Document MJN16QKZ43K8OBKwgONnLpxk9

From: To: Ce: Subject: Date: Attachments: --- On site intermediates exemptions under the EU REACH and POP Regulations 08 July 2020 15: 13:06 iroageQQJ 0if Dear Dear 1 hope this email finds you both weil during these interesting times. As PFOA recently moved from the REACH Restriction to the POP Regulation, 1 am contacting you for an advice regarding the 'on site intermediates': Am I correct in understanding that under the POP Regulation the on-site intermediates are not 'automatically' exempted, as they were under the REACH Article 68 (1)(2) (= "on site isolated intermediates are excluded from the introduction and amendment of restrictions"), but we would need to ask for a separate exemption for 'closed-system site limited intermediate' (Article 4 (3) of the POP Regulation (EU) 2019/1021)? We noted there is a transition period until 3 December 2020 for PFOA compounds that are currently subject to a derogation from the Annex XVII restriction (Recital 9). Would that extension apply also to on-side intermediate uses of PFOA compounds? Lastly, 1 would also like to understand better the conditions and sequence (+ timing) for requesting an exemption under Article 4(3) of the POP Regulation. lt is not clear from that Article whether and to what extent the Commission must intervene in adopting a delegated act with such exemption, before or after notification to the POP secretariat. 1 would appreciate your feedback on these three questions, as 3M Dyneon plant in Germany might need to request an exemption for closed-system site-limited intermediates under Article 4(3). 1 can be reached on my mobile phone ) if you would like to discuss further by phone. Thank you very much & Best regards ---- lil