Document KpQ1ML0ZoZOO4wdQQpL8Y2bx

To: From: restrictiePFAS @rivm.nl] 2966005 Sent: Subject: Tue 7/19/2022 12:19:13 PM FW: Fluoropolymers - New scientific study demonstrates the insignificant risk fluoropolymers have on human health or the environment during the intended use phase, according to internationally recognized criteria Received: Tue 7/19/2022 12:19:14 PM Ter archivering bij Plastics Europe From: JIE @iasticseurope.org> Sent: dinsdag 19 juli 2022 14:16 WE EES @baua.bund.de; EEE se; EEE eo niljodir.no; IEEE @mst.dk; < 5.1.2e @rivm.nl> oem Subject: Fluoropolymers - New scientific study demonstrates the insignificant risk fluoropolymers have on human health or the environment during the intended use phase, according to internationally recognized criteria Dear Madam, Dear Sir, A new scientific study demonstrates the insignificant risk fluoropolymers have on human health or the environment during the intended use phase, according to internationally recognized criteria. 1. About the Study The Fluoropolymers Product Group (FPG) members are committed to substantiating the safety to human health and the environment of its products during their intended use phase. As such, FPG members participated in the development of an in-depth assessment of its commercially available products against the 13 internationally recognized OECD polymer of low concern (PLC) criteria. This study was led by the American Chemistry Council's Performance Fluoropolymer Partnership (PFP). The study looked specifically at the use phase ofthe life cycle and potential threats to human or environmental health during intended use. 2. Study Findings - The findings of the study in full can be found here. The outcome of this scientific study demonstrates that approximately 96% of the global commercial fluoropolymer market meet or exceed the OECD PLC criteria 2. They have been shown to be chemically and biologically stable, non-bio accumulative, nonbioavailable and non-toxic during their intended use phase. The results clearly demonstrate that the five most economically valuable fluoropolymers (by global market volume) pose insignificant threats to humans or the environment. The conclusions of this study also provide further evidence that PFAS should not be grouped together as one for the purpose of regulation. Although fluoropolymers can be considered PFAS due to their structural makeup, they have unique physical, chemical, environmental, and toxicological properties which differentiate them from other PFAS. The authors of the study "advocate for a segmentation based on properties before performing any grouping-based risk assessment, placing stable, non-hazardous fluoropolymers, that meet the criteria to be considered polymers on low concern, in a separate category." 3. Next Steps While the results of the study demonstrate, overwhelmingly, that fluoropolymers are safe during intended use phase, FPG members continue to look at the full cycle of its products. All FPG Members have already committed voluntarily to responsible manufacturing principles in term of continuously improve and/or develop best available techniques in the manufacturing process, management of environmental emissions, development of R&D programs for the advancement of technologies allowing for the replacement of PFAS-based polymerization aids, and/or the increase recyclability and reuse of its products in line with the objectives of circular economy. Work is in progress regarding the possible implementation ofa responsible manufacturing label. 4, What are fluoropolymers? Fluoropolymers are a distinct subset of fluorinated polymers. They are polymers with fluorine atoms directly attached to their carbononly backbone. Fluoropolymers are critical for many uses in our daily lives as well as those integral to helping us achieve the European Green Deal objectives. Fluoropolymers provide exceptional functionality and benefits for multiple innovations and markets such as semiconductors, renewable energy, electronics, medical devices and aerospace and smart mobility solutions. In most applications, there are no suitable alternatives which can provide the same combination of functionality and performance. 5. About the Fluoropolymers Product Group The Fluoropolymers Product Group represents Europe's leading fluoropolymer producers and experts. With a unique set of properties unobtainable by other polymers, fluoropolymers are non-replaceable across many key sectors and applications. Fluoropolymers ensure safety, reliability, durability and performance in numerous technologies, industrial processes and 2966005 products that are critical for human health, safety and the environment. We are committed to promoting innovation, safe use of their products, sustainable manufacturing and stewardship across the industry for all our products. As the voice of the industry across Europe, the Fluoropolymers Product Group advocates for a balanced regulatory environment based on scientific facts to ensure that European industries remain competitive and sustainable. Part of PlasticsEurope, the group's members are 3M, AGC, Arkema, Chemours, Daikin Chemicals, W. L. Gore & Associates and Solvay. Associate members are DuPont, Gujarat Fluorochemicals and Honeywell. Do not hesitate to contact me if you need additional information. Kind regards, 5.1..512e Fluoropolymers Group Le PLASTICS EUROPE Enabling a sustainable future EEE @plasticseurope.org 5.1.2 PlasticsEurope AISBL- fluoropolymers.plasticseurope.org Rue Belliard 40 Box 16+1040Brussels+Belgium inV Transparency Register identification number: 454264611835-56 Plastics Europe is the pan-European association of plastics manufacturers with offices across Europe. For over 100 years, science and innovation has been the DNA that cuts across our industry. With close to 100 members producing over 90% of all polymers across Europe, we are the catalyst for the industry with a responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and sustainable. We are committed to implementing long-lasting positive change. To know more on how we process personal data, read our Privacy Notice. We process your email address to send you our newsletter or invite you to events. You can unsubscribe by emailing us at privacy@plasticseurope. org. When we send you an email, it may contain a web beacon or tracking pixel that we use to collect certain information about your interaction with the email (such as your IP address and the date/time that you opened an email). Check our Cookies Notice to know more. If you don't want to be tracked, choose to display your emails in text-only format. The substances included in this study are: polyvinylidene fluoride (PVDF) homopolymer; PVDF copolymer; ethylene-chlorotrifluoroethylene (ECTFE) copolymer; ECTFE terpolymer; polychlorotrifluoroethylene; fluoroethylene-vinyl ether copolymer; terpolymer of ethylene, tetrafluoroethylene, and hexafluoropropylene; terpolymer of chlorotrifiucroethylene, tetrafluoroethene, and perfluoroalkyl-vinyl-ether; and terpolymer of tetrafluoroethylene, hexaflucropropylene and vinylidene fluoride, as well as specialty fluoroplastics amorphous fluoropolymers and fluorinated ionomers. The fluoroelastomers included in this study include tetrafluoroethylene-propylene copolymer (FEPM); three fluoroelastomers (FKM); and a perflucroelastomer (FFKM). 12113 OECD criteria were used to determine PLC status: polymer composition, molecular weight, weight percentage of oligomers, electrical charge, reactive functional groups, functional group equivalent weight, low molecular weight leachables, water solubility, particle size, polymer stability, thermal stability, abiotic stability, and biotic stability.