.1.2.1) Bogie and transmission In the past, many tests on the bench and in commercial service have been carried out to validate the materials capable of guaranteeing these performance requirements. From using NBR (nitrile butadiene rubber) materials, the experts were ini ally led to use more technical materials to meet the stricter performance requirements. To date, only FKM materials are validated for sealing solu ons. In some applica ons, using HNBR could be an alterna ve to FKM seals, but this subs tu on will involve design modifica ons and requalifica on tests. The current seals with FKM cannot be replaced directly in the actual design and the exis ng fleets of trains in opera on. Requalifica on tests would require many engineering hours, extensive financial resources, customer support, and delays of several months. All this on a large number of references and projects. Prohibi ng the use of this type of material would lead to two significant constraints: x The need to review the valida on of the sta c and dynamic seals of the gearboxes via the development of alterna ve materials for the delivery of new equipment. x The impossibility for the customers to obtain spare parts to carry out maintenance opera ons (as a reminder, the trains are defined for a contractual life of 30 to 40 years). 40 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.1.2.2) Traction motors Alterna ve materials to fluoroelastomers (FKM and FPM) for sealing gaskets do not have the same chemical resistance, meaning lower performances and shorter life mes. No known alterna ve is available for this applica on. 3.1.2.3) Dampers The seal material's composi on is a cri cal parameter for good ghtness. Suppose something is modified in the ghtness func on (seal shape, seal material, rod condi on surface, rod surface treatment). In that case, extensive valida on must be done to be sure that the new condi ons of the ghtness func on will give an equivalent behaviour. Seals are in contact with the oil of the dampers. It could be possible to use seals in NBR as it was done 20 years ago, but a redesign is mandatory, and the performances have to be validated. HNBR could be a possible alterna ve for seals under the condi on to succeed in performance and fa gue tests. An -yaw dampers that use these seals are safety-relevant, and any modifica on must be validated in every detail. An extensive valida on requires many engineering hours, substan al financial resources for valida on tests (on the test bench and track tests), and customer support. It will take several years, knowing it is not sure to reach the expected results with the first mixture. The polymer market currently does not provide material comparable to FKM for sealings and dampers used under harsh condi ons in rail vehicles. Alterna ve elastomers men oned in the restric on dossier (Appendix E.2.10), such as rubbers, polyurethanes or silicones, do not meet the requirements regarding extreme temperature ranges or aggressive media. For FKM subs tu on research applica ons, tes ng and implementa on un l market maturity level would take more than ten years. 3.1.2.4) Traction transformer In some past projects, the use of NBR and HNBR seals has been realised, but it depends on the temperature ranges and especially on the compa bility of the seals with the oil used. While switching to NBR or HNBR seals, the OEMs must requalify the seals with the oils used and guarantee a hold on the temperature ranges. Oil manufacturers perform qualifica ons. Few alterna ves can be used from -50C to +150C. 3.1.2.5) Tank wagons for the transport of dangerous goods To the European rail sector's best knowledge and supported by the European Sealing Manufacturers and ITCO, no alterna ve materials would perform as well as exis ng solid PFAS sealings required for chemical thermal, plasma and radioac ve resistance for seals. Less-performing alterna ves would significantly increase the risk of leakages and threaten the environment and human health due to the more frequent replacements of sealings and the risk of contamina on and leaks. For a more detailed presenta on, please refer to the contribu on of UIP (ECHA's consulta on reference number 6213). 3.1.2.6) Cooling system components with PTFE or FKM sealing They cannot be changed without the proof of their suitability. Alterna ve PFAS-free materials are unavailable due to the excep onally severe opera ng requirements. 41 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.1.3) Coa ngs, adhesives and finishing Liner on ball joints and rods Lubrifica on can be done using liquid grease. However, in the railway industry, finding a grease that can do lubrifica on and shock and vibra on suppression has been proven impossible while guaranteeing the required load, angular capacity and life me (10 years at least). Regarding the use of lined bearings in railway vehicles, there are no alterna ves available in the market without PTFE that can achieve the performances of the current solu ons. Using this bearing in safetyrelated elements of the trains makes it difficult to subs tute them with products with less reliability or worse performances under extreme condi ons where the trains are used. Pain ng and corrosion protec on in the air supply unit Alterna ves are not available soon. Zinc flake coa ng This is a safety-cri cal point for which there is currently no alterna ve known. 3.1.4) Detailed applica on per main system 3.1.4.1) Air supply unit Relief valve used in the air supply unit Alterna ves are possible. However, homologa on and qualifica on of the proposed solu ons will take several years. Developing and qualifying alterna ve material is without guaranteeing success. These poten al alterna ves are not available soon. Piston ring and piston in the air supply unit There is no alterna ve known. Based on the experience of developing the current system, a PFAS-free alterna ve is hardly imaginable. As outlined above, alterna ve materials must provide an extremely low fric on coefficient, high-temperature resistance, and mechanical strength. Simultaneously, the coa ng must not have an abrasive effect on the counterpart. The research and development of alterna ves without PFAS will take several years, and the homologa on and qualifica on of the proposed solu ons will also take several years. Oil pipe, screw fi ngs in the air supply unit One theore cal alterna ve could be NBR rubber. However, NBR is unsuitable due to insufficient resistance to high and low temperatures. Addi onally, NBR does not have sufficient resistance to elements such as oil, grease and water. These elements could be found inside the compressed air, causing damage to the whole system. Casing in the air supply unit There is an alterna ve available, but not enough informa on about it. It is required to test and validate these alterna ves before using them. 42 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Needle bearings in the air supply unit Suitable alterna ves for PFPE-based grease in this specific applica on are currently unknown. However, it would be possible. Homologa on and qualifica on of the proposed solu ons will also take several years. Sha sealing rings and O-rings in the air supply unit Alterna ves are possible, however, depending on the concrete use-case unknown. Homologa on and qualifica on of the proposed solu ons will also take several years. Valve cones in the air supply unit Currently, there is no known alterna ve. Safety valve, minimum pressure valve in the air supply unit Currently, no alterna ves are known. General rubber materials may not endure the described requirements. 3.1.4.2) Brake control O- Rings in switching cylinders in the brake control As an alterna ve, low-temperature nitrile rubbers could be tested, and other possibili es have to be checked. However, current limita ons are high-temperature proper es, chemical resistance, dynamic impact proper es, ques ons about cost, cer fica on and homologa on, which require several years without guarantee of success. Alterna ves are not available soon. Guides (solenoid valves) in the brake control Alterna ves could be TECASINT 2021 (Polyimide) or POM. However, availability, price and func on must be checked and validated before replacement. 3.1.4.3) Bogie equipment Slide bands, bushes, bandages, gaskets, swivel bearings, and different rings (spacing ring, thread seal ring, etc.) in the bogie equipment Compliance with Standards of alterna ve material cannot be guaranteed. Some standards require, e.g. efficiency and sensi vity for brake mechanics products, which must also be met in different environmental condi ons (e.g. low-temperature performances). Currently, alterna ves are in development for some of these use cases. However, no informa on on other op ons is available for most use cases. The development and valida on of alterna ve solu ons take me. 3.1.4.4) HVAC Washers, bushings, gaskets, and suppor ng plates in the HVAC Suitable alterna ves for PTFE-based joints in this specific applica on are currently unavailable. However, they are in development. 43 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Valves in the HVAC Suitable alterna ves for PTFE-based joints in this specific applica on are currently unavailable. However, they are in development. Fans in the HVAC Suitable alterna ves for PTFE-based joints in this specific applica on are currently unavailable. However, they are in development. Compressor in the HVAC Suitable alterna ves for PTFE-based joints in this specific applica on are currently unavailable. However, they are in development. 3.1.4.5) Hydraulic Hydraulic Magnet and propor onal valves used for pressure control of the hydraulic brake Alterna ves are not available soon. Sliding sealing rings in mechanical pressure switches or pressure limi ng valves in the hydraulics Alterna ves are not available soon. 3.1.4.6) Powe electric and sanitary systems Contactor core, bushing, adhesive tape, humidity valve, insula ng pipe, insulator, and various mechanical parts in the power electric Alterna ves are not available soon. Ball valves, control boards/ panels, gaskets, line strainers, hoses, pipes, sealing rings, resolvable screw connec ons and other parts in the sanitary systems Alterna ves are not available soon. 44 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.2) Alterna ves to fluorinated gases As far as the use of fluorinated greenhouse gases in the rail sector is concerned, the development of alterna ves is gradually star ng to be mature enough for large-scale deployment on some applica ons, as evidenced by the first projects: R-744 (CO2) The use of R-744 (CO2) as a natural refrigerant in eco-friendly HVAC units has been simulated, developed and tested in real opera on in the Shi 2Rail research projects PIVOT2 and PINTA3, to be finalised in 2023. These solu ons are less efficient regarding weight/volume due to higher working pressure and less performant in higher ambient opera onal temperatures. Therefore, state-of-the-art HVAC equipment with alterna ve fluids does not yet follow the railway market requirements, such as weight reduc on (significant for ba ery trains) and good performance in extremely high temperatures (more common due to the climate change adapta on needs). R-290 (Propane) Refrigerant R-290 (Propane) was also deeply inves gated by two major HVAC railway suppliers and a railway operator in 2019-2021, with a prototype in a field test on a regional train. The first projects with R-290 HVAC in serial produc on are under development and will start opera on in 2023. With R290, these solu ons have similar weight/volume/energy consump on performance, but the safety concerns related to the gas flammability need to be respected. The first projects have demonstrated technical feasibility for opera on in the opened field of trains with roof-mounted HVAC, typical applica on of mainlines or regional trains. Safety studies require a strong collabora on between HVAC suppliers, car builders, rail operators, and assessors (Independent Safety Assessors and Designated Bodies (DeBo) in case of specific Na onal Safety Rules) to check all the use cases in the life cycle of the product (manufacturing, transport, assembly, opera on, maintenance and end of life). So far, only a few stakeholders in specific markets have reached maturity. In conclusion, R-290 is a poten al alterna ve, but its suitability for all railway applica ons has not yet been validated and proven in the field. 3.2.1) Air condi oning and heat pumps 3.2.1.1) On technical feasibility So far, the development of solu ons with natural refrigerants has started only for a few product applica ons, i.e. for mainlines and regional and only in a few countries; for the rest of the European market, no solu on has been realised. However, it is likely that the number of projects using HVAC units with R-290 will quickly increase in the coming years. S ll, a full implementa on of these solu ons will take up to ten years due to product development me in the railway industry. Refrigerant R-744 (CO2) is not an acceptable alterna ve for all applica ons due to environmental reasons. It has a higher weight (leading to an increase in energy consump on for trac on) and higher cooling power consump on, especially in condi ons of external temperature higher than 40C, where most trains in the EU must operate. Extensive test campaigns are ongoing to prove the use of R-290 is safe in other applica ons such as metro/underground opera on, roof-embedded HVAC units, or both. 45 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.2.1.2) On project execution As far as R-290 is concerned, no interna onal nor European railway standard is available yet for using flammable refrigerants for HVAC, as it is for other domains (for instance, IEC 60335- 2-401 for household appliances). Nevertheless, a dra of the German standard (DIN 27165), which has been elaborated and is currently in the discussion phase, may be the star ng point for crea ng a Europeanwide or even interna onal standard. Therefore, any project relying on R-290 will suffer during a transi on period from a longer me to deliver trains, as the safety study hypothesis and methodology must be discussed case by case for each project with the HVAC supplier, rolling stock manufacturer, operator, maintainer, Independent Safety Assessor, No fied Body (NoBo) and Designated Body (DeBo), that is providing the third party assessment as required in Interoperability Direc ve 2016/797. 3.2.1.3) On economic feasibility The ini al cost of a refrigerant R-290 HVAC unit or R-744 (CO2) unit is s ll higher than that of a unit equipped with exis ng refrigerant R-134a (HFC) or R-513A (a blend of HCF/HFO). For instance, in the case of R-290, the maintainer would have to adapt their infrastructure and process to the characteris cs of R-290 proof (sufficient ven la on, new procedures, par cular storage area, etc.). 3.2.2) Refrigera on To this day, alterna ves to fluorinated gases for burn-in tests and clima c chambers, based on R-290 refrigerant, exist in the opera ng range between -20C and +60C and for the test of medium and small-scale equipment. No alterna ve exists for applica ons outside this temperature range to test big-scale equipment, such as a complete car body or train. Recent installa ons using natural gas like R-744 (CO2) are not considered adequate alterna ves, as they use hydrofluorocarbons in addi on to CO2. 3.2.3) Fire suppressants Alterna ves to PFAS exist on the market but not for every applica ons. 3.2.4) Electrical switchgear Alterna ves to PFAS exist on the market. 46 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.3) Alterna ves to PFAS used in electronics and semiconductors Detailed alterna ves per applica on 3.3.1) Wires and cables Today, regarding the high performance of trac on motors, no known alterna ve exists to using Polyimide (PI) and Fluorinated ethylene-propylene (FEP) tape. The use of this tape is common in all industries manufacturing trac on motors. The development of alterna ves by the suppliers of copper insula on without PFAS will take several years, and the homologa on and qualifica on of the proposed solu ons will also take many years. The development and qualifica on of new materials risk failure in the end. Developing an alterna ve material to Polyimide/FEP is very challenging. It includes several technological barriers to overcome to find an equivalent solu on with the same technical performance. On the one hand, products used in the automo ve industry for electrical motors, such as enamelled copper wire or fibre-insulated wire using Polyamide-imide varnish, cannot be used for railway industry trac on motors because this insula on is not able to support the coil-forming process of a formwound winding without cracking. The temperature and voltage resistances are too low compared to Polyimide/FEP film. The electrical motors in the automo ve industry use completely different winding processes (random wire technology or hairpin technology) compared to the trac on motors manufactured for the railway industry (form-wound winding), and the technical constraints are different. In the automo ve industry, the voltage levels are lower (400V compared to 900V minimum), the temperature condi ons are lower (not 240C as in railway), and the life me of an automo ve vehicle is also significantly shorter, 12 years compared to the 40 years of a train life me. On the other hand, the technologies of high-power electrical motors manufactured for heavy industries (steelmaking industry, for example) or nuclear power plants cannot be used because the design constraints are en rely different. Voltage levels (6 600V) are higher than in railway, with lower temperature resistance materials (155C vs 240C), and for a different life me. In conclusion, materials used in other fields cannot be used for the trac on motors in the railway industry. Highly resistant adhesive layer in wire insula on used in electric motor coils Drop-in alterna ves of FEP in electric insula on applica ons, such as motor coil insula on systems, are not yet on the market. FEP alterna ves for motor coil insula on systems that are in research are, e.g. polyimide (PI) materials. However, market readiness will take at least five years. The PI solu on will increase the product prices significantly. Expected is more than a doubling of costs per subpart. Another PFAS-free insula on system is already under development, which does not need any thermoplas c adhesives. This new technology is not expected to be available before 2030. Insula on materials or cable insula on in power converters of trains It must ensure the highest tracking resistance. Thus, PTFE and PVDF are the ideal materials. Without a drop-in replacement, a considerable engineering effort would be required, focusing on, e.g. dras c changes to the mechanical design. 47 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.3.2) Electronic components, semiconductors and coa ngs The semiconductor produc on industry uses PFAS widely in chemical formula on, components of manufacturing process tools, facili es and packaging. The current semiconductor state of the art is cri cally reliant on PFAS chemistry. Nowadays, there are no alterna ves in the market for producing non-PFAS semiconductors. Parallel to the applica on in rolling stocks, this also applies to the railway infrastructure. Signalling equipment and point machines for turnout systems are essen al for opera ng a modern railway system. PFAS can also be used in electrohydraulic point machine systems as sealings in the railway infrastructure due to their water-repellent proper es. Point machines are essen ally for the safety and func onality of the railway network, and correct func oning avoids failures and accidents. Alterna ves for PFAS in the two-phase cooling technology for power semiconductors in power converters are unavailable. As the technology and the related products are mainly outdated, there is currently no a empt or business case for suppliers of the substances to research alterna ve non-PFAS subs tutes. Drop-in alterna ves for PFAS used as insula on material in power converters are unavailable. While there are indeed PFAS-free materials that will be used in new designs, to subs tute PFAS in established power converter technology, the mechanical design of the converter would need to be changed. Apart from the immense effort of developing this altered design, maintenance and supply of spare parts pose a significant problem. For a more detailed presenta on, please refer to the contribu ons of Orgalim, SEMI (ECHA's consulta on reference number 4304) and ESIA (ECHA's consulta on reference number 4449). 3.3.3) Various electronic assemblies (capacitors, plugs, transducers...) in the brake control Alterna ve polymers for use as dielectric films are theore cally available. However, it can be assumed that, at least not for all use cases, alterna ves are available or in development today. A complete analysis of > 1,000 capacitors would be required to get the complete picture. 3.3.4) Cables for magne c coil, used in valves for pressure control of the hydraulic brake Today, there are no known alterna ves. The development of other materials for insula on without PFAS that can fulfil the fire protec on requirements will take several years, and the homologa on and qualifica on of the proposed solu ons will also take several years. Of course, the development and qualifica on are without guarantee of success. Alterna ves are not available soon. 48 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.4) Alterna ves to PFAS used in the energy sector 3.4.1) Alterna ves to PFAS used in ba eries Contrary to what is stated in Annex E of the PFAS restric on proposal (page 416), solid-state and leadacid ba eries are not poten al non-PFAS alterna ves to Lithium-ion ba eries. This is because: x Solid-state ba eries use PFAS, specifically PVDF and PTFE: In the binder within the ac ve material, In solid electrolytes and, In gel polymer electrolytes. x Although lead acid ba eries do not use PFAS, they have a low energy density. They cannot be used in applica ons which require high energy, high power, very long life, superior reliability, and the ability to withstand extreme temperatures. 3.4.1.1) Use of PVDF and PTFE as electrode binders PVDF is the binder material in the ac ve masses for electrodes for the Li-ion wet process (except for the graphite anode), Na-ion, Lithium metal rechargeable, and solid-state ba eries. All a empts to replace PVDF binder materials with other polymers for the posi ve electrode have caused cell performance and manufacturability issues. The degrada on of alterna ve binder systems in the electrolyte has been demonstrated for the posi ve electrode. The European Commission has recently funded the GIGAGREEN research project on dry alterna ves and water-based binder systems for the posi ve electrode, which propose to u lise a range of polymers including CMC/SBR, poly(acrylic acid), sodium alginate, polyurethanes and catechol-bearing polymers.3. Whilst these ini al research studies have indicated that these aqueous binder systems may have good adhesion proper es, further research and development are required to inves gate whether these alterna ves have adequate chemical, mechanical, and electrical proper es4. Significant concerns exist about whether water-based CMC/SBR technology will have the necessary rheology and stability to match today's posi ve electrode ac ve materials such as LCO, NMC, NCA, LNMO, and LFP. There are specific concerns about water use in the slurry produc on and the electrode coa ng, drying and calendaring processes, mainly if the water is not completely removed before the ba ery is assembled. PTFE is used as the binder material in the ac ve masses for electrodes for Li-ion dry process and semidry process, Li primary, Ni-Cd, Ni-MH, Zinc oxide, metal-air, Silver oxide, Zinc-ion rechargeable, Lithium metal rechargeable and solid-state ba eries. There are currently no alterna ves to PTFE due to its unique combina on of proper es that are essen al for the performance and durability of these ba eries, especially for the following: 3 Funding & tenders, Towards the sustainable giga-factory: developing green cell manufacturing processes (GIGAGREEN). (n.d.) https://ec.europa.eu/info/funding-tenders/opportunities/portal/screen/how-toparticipate/org-details/999999999/project/101069707/program/43108390/details 4 Cholewinski, A., Si, P., Uceda, M., Pope, M., & Zhao, B. (2021). Polymer Binders: Characteriza on and Development toward Aqueous Electrode Fabrica on for Sustainability. Polymers, 13(4), 631- h ps://doi.org/10.3390/polym13040631 49 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 - Fibrilla on proper es, which produce an excellent mechanical electrode surface without covering the surface of the ac ve material, - Chemical proper es, including chemical stability in very aggressive environments, - hydrophobic proper es. Alterna ve non-PFAS materials such as Polyvinyl alcohol (PVA, CAS 9002-89-5) and Poly(acrylic acid) (PAA, CAS 9003-01-4) have been tested as poten al binder materials for the posi ve electrode and have been found to fail due to performance and manufacturability issues. The degrada on of these alterna ve binder systems in the electrolyte has been demonstrated. 3.4.1.2) Use of PFAS in electrolytes Various PFAS substances are used in electrolytes for established and new ba ery technologies under development in areas such as Lithium-ion rechargeable, Lithium primary, secondary Lithium metal, and Sodium-ion rechargeable ba eries. PFAS substances are u lised as salts (a significant component or an addi ve), electrolyte solvents or electrolyte addi ves. These substances improve a ba ery's performance, efficiency, safety and life me5. 3.4.1.3) Use of PTFE & FEP in gaskets and washers (and in battery equipment) in chemically aggressive environments There are no alterna ves to using PTFE and FEP in gaskets and washers used in chemically aggressive environments, such as the SO2 and SOCl2 substances used in electrolytes in primary Lithium ba eries. SO2 and SOCl2 are powerful oxidising agents that degrade almost all polymer types except PFAS materials. Degrada on of the gasket and washer would result in loss of ba ery component proper es and release of the electrolyte. 3.4.1.4) Use of PFA, VDF-HFP, and FKM in gaskets in high-performance batteries There are no alterna ves to the use of PFA, VDF-HFP, and FKM in gaskets in high-performance Lithiumion rechargeable and Lithium metal rechargeable ba eries (e.g., high-power ba eries for automo ve, industrial applica ons and power tools), which require very thin and thermally robust gaskets for safety reasons. These gaskets are cri cal to the func oning of current interrupt devices, which are essen al to use high-performance ba eries safely. A emp ng to use non-PFAS materials available today to manufacture these gaskets will result in the ba ery failing safety tes ng standards and risking the ba ery catching fire or exploding during use. For a more detailed presenta on, please refer to the second contribu on of RECHARGE. 5 Xu, N., Shi, J., Liu, G., Yang, X., Zheng, J., Zhang, Z., & Yang, Y. (2021). Research progress of fluorine-containing electrolyte additives for lithium ion batteries. Journal of Power Sources Advances, 7, 100043 https://doi.org/10.1016/j.powera.2020.100043 50 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.4.2) Proton exchange membrane (PEM) fuel cells Fluorine-free ionomers and membrane materials have been around in science for decades. However, making them meet the requirements for hydrogen applica ons was impossible all this me. Research has been ongoing for developing hydrocarbon membranes such as sulphonated polyetheretherketone (PEEK). The durability is o en poor, as oxida on by oxygen radicals, which are inevitably generated at the cathode electrode, occurs. The non-fluorinated membrane concepts are mainly unproven at the laboratory or pilot scale on industrial scales. They are s ll highly immature, las ng only dozens of hours against life me requirements of >25,000 hours for fuel cell applica ons. In the 1990s, there was great interest in subs tu ng Nafion and other fluoropolymer-based membranes since those were more expensive and released HF, which can a ack the steel bipolar plates. S ll, all of these programmes failed to produce viable alterna ves. In the 2010s, there was another surge of hydrocarbon membrane interest, as companies have tried non- and par ally fluorinated chemistries. In PEM fuel cell applica ons, hydrocarbon alterna ves are poor in situa onal performance, par cularly under reduced RH (rela ve humidity) of <50% and thus opera onally relevant condi ons: we experience a strong dependence of electrochemical performance on material hydra on, and more excellent material swelling and dimensional instability. PFSA ionomers are used in the catalyst layer as they provide ion conduc vity and hydrophobic proper es to the electrode catalyst layer. The hydrophobicity is a func on of the fluorinated PFSA backbone and is, therefore, very difficult to replace, as hydrocarbon polymers are inherently not as hydrophobic as fluorocarbons. There are addi onal issues with implementa on in a manufacturing se ng, as the new materials' mechanical proper es in a membrane electrode assembly cause poor adhesion between the catalyst layer and the membrane. Solu ons to this problem are unclear and unproven. The mescale to resolve these performance and manufacturing issues would go far beyond the me provided by any melimited deroga ons. Research ac vi es to replace conven onal perfluorinated ionomers with fluorine-free materials have been ongoing for 25 years. S ll, no commercial product has been released due to poor oxida on stability. Fuel cell manufacturers are in close contact with the manufacturers of the components to test the materials at a rela vely early stage and thus iden fy and qualify promising materials, promote their industrialisa on and replace the current perfluorinated compounds as early as possible. However, building on experience and knowing when a validated alterna ve material may be available in volume is impossible. For a more detailed presenta on, please refer to the contribu on of Hydrogen Europe (ECHA's consulta on reference number 4144). 51 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 3.5) Alterna ves to PFAS used in lubricants Trac on motors. Without PTFE, the lubrica ng grease will have poor performance in terms of thermal resistance. This means lower reliability of the trac on motors and the need to regularly replace the lubrica ng grease for high-temperature applica ons to avoid trac on motor failures. Today, there is no known lubrica ng grease with the same performance. PTFE-free micronised polyethylene wax It is an addi ve for aqueous, solvent-borne, solventless and UV coa ng systems to improve scratch and abrasion resistance and increase surface slip, comparable to typical PE/PTFE wax addi ves. PTFE-free silicone oil They are usually linear molecules of different chain lengths made up of dimethylsiloxane units. For this reason, silicone oils are also called polydimethylsiloxanes (PDMS). Compared to mineral oils, silicone oils have high thermal and oxida ve resistance. They can be func onalised with different groups to specifically influence the proper es of the pure silicone oils. PTFE-free ceramic lubrica ng greases They are resource-saving, wear-reducing and sustainable. The ceramic par cles smooth metal surfaces and thus reduce the need for lubrica on. The efficiency gains are reflected in lower opera ng temperatures and longer component life. Significantly lower amounts of lubricant reduce the logis cs effort. PTFE-free medical grade white oil This component serves as a lubricant and an -corrosion agent. The alcohol components have a disinfec ng and preserving effect. So that the two can be mixed, alkali salts of oleic acid are present as detergents. Together with the alcohols, they enable a water-displacing and dirt-dissolving effect, making the oil film washable. Ballistol forms a milky emulsion with water and, according to the manufacturer, has a pH of 8 to 8.5 (alkaline). Ballistol is biodegradable, not hazardous to water and harmless in terms of the food law. For a more detailed presenta on, please refer to the contribu on of ATIEL (ECHA's consulta on reference number 4423). 3.6) Alterna ves to PFAS used in TULAC (Tex le, upholstery, leather, apparel and carpets) An alterna ve solu on to the waterproof envelope could be filling the product with resin. However, this solu on is unsuitable because it prohibits product maintenance, which becomes disposable and is incompa ble with electronic devices like contactors, insula on switches, etc. Today, no solu on has been iden fied to replace the protec ve vent made with PTFE. 52 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 4) Possible consequences: socio-economic impact assessment of the proposed PFAS restric on for railways value chain Scenario 1: No deroga on at all In an unlikely scenario, all the deroga ons in the current PFAS restric on proposal are not granted. In this case, this means the end of the rail sector in Europe and the loss of hundreds of thousands of jobs. Without some essen al PFAS, operators will not fulfil safety standards, disrup ng railway traffic. The impact of this decision on climate change will be an increase in current CO2 emissions due to a nega ve modal shi from rail to other more polluted modes of transport. A ban on PFAS for sealings used in tank wagons approved for transpor ng dangerous goods would severely disrupt the global chemical and liquefied gas transporta on supply chain. Some products could not be transported any longer, implying a possible shortage of basic needs products. Given that around 212 million tons/km of dangerous goods are transported by rail yearly, the effects would be catastrophic for the chemical industry, all related industries that depend on chemical supplies, and the European economy. In addi on, around 82,477 tank wagons and hence, the assets of SMEs will be affected. For a more detailed presenta on, please refer to the contribu on of UIP (ECHA's consulta on reference number 6213). Scenario 2: Proposed deroga ons are confirmed, but no other specific deroga ons The current PFAS restriction proposal lacks several derogations for PFAS applications, which are essential for the European rail industry. These missing use applications comprise the following: x Refrigerant of air conditioning and heat pumps - new HVAC, x Refrigeration - catering battery monitoring systems, x Coating, solvents & cleaning, x Electronic components, x Wires, cables, motor sheath - heat shrinkable, x Batteries. In a scenario where only the derogations of the current PFAS restriction proposal are granted, the impact on the European rail sector would be immense, with significant consequences for the European economy, citizens, workers, and public transport, as well as the shift towards more sustainable transport. Failure to grant derogations (or exemptions for fluorinated gases) would mean an immediate (18 months after entry into force) and total ban of PFAS for the above applications. As these applications are critical for various essential rail components and are also required for spare parts and maintenance activities, the ban will trigger a cascade of far-reaching consequences. These include a complete stop and loss of established technologies and products, the need for rapid re-design or shortterm development of new solutions, or loss of certification, homologation, and safety approval. This, in turn, would have significant economic, social, and environmental impacts. 53 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Economic impacts will include increased design, manufacturing, operating, maintenance and repair costs and longer service intervals leading to higher prices and expenses for the product owners (e.g. companies, public transport operators, cities and communities) and passengers. Social and environmental impacts will include, e.g. reduced reliability of rail products and, thus, increased safety and health risks and reduced durability of rail products. Reduced durability means materials must be replaced more frequently, leading to an increase in waste and loss of resources. The instant ban (18 months after entry into force) of PFAS for electronic components, wires, cables, electric motors, and batteries without the availability of drop-in alternatives will endanger the entire railway industry and, thus, all related stakeholders. Scenario 3: No deroga on for spare parts and maintenance ac vi es Although the PFAS restric ons and bans will not apply retroac vely on products already placed on the market before the ban date, they will affect the a ermarket, spare part and maintenance business as far as it will not be possible a er the ban date to replace products in use with spare or equivalent products that contain PFAS or refill/exchange opera ng substances. Following the "Repair as Produced" principle, PFAS applica ons will be required for spare parts and maintenance ac vi es. Many exemp ons will be required for PFAS applica ons. Many PFAS applica ons will s ll need to be used on components that have been type-approved. This also applies to spare parts and opera ng substances rela ng to type-approved components. As this scenario is currently not sufficiently addressed within the Restric on Proposal, the railways sector is highly concerned that this may generate mul ple liability and contractual disputes between OEMs and train operators as to which en ty is responsible for bearing the efforts (hence, the costs) for re-designing spare parts to comply with the PFAS restric ons. In the case of maintenance ac vi es that require the refill or exchange of opera ng substances of PFAS consumables or substances, customers or product owners would be immediately and unexpectedly faced with a situa on where their rail products would need to be redesigned, retrofi ed or replaced. This will affect many European rail and public transport companies and many European ci es currently planning for a mul -decade life me of their transport systems. A theore cal workaround to this conflic ng scenario could be that, shortly before the entry into force of the PFAS restric on, the train operators refill the spare stock to cover the remaining useful life of PFAS-based products in use. Nevertheless, this is not considered a viable solu on as it implies significant economic and logis c impacts for operators and OEMs and does not address the need for replacing products in use because of obsolescence. Furthermore, stockpiling large quan es of PFAS spares or opera ng substances would counteract the inten on of the proposed restric on and even increase the risk of increased release of PFAS into the environment. 54 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 As a consequence of the above, the railway's sector requires that either the PFAS restric ons are not applied to spare parts of products in use as well as maintenance ac vi es at the date of the ban and throughout their useful life or that specific provisions are provided in the PFAS restric on proposal as to how to handle this poten ally very cri cal scenario from a contractual, legal and technical standpoint, spli ng the responsibili es between OEMs and final users (i.e. railways operators). Possible consequences: environmental and human health consequences As regards the tank wagons, a ban on PFAS and the fact that there are no real alterna ves to PFAS for sealing applica ons would mean a significantly higher risk of leakages of dangerous goods into the environment. It would also mean higher emissions of toxic and hazardous products because before sealing can be replaced, the tank needs to be cleaned from the product. Less-performing alterna ves would also bring a much higher risk to human health, especially those working in workshops that would need to work with possible contaminated sealings. It means a higher exposure to dangerous goods while replacing the sealings. 55 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5) Requests for deroga ons and for a review clause 5.1) Applica ons affec ng the proper func oning related to the safety of transport 5.1.1) Sliding and guiding elements The Annex XV report proposes a deroga on under reconsidera on : x 6.o [applica ons affec ng the proper func oning related to the safety of transport vehicles and affec ng the safety of operators, passengers or goods un l 13.5 years a er EiF] Fluoropolymers ensure the operability and guidance of the rail equipment. Without these polymers, there is a risk of equipment failure and a risk to the safety of operators, passengers or goods. Drop-in replacements for PTFE and PVDF are currently not available. This results in the safe opera on of products containing, e.g. air spring systems, which would not be able to be ensured in case of an instant ban of PTFE with a transi on period of only 18 months. This holds for more than 90% of all rolling stock products. Moreover, even if alterna ve materials were available, this would not guarantee a drop-in exchange of PTFE in this applica on, as a change of fabric in ongoing projects would affect the homologa on of the whole train, including extensive dynamic tests in finished vehicles. Altered fric on and s ffness values will change the reac on moments when driving through curves. According to EN 14363, only a minimal % tolerance range of 10% is allowed. Repea ng all affected products' homologa ons and test runs would take several years and an enormous investment. As the PTFE ban would also affect spare parts for the air spring systems of trains already put on the market, this would result in a gradual loss of more and more trains if the air spring system is subject to maintenance. Also, in other safety-related applica ons men oned in Sec on 2.1, such as resistance to aggressive media, emergency running proper es, high tracking resistance or high-temperature range applica ons, PTFE and PVDF are essen al materials (i.e. sliding parts, lubrica on-free plain bearings, hose assemblies, joint heads, couplers, threads, and insula on material or cable insula on for power converters). Total turnover only with products depending on PTFE materials to ensure high tracking resistance under high-temperature condi ons is es mated to be immense. However, the economic impact will be even higher as almost all train products depend on the men oned subparts. Thus, an instant ban on perfluorinated polymers with a transi on period of only 18 months would cause a significant threat to the safety of rail transport applica ons in general and a setback to well-established and needed safety-relevant and compe ve technologies. This would highly affect the whole rail industry, thus significantly impac ng employees, public transport, and the shi toward more sustainable transporta on. In addi on, since in most of the above applica ons, emissions of Fluoropolymers to the environment can be excluded en rely (e.g. because of use in closed assemblies or sealed and leak-proof containers with no direct contact with the environment), there is no environmental concern with the help of these materials in the safety-related applica ons. Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these materials. 56 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 As laid down, alterna ves for PTFE and PVDF materials in rail applica ons are unavailable soon. Therefore, a deroga on of at least 13.5 years a er entry into force is required, e.g. via the "PFAS used in applica ons affec ng the proper func oning related to the safety of transport" deroga on or a general deroga on for perfluoro polymers. 5.1.2) Sealing applica ons The Annex XV report proposes a deroga on under reconsidera on : x 6.o [applica ons affec ng the proper func oning related to the safety of transport vehicles and affec ng the safety of operators, passengers or goods un l 13.5 years a er EiF] FKM materials ensure the safety of the rolling stock during opera on. This includes the safety-relevant applica ons men oned in sec on 2.1, such as sealings (safety relief) valves, sealing gaskets in trac on motors, dampers, sealing of trac on transformers, sealing of casings, etc. A failure in the effec veness of the sta c and dynamic seals generates, e.g., a lubricant leak and, thus, rapid destruc on of gears and bearings, which can go as far as an axle blockage in commercial service. This risk is one of the most severe in terms of cri cality, involving a poten al derailment of the train or a fire and the loss of the lives of passengers. Other sealing failures could, e.g. lead to safety-relevant loss of opera ng pressure or liquid, corrosion, or environmental pollu on. Thus, sealing failure may lead to diverse risks to the safety of operators, passengers or goods. Also, the materials of sta c and dynamic seals must withstand the thermal stresses and chemically resist the aggressiveness of oils and lubricants used for up to 10 years (poten ally 15 years in the future) between two maintenance steps. As laid down, alterna ves for FKM materials in rail applica ons are unavailable soon. Therefore, a deroga on of at least 13.5 years a er entry into force is required, e.g. via the "PFAS used in applica ons affec ng the proper func oning related to the safety of transport" deroga on or a general deroga on for perfluoro polymers. The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force. As of today, no alterna ves exist. 5.1.3) Coa ng, adhesives and finishings The Annex XV report proposes a deroga on under reconsidera on: x 6.o [applica ons affec ng the proper func oning related to the safety of transport vehicles and affec ng the safety of operators, passengers or goods un l 13.5 years a er EiF] PTFE liner ensures the operability and the auto-lubrica on of the ball joints and rods used in bogies. Without this liner, there is a risk of equipment failure and genera ng risk to the safety of operators, passengers or goods. Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these materials. 57 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.1.4) Noise dampening components FKM materials are the only materials that can effec vely reduce ambient noise levels of rail vehicles by reducing rolling and squealing noise. So far, no alterna ve materials have been known that combine the best noise-absorbing proper es and meet thermal, mechanical, and chemical specifica ons. The FKM noise-absorbing wheel damping technology is incorporated in various rolling stock products, from metros and trams to high-speed trains. According to WHO6, reducing noise exposure could also reduce accidents, injuries and other poten al safety risks. Several organisa ons have established regula ons for protec ng workers from hazards to their health and safety arising from noise exposure, par cularly hearing threats. The target of protec ng human health from noise pollu on from various sources, including rail transport, will be in danger due to the ban on PFAS. A ban on FKM materials in the rail industry would thus set back well-established and needed safety and noise-reduc on related technologies, would highly affect the whole industry, and thus lead to a significant impact on employees, ci zens, product users, and the transporta on shi toward more sustainable transporta on. As laid down, alterna ves for FKM materials in rail applica ons are unavailable soon. Therefore, a deroga on of at least 13.5 years a er entry into force is required, e.g. via the "PFAS used in applica ons affec ng the proper func oning related to the safety of transport" deroga on or a general deroga on for perfluoro polymers. 5.1.5) Detailed applica on per main system The main systems and specific uses described in sec on 2.1.5 ensure that the railway system is a reliable and safe means of transport. Systems such as the brake and air supply allow the train to be stopped safely when required, with the highest safety integra on levels in the transport sector. A failure in the effec veness of the brake elements can go as far as a train collision and the lives of passengers. As many components rely on using elements containing PFAS, a ban will cause extensive redesign, homologa on and tes ng campaigns taking several years and great investment. Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these systems. 5.1.6) Electrical engineering & informa on technology The Annex XV report proposes a deroga on under reconsidera on : x 6.o [applica ons affec ng the proper func oning related to the safety of transport vehicles and affec ng the safety of operators, passengers or goods un l 13.5 years a er EiF] Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these materials. 6 https://www.who.int/europe/publications/i/item/9789289053563 58 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.1.7) Safety equipment (including fire preven on and protec on) The Annex XV report proposes a deroga on under reconsidera on : 6.o [applica ons affec ng the proper func oning related to the safety of transport vehicles and affec ng the safety of operators, passengers or goods un l 13.5 years a er EiF] Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these materials. Ball valves, control boards/panels, gaskets, line strainers, hoses, pipes, sealing rings, resolvable screw connec ons and other parts in the sanitary systems A deroga on of 13.5 years a er entry into force is required. Sealing elements in tank wagons approved for the transport of dangerous goods Since there are no equal performant alterna ves to PFAS sealings in tank wagons and given the significant impact it would have in terms of environmental and human health as well as on the economy due to the disrup on of the global chemical and liquefied gas transporta on supply chain and all related industries, a deroga on of 13.5 years a er entry into force as a minimum is required. For a more detailed presenta on, please refer to the contribu on of UIP (ECHA's consulta on reference number 6213). 59 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.2) Applica on of fluorinated gases Several deroga ons are proposed in the Annex XV report concerning the use of fluorinated gases impac ng the rail sector: x 5.f refrigerants in low-temperature refrigera on below -50 C un l 6.5 years a er EiF; x 5.g. refrigerants in laboratory test and measurement equipment un l 13.5 years a er EiF; x 5.i. maintenance and refilling of exis ng HVACR equipment put on the market before [18 months a er EiF] and for which no drop-in alterna ve exists un l 13.5 years a er EiF; x 5.p. refrigerants in mobile air condi oning systems in combus on engine vehicles with mechanical compressors un l 6.5 years a er EiF; x 5.r. insula ng gases in high-voltage switchgear (above 145 kV) un l 6.5 years a er EIF. For some uses, par cularly for HVAC and refrigera on, the proposed dura on is incompa ble with developing new solu ons without F-Gases and PFAS. Rolling stocks have a long life dura on (40 years), and it is impossible to replace refrigerant with HFC with natural gas without an essen al design modifica on. Concerning the reduc on of CO2 emissions, the remaining service life of the vehicles must also be considered as a func on of the ban on use in order not to cause a higher burden due to any new produc on of HVAC systems, which are then in use for a remaining service life of the vehicles of a few months. The risks of emissions and prohibi on of fluorinated gases are adequately controlled through exis ng EU legisla on, in par cular the F-Gases Regula on (517/2014), by consequent rail sector proposed an exemp on for fluorinated gases under the scope of this regula on as some regula ons are already exempted in the proposed restric ons in the point 4. Having the inclusion of fluorinated gases in the restric on list will generate several prohibi ons on the placing on the market with different melines and rules. 60 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.3) Electronics and semiconductors 5.3.1) Coa ng, solvents and cleaning The Annex XV report does not propose any deroga on on coa ng, solvents, and cleaning. Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these materials. The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force made by FIEEC and by Orgalim. 5.3.2) Electronic components The Annex XV report does not propose any deroga on regarding the use of fluoropolymers for technically func onal elements within the electrical or electronic equipment in the rail industry. Without an alterna ve solu on, the rail sector faces a situa on that jus fies the deroga on for 13.5 years a er entry into force to retain the possibility of supplying these materials. The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force made by FIEEC and by Orgalim. 5.3.3) Semiconductors Semiconductors are essen al for opera ng the railway system. The rail industry is a downstream user of PFAS-containing products and is not responsible for selec ng the material used for the semiconductors. As drop-in PFAS subs tutes for established technologies, such as two-phase semiconductor cooling in metros, are not available, an instant ban with a transi on period of only 18 months would result in the affected product owners (European ci es) no longer being able to maintain their metros and thus gradually (maintenance typically necessary every 5-6 years) must take them out of service. Wellestablished and running metro lines of big European ci es currently planned with a projected remaining life me of around 20 years would be affected. Per city which will be affected, this concerns at minimum around 80 metro trains, each containing several power converters that depend on these substances. This would also mean that if one of those converters would need maintenance, the whole train would instantly fall out. In addi on, even if retrofi ng is technically feasible, ci es would have to pay for redesign and implementa on, extensive tes ng, and re-cer fica on. Costs that cannot be es mated now would certainly and unexpectedly challenge or even overwhelm the ci es' budgets. The need to completely replace an exis ng metro train/line would be even more challenging. If retrofi ng or replacement would not be an op on for a city, the worst-case scenario of banning PFAS would be the gradual loss of its public transport system. 61 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 As laid down, drop-in alterna ves for PFAS-based heat transfer and semiconductor cooling substances such as FC-3284, FC-72, or Novec 649 in exis ng rail applica ons, e.g. metros are not available, and their ban would significantly impact the owners of the products (e.g. European ci es). Therefore, a deroga on of at least 12 years + 18 months a er entry into force is required. The best op on would be the complete exemp on of those substances or PFAS from applica ons for rolling stock maintenance ac vi es. The Annex XV report proposes a deroga on under reconsidera on : x 5.ee [[the semiconductor manufacturing process un l 13.5 year a er EiF] The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force made by SEMI Europe (ECHA's consulta on reference number 4304) by ESIA (ECHA's consulta on reference number 4449) and by FIEEC and by Orgalim. 5.3.4) Wires and cables For wires and cables in the proposed restric on, there is no deroga on covering the use of motor winding. The rail sector needs at least 13.5 years a er entry into force to find alterna ve solu ons. Without this deroga on, an immediate ban of PFAS with a transi on period of only 18 months for use in electric motors for rail applica ons would result in a total prohibi on on electric train motors, including new and exis ng motors, when they require maintenance. The total turnover of new motors that a PFAS ban would impact is es mated to be immense. The economic impact on business with electric trains or trains depending on electric motors is expected to be even higher. This would highly affect and threaten the whole rail industry, thus significantly impac ng employees, public transport, and the shi toward more sustainable transporta on. 5.3.5) Various electronic assemblies (capacitors, plugs, transducers...) in the brake control It can be assumed that, at least not for all use cases, alterna ves are available or in development today. A complete analysis of > 1,000 capacitors would be required to get the complete picture. 5.3.6) Cables for magne c coil, used in valves for pressure control of the hydraulic brake A deroga on for 13.5 years a er entry into force is required. 62 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.4) Energy sector 5.4.1) Ba eries Ba eries are essen al for opera ng the railway system. The rail industry is a downstream user of PFAScontaining products and is not responsible for selec ng the substances used for the ba ery composi on. The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force made by RECHARGE (the second contribu on). 5.4.2) Proton exchange membrane (PEM) fuel cells For the PEM fuel cell, the restric on proposal includes a deroga on: x 6.e proton-exchange membrane (PEM) fuel cells un l 6.5 years a er EiF; Fluoropolymers used in fuel cells are a dis nct category of PFAS, recognised by OCDE as "of low concern". S ll, the target of decreasing all emissions could be envisaged through a "binding monitoring, repor ng and verifica on (MRV) system", ideally harmonised across industry and Member States. For more informa on, read the contribu on of Hydrogen Europe (ECHA's consulta on reference number 4144). The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force as a minimum for fluoropolymers used in fuel cells. This appropriate set-up would guarantee strict emissions control whilst securing adequate regula on for a crucial sector in the energy transi on, as hydrogen is essen al in suppor ng the European Green Deal and REPowerEU schemes. 63 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.5) Lubricants 5.5.1) Greases Greases are essen al for opera ng the railway system. The rail industry is a downstream user of PFAScontaining products and is not responsible for selec ng the substances used for the grease composi on. The Annex XV report proposes a deroga on under reconsidera on : x 5.s [lubricants where the use takes place under harsh condi ons, or the use is needed for safe func oning and safety of equipment un l 13.5 years a er EIF;] The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force made by ATIEL (ECHA's consulta on reference number 4423). 5.5.2) Low-viscosity lubricants Lubricants are essen al for opera ng the railway system. The rail industry is a downstream user of PFAS-containing products and is not responsible for selec ng the substances used for the lubricant composi on. The Annex XV report proposes a deroga on under reconsidera on : x 5.s [lubricants where the use takes place under harsh condi ons, or the use is needed for safe func oning and safety of equipment un l 13.5 years a er EIF;] The European rail sector supports the requests for deroga ons for 13.5 years a er entry into force made by ATIEL (ECHA's consulta on reference number 4423). 64 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.6) TULAC (Tex le, upholstery, leather, apparel and carpets) The Annex XV report proposes a deroga on : x 5.e tex les for the use in filtra on and separa on media used in high-performance air and liquid applica ons in industrial or professional se ngs that require a combina on of waterand oil repellence un l 6.5 years a er EiF. As a downstream user of PFAS-containing products and not responsible for selec ng the material used for the filtra on, the rail industry supports the deroga on for 6.5 years a er entry into force. 65 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 5.7) Request for a review clause and summary of deroga on requests The assessment of railways ideally requires an exemp on for all spare parts of products and for maintenance/servicing of equipment and vehicles already placed on the market at the me of the ban. If necessary, a unique railway regula on with transi onal arrangements could be applicable un l the end of the useful life of the equipment commonly used for the safe opera on of the railway system. The European rail sector is applying for 13.5 years deroga on periods for the uses where alterna ves are unavailable today. At the end of this deroga on period, some uses could be iden fied for which op ons will s ll not be available or where the choices would be regre able subs tu ons. In these cases, a mechanism to renew the deroga on would be essen al to avoid the substan al socio-economic impacts of the European Green Deal. However, such a renewal mechanism is currently missing from the proposed PFAS restric on. Therefore, a review clause should be included in the final restric on to provide three years to evaluate deroga ons before their expiry to assess whether alterna ves are now available or whether a further renewal of the deroga on is needed. In addi on, achieving a coherent policy without duplica ng the future revised regula ons on F-gases will also be necessary. Table 1 - The following table summarises the deroga on requests : Exemp on*: as already covered by the revision of the F-gases regula on Main application as defined Sub-uses as described in Annex XV Examples of use in Annex XV report proposal report proposal Applications of fluorinated Air conditioning and heat pumps gases (F-gas) Fire suppressants New HVAC Existing HVAC Existing HVAC with mechanical and hydraulic compressors Automatic fire system Request for confirmation of Request for derogations for the proposed derogation as missing uses and/or no in the Annex XV report possibility of modifying the proposal (plus a review existing application (plus a clause) review clause) Missing use Exemption* 5.i (13.5 years after EiF) Exemption* 5.p (6.5 years after EiF) Exemption* 5.m (13.5 years after EiF) Exemption* 66 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 Electronics & semiconductors Energy sector Lubricants Transport Refrigeration Coating, solvents, cleaning Electronic components Semiconductors Wires & cables Batteries Proton exchange membrane (PEM) fuel cells Greases Low viscosity lubricants Coating and finishings Electrical engineering and information technology Sliding and guiding elements Safety equipment (incl. fire prevention & protection) Sealing applications Catering Battery Monitoring Systems Climatic chamber Motor Sheath - Heat shrinkable Batteries Fuel cells Grease Oil Balljoint Sliding part - segment - guide - bearing Transformer - bogie motor - brake Valves of tank wagons Missing use 5.g (13.5 years after EiF) Missing use Missing use 5.ee (13.5 years after EiF) Missing use Missing use 6.e (6.5 years after EiF) 5.s (13.5 years after EiF) 5.s (13.5 years after EiF) 6.o (13.5 years after EiF) 6.o (13.5 years after EiF) 5.a (6.5 years after EiF) 6.o (13.5 years after EiF) 6.o (13.5 years after EiF) 6.o (13.5 years after EiF) Missing use TULAC (Textile, upholstery, Technical textiles leather, apparel and carpets) Valves, venting, 5.e (6.5 years after EiF) membrane Exemption* Exemption* 13.5 years after EiF 13.5 years after EiF 13.5 years after EiF 13.5 years after EiF 13.5 years after EiF as a minimum - 13.5 years after EiF - - 13.5 years after EiF as a minimum - 67 European rail sector's contribu on to the public consulta on on the PFAS restric on proposal - September 2023 6) Annex A tenta ve list of mapping PFAS used by the rail industry, par cularly by a rolling stock manufacturer, is an example of how many and where PFAS are used in its products. Cf. 2023-09 UNIFE contribu on to PFAS restric on proposal - non-exhaus ve list 68