Document KLNwwXjB7QKL9adenkkwwMJK
From: Sent: To: Subject: Attachments:
RReeff. AArres((220024))62206886375961 --1049//0093//2002244
(CAB-VON DER LEYEN) 19 March 2024 18:05
;CAB-VON DER LEYEN) FW: nomination of siloxanes to the Stockholm convention Siloxanes nomination to Stockholm convention.pdf
From:
1ec.europa.eu>
Sent: Thursday, March 14, 2024 3:02 PM
To:
^M^Bec.europa.eu>
Subject: RE: nomination of siloxanes to the Stockholm convention
From:
cea.auto>
Sent: Wednesday, March 13, 2024 2:30 PM
To: VAN KEMSEKE Peter (CAB-VON DER LEYEN) <Peter.VAN-KEMSEKE@ec.europa.eu>: CANTON
Joan (CAB-BRETON) <Joan.CANTON@ec.europa.eu>; LESOVICI Roxana (CAB-VALEAN)
<Roxana.LESOVICI@ec.europa.eu>
Subject: nomination of siloxanes to the Stockholm convention
Dear Mr. Van Kemseke, dear Mr. Canton, dear Ms. Lesovici,
I hope this e-mail finds you well. As Automotive industry we would like to express our concerns regarding the POP nomination of siloxanes (better known as D4,D5,D6) and ask first for an impact assessment.
The Automotive industry acknowledges the effort of the COM to phase out hazardous substances. However, ACEA, ACEM, CLEPA and ETRMA respectfully urges the European Commission to conduct a thorough impact assessment before nominating D4, D5, and D6 as persistent organic pollutants (POPs) under the Stockholm Convention. In accordance with the Commission's Better Regulation guidelines (#Toolbox 7), an impact assessment is recommended when the proposal is likely to result in significant economic, environmental, or other impacts, and when alternative policy options are available (page 42, Toolbox). We believe these conditions apply to the potential POP nomination of D4, D5, and D6.
The oversight of an impact assessment could neglect the essential role of D4, D5, and D6 in the intermediate production of silicone polymers, as indicated by our upstream suppliers. These compounds are fundamental building blocks for silicone polymer manufacturing, critical for producing components such as seals, gaskets, adhesives, lubricants, and coatings in the automotive industry and in the tyres manufacturing process. These materials are indispensable for ensuring vehicle safety, reliability, and longevity. Additionally, we draw attention to the complexity associated with finding viable alternatives. The current regulatory scrutiny on per- and polyfluoroalkyl substances (PFAS) positions them as the only known potential substitutes, in some applications. However, PFAS also present unique challenges, and their adoption without careful
consideration could lead to unintended consequences. ACEA, ACEM, CLEPA and ETRMA maintains its reservation against the hasty nomination of D4, D5, D6 into the Stockholm Convention. Rushing into restrictive measures without a comprehensive impact assessment could inadvertently create new challenges without addressing existing concerns. We are at your disposal to address any inquiries or provide further information. Yours sincerely, On behalf of ACEA, ACEM, CLEPA and ETRMA (European Automobile Manufacturers Association; European Motorcycle Manufacturers Association; European Association of Automotive Suppliers and European Tyre & Rubber Manufacturers Association)
acea.auto
European Automobile Manufacturers' Association
www.acea.auto