Document Lgdkn43L5wqa1Ynq6yXMV14rX

RIFRA .0 MASTERBATCHES Molinetto di Mazzano, 31/08/2021 . Kind attention: Mr. Martijn Beekman - Netherlands Dr. Mandy Lokaj - Germany Mrs. Jenny Ivarsson - Sweden Mr. Toke Winther - Denmark Mr. Audun Heggelund - Norway Mr. Mark Blainey - ECHA rivm.nl @baua.bund.de @kemi.se M@mst.dk @miliodir.no @echa.europa.eu Through: Pro-K Industrieverband Halbzeuge and Konsumprodukte aus Kunststoff e.V. (pro-K), Stadelstr. 10, 60596, Frankfurt am Main, Germany The members of pro-K mainly focus on processing of Fluoropolymers, part manufacturing and its applications, the involvement of downstream users in PFAS process. Subject: PFAS restriction proposal & request for exemption of FLUOROPOLYMERS Reference: PFAS - Registry of restriction intentions until outcome (Rol) dated 15th July 2021 Dear Sir/Madam, With regards to Registry of Intention (Rol) filed by 4 EU Member States (Germany, the Netherlands, Sweden, and Denmark) & Norway for the restriction of PFAS, we, a member of fluoropolymer downstream user industry, hereby, would like to share some salient facts related to the importance of fluoropolymers, critical functionalities, performance and benefits of its applications to society, while acknowledging concerns regarding PFAS emissions related to the use of fluoropolymers and their end of life. Registry of Intention for PFAS restriction was announced by ECHA on 15th July 2021, to prepare a restriction proposal for PFAS. Fluoropolymers are also included in the scope. The restriction proposal is intended to be submitted to ECHA by 15th July 2022. Fluoropolymers are a distinct subset of PFAS and are inherently safe, non-mobile, non-bio accumulative and nontoxic. Fluoropolymers are different from other PFAS as they do not share the toxicological and environmental profiles associated with PFAS of concern. Fluoropolymers have unique set of physicochemical properties, they meet OECD polymer of low concern criteria, and are considered to have insignificant environmental and human health impact. Fluoropolymers ensure safety, reliability, durability and critical performance in numerous technologies, industrial processes and everyday applications that are important for human health, safety, and the environment. With a unique combination of functionalities, fluoropolymers are irreplaceable across many key sectors/applications. Alternatives to fluoropolymers, if exist, escalate safety risks, carbon footprint, technology regression, and do not match the advanced performance of fluoropolymers. Most importantly, restriction on fluoropolymers will make EU industry Rifra Masterbatches S.p.A. Via T. Tasso, 8 25080 Molinetto di Mazzano (BS) Tel. +39 030 212171 Fax +39 030 2629757 R.I. 01006560179 R.E.A. 224144 C.C.I.A.A. BS P.IVA e C.F.:01006560179 Capitate Sociale 600.000 i.v. www.rifra.it inio@r [II lose its technological superiority over other economies and could put Europe's climate and energy goals at risk. Overall, fluoropolymers contribute heavily to Europe's socioeconomic status and are critical for the betterment of the society. The fluoropolymer downstream user industry acknowledges the concerns regarding PFAS emissions due to the use of fluoropolymers and end of life processes. We wish to assure the authorities and EU Member States that, we are implementing Best Available Technologies to ensure reduction in PFAS emissions in a systematic way and eventually eliminating them to achieve EU's sustainability goals. Parallelly, we are consciously working on recyclability and reusability to meet circular economy goal. Fluoropolymers play an important role in achieving EU Green Deal objectives and UN Sustainable Development Goals (UN SDG) because of their vital use in Lithiumion batteries, Green hydrogen, Fuel Cell, Solar and Wind energy. No newage technologies are possible without the use of fluoropolymers. Restriction on the use of fluoropolymers would adversely impact implementation of these technologies crucial for planet's future as well as in all existing applications vital for the society. Considering the benefits of fluoropolymer applications to environment and society, low PFAS emissions and initia tives being taken by the processing industry to further minimize emissions and closing the loop by implementing circular economy wherever possible, we request for a complete exemption of fluoropolymers from the PFAS re striction proposal. Fluoropolymers processed by us: ...PTFE, PVDF.................................................................................................................. Service application industries: Medical devices, food contact and "non food contact" packaging, Plastic Films in general............................................. Sincerely yours, Name and signature Andrea Ubbiali............ Company name and address Rifra Masterbatches SpA Via T Tasso, 8 25080 - Molinetto ITALY