Document LpKwZmOm6D4VkKaLdbem51pOQ

Hydrogen Europe input to ECHA public consultation on the universal PFAS restriction proposal ANNEX Note 1: Henry et al. (2018), A critical review of the application of polymer of low concern and regulatory criteria to fluoropolymers, Integrated Environmental Assessment and Management published by Wiley Periodicals, Inc. on behalf of Society of Environmental Toxicology & Chemistry (SETAC), Volume 14, Number 3, pp. 316-334. Retrieved on: https://setac.onlinelibrary.wiley.com/doi/10.1002/ieam.4035. Note 2: Korzeniowski, S.H., et al. (2022), A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers. Integr Environ Assess Manag. Note 3: Fluoropolymers and fluoroelastomers are manufactured in closed manufacturing processes. In use, fuel cells and electrolysers use or create lethal electrical current, therefore consumers cannot be in contact with the components. In one of Hydrogen Europe's Members, general and local exhaust ventilation and respiratory personal protective equipment is utilized to ensure that exposure to workers is below 0.01 mg/m3, as an 8-hour time-weighted average. Where there is a potential for contact with process material, chemically protective dermal protective equipment is also utilized. Fluoropolymer and fluoroelastomer products are low-vapor pressure solids (and some may be dispersed in liquid). These products are handled in controlled environments and dermal and eye protection is used to guard the worker against the possibility of a splash or contact with dust, as well as to protect the product purity. At the same Member's installations, the principle risk is from a nonaqueous solvent in which the product may be dispersed or from transfer of a solid product to a cigarette or to food. For this reason, consumption of food is strictly controlled, and smoking prohibited in our workplaces. (Source: included in the first Call for Evidence by one of Hydrogen Europe's members) Note 4: Technology Readiness Level, as described by the European Commission in its Horizon 2020 Work Programme General Annexes. TRL 2 mentioned refers to a technology that is `technology concept formulated'. https://ec.europa.eu/research/participants/data/ref/h2020/wp/2014_2015/annexes/h2020wp1415-annex-g-trl_en.pdf Note 5: Jobs at risk calculated based on FCHJU Study (https://www.fch.europa.eu/sites/default/files/Evidence%20Report%20v4.pdf; https://www.fch.eur opa.eu/sites/default/files/Findings Report v4.pdf): 5.6 full-time employment (FTE) direct jobs (DJ) & 1.84 FTE/1M worth of PEM electrolyser deployment; 2.3 FTE DJ & 14.1 indirect jobs (IJ)/1M worth of heavy-duty fuel cell electric vehicle deployed (incl. ships); 2.8 FTE DJ & 12.9 FTE IJ/1M worth of light-duty fuel cell electric vehicle deployed Note 6: As mentioned in the European Commission's REPowerEU Communication https://eurlex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A230%3AFIN&qid=1653033742483 Note 7: Hydrogen fuel cells are a potential electrification technology that can provide near-silent power and mobility for military vehicles while providing high torque with inherently scalable power and energy, capable of providing range beyond that of purely battery-powered electric vehicles. Sobo, A.; Sly, D.; Ruszel, M.; Wicek, A. Prospects for the Use of Hydrogen in the Armed Forces. Energies 2021, 14, 7089. https://doi.org/10.3390/en14217089 Note 8: It can be assumed that companies producing PEM fuel cells and PEM electrolysers outside the EU (e.g. Asia, North America) can gain a significant competitive advantage, as they are not affected by the ban and can enter the market with the PFAS-containing raw materials according to the state of the art in the respective countries outside the EU. Companies manufacturing fuel cells and electrolysers within the EU would thus face a significant delay in market entry, as they would first have to develop a PFASfree product to offer on the market. In addition to the loss of time, the companies within the EU would also be at a significant competitive disadvantage, as the number of units of competitors who could manufacture their PFAS-containing products outside the EU could also sell increasing numbers of units with the current increase in global demand and could thus offer their products on the market more cheaply than manufacturers from the EU due to the economies of scale. Since manufacturers of fuel cells and electrolysers who can produce stacks containing PFAS outside the EU can also establish themselves on the market earlier with their products and build and consolidate business relationships with customers, while companies in the EU still have to develop fluorine-free alternatives, market entry for companies based in the EU is also made much more difficult downstream and it is questionable whether products from the EU can be offered at competitive prices at all. Note 9: Fluoropolymers are also used in critical CCUS applications (e.g. CO2 transport, filtration, and compression), which is necessary for the production of blue hydrogen. Note 10: In particular, electronic components are largely used within the hydrogen industry (e.g. sealings devices, monitoring systems, sensors.) and are not derogated. Electronic components are typically integrated into complex devices or systems. Therefore, even if the hydrogen sector gets a derogation, the absence of derogation in electronics may still result in major disruptions within the industry. Indeed, some electronics-containing devices may not be produced and/or repaired until a PFAS-free alternative is developed, which could take beyond even a 12-year derogation. Note 11: The restriction proposal includes a derogation for polymerization aids/polymer processing aids (PPAs) in the production of polymeric PFAS until 6.5 years after entry into force, but it currently excludes use of PPAs for the production of PTFE, PVDF and FKM. We would like to highlight that the current state of non-fluorinated polymer processing aid technology cannot produce all the necessary grades of fine powder PTFE, including those necessary for many of the end-uses, including applications in Hydrogen value chain (e.g. membranes, sealants and gaskets). Based on the input from our members, real-world experience has demonstrated that it takes greater than 7 years to fully transition complex fluoropolymer-based products from PTFE resins made with one polymerization aid to PTFE resins made using a new (also PFAS based) polymerization aid, after the new polymerization aid was demonstrated to be technically feasible for PTFE resin production. Transition to non-PFAS-based polymerization aids, to achieve the necessary grade of fine powder PTFE, is expected to be even more challenging. Nonfluorinated PPA technology to make fine powder PTFE has not yet even reached that initial technical feasibility point, and the timeline for such advancement is not known. Although ECHA clarified its intention during the April 5 Q&A session that a derogation of a use brings about the same derogation for the entire upstream value chain of that use (including the use of monomers and polymerization aids in the case of fluoropolymers), this is not reflected in the wording of the draft yet. This is a crucial point which should be defined very clearly without room for different interpretations. We would like to make it clear, that to enable production of any currently proposed derogated use (e.g PEM Fuel Cells, as proposed in point 6e of restriction proposal), or any derogated use proposed in the hydrogen value chain, it is necessary to also derogate PPAs to produce fluoropolymers, for the duration matching the derogated use duration. Note 12: Aleksandrov et al., Waste incineration of Polytetrafluoroethylene (PTFE) to evaluate potential formation of per- and Poly-Fluorinated Alkyl Substances (PFAS) in flue gas, Chemosphere, Volume 226, 2019, Pages 898-906, ISSN 0045-6535, https://doi.org/10.1016/j.chemosphere.2019.03.191, (https://www.sciencedirect.com/science/article/pii/S0045653519306435). Note 13: The American Institute of Chemical Engineers will lead a consortium that includes H2 industry partners, universities, and national laboratories. The effort will develop technology relevant to circular recycling for the H2 economy to address end-of-life and critical supply chain challenges. Through this program the following recycling targets for primary components of fuel cell and electrolysers are set with green methodologies Component Platinum Iridium Ionomer Carbon Program Goal 99% 95% 90% 70% Notes 99.95% pure - in form reusable for H2 economy 99.90% pure - in form reusable for H2 economy Reuse, repair, or restart the fluorinated components for H2 economy Carbon black, reusable for carbon support or other. Note 14: For more information on the HyTechCycling project, please consult: https://hytechcycling.eu/ Note 15: For more information on the H2Giga project, please consult: https://www.wasserstoffleitprojekte.de/projects/h2giga Note 16: This is achieved through various workstreams; Technoeconomic and Lifecycle Analysis (TEA/LCA), Digital Passport for Data/Material Handling, Stack Disassembly, MEA Disassembly, Membrane/Ionomer Separation and Purification, Precious Metal Separation and Purification, and Remanufacture and Validation of Performance. Note 17: for more information on project BEST4Hy, please consult: https://cordis.europa.eu/project/id/101007216 Note 18: Please consult the BReCycle project in Germany: https://www.enargus.de/pub/bscw.cgi/?op=enargus.eps2&q=%2201206524/1%22 Note 19: Frankenstack, UK Research and Innovation, https://gtr.ukri.org/projects?ref=133704 Note 20: Marcelo Carmo, Gareth P. Keeley, Daniel Holtz, Thomas Grube, Martin Robinius, Martin Mller, Detlef Stolten, PEM water electrolysis: Innovative approaches towards catalyst separation, recovery and recycling, International Journal of Hydrogen Energy, Volume 44, Issue 7, 2019, Pages 3450-3455, ISSN 0360-3199, https://doi.org/10.1016/j.ijhydene.2018.12.030. Note 21: E.g.: Grot S. and Grot W., US7255798B2 - Recycling of used perfluorosulfonic acid membranes - Google Patents; Coleman R. Ralph T., and Plechkova N., EP3275036B1 - Process Google Patents Note 22: Aleksandrov et al., Waste incineration of Polytetrafluoroethylene (PTFE) to evaluate potential formation of per- and Poly-Fluorinated Alkyl Substances (PFAS) in flue gas, Chemosphere, Volume 226, 2019, Pages 898-906, ISSN 0045-6535, https://doi.org/10.1016/j.chemosphere.2019.03.191, (https://www.sciencedirect.com/science/article/pii/S0045653519306435) tested for the presence of 31 different PFAS and 11 of these were detected but deemed to be due to contamination from the environment. The labs detected 11 PFAS randomly in both neutral burns and PTFE burns, leading the scientists to conclude that the source of the PFAS are due to background contamination rather than the addition of PTFE'. Note 23: Bakker et al., Per- and polyfluorinated substances in waste incinerator flue gases, RIVM rapport 2021-0143, 2021. DOI 10.21945/RIVM-2021-0143 Note 24: The International Energy Agency (IEA) tables over 15 million fuel cell vehicles on the road by 2030, in: IEA, Net Zero by 2050 A Roadmap for the Global Energy Sector, 2021. As a complement, Table 1 on page 9 of the report `Value Added of the Hydrogen and Fuel Cell Sector in Europe' (FCH 2 JU, 2019) provides some estimates for 2024 and 2030, but in amounts of units and not in MW/GW capacities. Looking at today's data, based on tables page 41 of the same study and assuming a 78% share of PEM fuel cells in Europe, we can deduct an adopted capacity of 116 MW of PEM fuel cells in Europe (forecast for 2020). URL: https://www.fch.europa.eu/sites/default/files/Value%20Chain%20study%20SummaryReport_v2.02. pdf Note 25: European Commission, REPowerEU Plan, May 2022: https://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=COM%3A2022%3A230%3AFIN&qid=1653033742483 Note 26: European Commission, A hydrogen strategy for a climate-neutral Europe, July 2020: https://ec.europa.eu/energy/sites/ener/files/hydrogen_strategy.pdf Note 27: See, amongst others: Chi Hoon Park, Chang Hyun Lee, Michael D. Guiver, Young Moo Lee, Progress in Polymer Science, Volume 36, Issue 11, 2011, Pages 1443-1498, ISSN 0079-6700, https://doi.org/10.1016/j.progpolymsci.2011.06.001; Dong Won Shin, Michael D. Guiver, and Young Moo Lee,Chemical Reviews 2017 117 (6), 4759-4805 DOI: 10.1021/acs.chemrev.6b00586; N. Esmaeili, E. M. Gray, C. J. Webb, ChemPhysChem 2019, 20, 2016. Note 28: Cumulative amounts from the relevant years: https://www.energy.gov/eere/fuelcells/hydrogen-andfuel-cells-annual-merit-review-proceedings Note 29: For more information, please consult: https://cordis.europa.eu/project/id/826097 Note 30: For more information, please consult: https://cordis.europa.eu/project/id/101006641 Note 31: For more information, please consult: https://cordis.europa.eu/project/id/300081 Note 32: For more information, please consult: See e.g. https://iopscience.iop.org/article/10.1149/2.0131806jes Note 33: For more information, please consult: See e.g. https://pubs.acs.org/doi/10.1021/acs.chemmater.8b05302 Note 34: The core of both proton exchange membrane (PEM) water electrolysers and PEM fuel cells is an electro-chemical reaction through a membrane in which certain types of polymers meeting the criteria defined by the five submitters of the restriction proposal, are used. A very large proportion of planned projects involving electrolysers and fuel cells (and in some applications 100%) are based on this PEM technology. Amongst tracked water electrolysis projects to be completed by 2030 in EU/EEA/UK for which information is available, PEM electrolysis accounts for 57% of the projects and 33% of the capacity. In the case of alkaline water electrolysis (ALK), a diaphragm (e.g., Zirfon) is used instead of a membrane and does not contain PFAS. Yet, like for the PEM technology, fluoropolymers are used in the product, e.g., as sealing materials and gaskets, and a fluorinated membrane is required to manufacture the liquid electrolyte needed for the ALK technology. ALK electrolysis accounts for 35% of the projects and 59% of the capacity. The remaining shares belong to solid oxide technology projects and projects combining multiple technologies for which the capacity cannot be split. It is important to note that as the hydrogen industry ramps up, it is crucial that all technologies are taken into account and supported, as no single technology can be used in isolation to achieve electrolyser ramp-up objectives. Regarding PEM/ALK and SOEC technologies, please find a short list of attributes: - Alkaline (ALK) water electrolysis: o Pros: ALK technology is today the most mature technology, with lower costs and higher efficiency than PEM. o Cons: lower surface energy yield (requires more space) and lower reactivity to load factor than PEM (its use for intermittent renewable energy storage application is more limited than PEM's). - Proton exchange membrane (PEM) water electrolysers: o Pros: PEM has a very high surface energy yield (higher than ALK) and better reactivity to load factor than ALK. It is typically adapted for a use with intermittent energy production sources. Cost and efficiency are also expected to decrease significantly and converge with those of ALK. o Cons: Currently ALK have a higher efficiency than PEM electrolysers (by about ~6%) but this is expected to converge in the long term. Similarly, current cost of PEM electrolyser is ~15 % higher than ALK, but again, in the long term this should converge as well. - High-temperature Solid Oxide electrolysis: o Pros: electricity consumption can be reduced to 41 kWh per kg of hydrogen (efficiency of over 80%) by operating the electrolysis process at temperatures around 7001,000C. Therefore industrial sites with available waste heat source are most suitable to take advantage of this technology. o Cons: For most applications, where there is no waste heat available at the hydrogen production site, the electrolysers that make the most sense are low temperature electrolysers (ALK and PEM). Other drawbacks are high start-up times and the need for materials that can sustain high temperature. Note 35: https://onlinelibrary.wiley.com/doi/full/10.1002/aenm.202103559 "Even with optimized ionomer content, ion exchange capacity, and solvent systems, hydrocarbon MEAs feature inferior performance compared to state-of-the-art PFSA MEAs even at high humidity (>80% RH) and especially in the kinetic region (E > 0.7 V).[1, 17, 59] The inferior performance of hydrocarbon MEAs at high humidity and at high cell potentials might be linked to 1) a lower ECSA, 2) a lower oxygen permeability of hydrocarbon ionomers, and 3) a slightly lower proton conductivity of hydrocarbon ionomers in the catalyst layer." Note 36: For more information on the DOLPHIN project, please consult: https://cordis.europa.eu/project/id/826204