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GFL GUJARAT FLUOROCHEMICALS Fluoropolymers in PFAS restriction proposal Gujarat Fluorochemicals Limited Date: 03.05.2023 Bk: 2966662 Contents * Fluoropolymers in PFAS restriction proposal ECHA's requirements in Public Consultation GFL's contribution to Public Consultation Contribution of Fluoropolymer Downstream User industry GF4 GUJARAT FLUOROCHEMICALS 2966662 We do not defend PFAS GFL GUJARAT FLUOROCHEMICALS * Regulators and environmentalists are mainly concerned about PFAS that are mobile, bioaccumulative and toxic * Fluoropolymers have nothing in common in terms of risk when compared to such PFAS of Concern * Fluoropolymers are included in the PFAS restriction proposal due to PFAS emission concerns during their lifecycle * GFL supports initiatives aimed at regulating PFAS of concern that pose an unacceptable risk * GFL does not defend PFAS of concern (For example: PFOA and SvHCs) 2966662 Fluoropolymers in EU PFAS restriction proposal GFbp GUJARAT FLUOROCHEMICALS 1. Fluoropolymers are banned with some time limited derogations 2. Intentional use of PFAS as polymerization aids in fluoropolymers is banned with derogations 3. Unintentional presence of PFAS in fluoropolymers is regulated 2966662 Time limited derogations on fluoropolymers Time limited derogations Potential derogations marked for reconsideration 6,5 YEARS AFTER EIF food contact materials for the purpose of industrial and professional food and feed production proton-exchange membrane (PEM) fuel cells textiles for the use in filtration and separation media 13,5 YEARS AFTER EIF VALUE SESH GUJARAT Fit HEMICAL THROUGH implantable medical devices (not including meshes, wound treatment products, tubes and catheters) tubes and catheters in medical devices coatings of Metered Dose Inhalers (MDIs) applications in petroleum and mining industry additives to hydraulic fluids in aircraft and aerospace industry Lubricants in certain categories diagnostic laboratory testing non-stick coatings in industrial and professional bakeware textiles used in personal protective equipment (PPE) hernia meshes wound treatment products coating applications for medical devices other than Metered Dose Inhalers Rigid gas permeable contact lenses and ophthalmic lenses, PTFE in ophthalmic solutions packaging PCTFE-based packaging for medicinal preparations, medical devices and medical molecular diagnostics packaging of terminally sterilized medical devices applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers or goods textiles for the use in engine bays for noise and vibration insulation used in the automotive industry membranes used for venting of medical devices the semiconductor manufacturing process 2966662 Intentional use of PFAS as polymerization aids SulARATFuOROCHEMCAS 1. PTFE, PVDF and FKM produced with fluorinated polymerization aids are banned from 18 months after Entry into Force (EiF) 2. All other fluoropolymers can be produced with PFAS polymerization aids until 6.5 years after EiF * More than 50% offluoropolymers do not require the use of polymerization aids 2966662 Unintentional presence of PFAS Ban on manufacture, use and placing on the market * As substances on their own * Asa constituent * A mixture * An article GF] GUJARAT FLUOROCHEMICALS > 25 ppb for any PFAS > 250 ppb for the sum of PFASs > 50 ppm for PFASs 2966662 ECHA's request for information in Public Consultation GFPp GUJARAT FLUOROCHEMICALS Data on emissions across lifecycle * Share of emissions (as percentages) attributable to these three different stages * Share of the waste (as percentages) treated through incineration, landfilling and recycling * Abatement technologies -- cost and efficacy Tonnage and emissions data on proposed derogations Analysis of alternatives and socio-economic analysis * Missing uses, Potential derogations marked for reconsideration, Other identified uses Analytical methods * Any new or additional information on analytical methods 2966662 GFbp Main concerns related to fluoropolymers during lifecycle GUJARAT FLUOROCHEMICALS 1. PFAS emissions during manufacturing of fluoropolymers Intentional use of PFAS as polymerization aids Presence of unreacted monomers, oligomers and other byproducts 2. PFAS emissions at the end of life of fluoropolymer applications Complete degradation offluoropolymers during incineration Leaching of PFAS during landfill due to potential degradation 2966662 PFAS emissions during manufacturing GFbp GUJARAT FLUOROCHEMICALS Intentional use of PFAS as polymerization aids * Hundreds of tons of PFAS are intentionally used as polymerization aids leading to serious environmental pollution * PFOA as depicted in the movie, Dark Waters * GenX and other C6 compounds as regrettable substitutions to PFOA * Manufacturing of PFAS polymerization aids are also contributing to PFAS emissions * Raw materials to manufacture PFAS polymerization aids are also PFAS * Packaging, Storage and transportation of these PFAS polymerization aids also contribute to emissions * Intentional use of PFAS as polymerization aids is the main cause of PFAS emissions linked to fluoropolymer lifecycle * Suitable regulations on intentional use of PFAS as polymerization aids will drastically reduce PFAS emissions 2966662 GFL's position on polymerization aids GFbp GUJARAT FLUOROCHEMICALS * GFL has developed Non-Fluorinated Polymerization Aid technology to manufacture the following fluoropolymers: PTFE * PVDF * FKM * PFA * GFL commits to completely stop the intentional use of PFAS as polymerization aids from 2024 2966662 Other PFAS emissions during lifecycle Unintentional generation of PFAS during manufacturing * Regulators have suggested a limit of 250 ppb for the sum of PFASs 250 ppb* 50000 tons = 12,5 kgs of PFAS Unintentional generation of PFAS during processing ?? (Data collection under progress) Unintentional generation of PFAS at End of Life ?? (Data expected by middle of May 2023 -- GFL incineration study) GFp GUJARAT FLUOROCHEMICALS 2966662 GFLs contribution to Public Consultation GF| GUJARAT FLUOROCHEMICALS Safety of fluoropolymers during its lifecycle mainly manufacturing and end of life phases Risks Information on remediation Use of PFAS Polymerization aids ManimeangS: (FPA) & its emissions thereof Processing phases Potential degradation into small DEAS Mol EauLEs Substitution of FPA with Non-FPA Implementation of abatement technologies to control emissions Fluoropolymers do not degrade End-of life phase IncompPlete incineration GFLUs incineration project in collaboration with KIT and other stakeholders Leachate from landfills Fluoropolymers are inert, non-toxic and do not leach 2966662 GFLs Incineration project GFPp GUJARAT FLUOROCHEMICALS Initiated & funded by Research partner Laboratory partner Feed sampling Incineration Advisor Academic Consultant Observers PFAS analysis collaboration partner Study Report generation Project Report generation Gujarat Fluorochemicals (GFL) Institute for Technical Chemistry (ITC), at Karlsruhe Institute of Technology (KIT) SGS, PFAS Competence Centre Pro-K, Fluoropolymer processing and downstream user association Dr. Phillip Taylor, P Taylor & Associates, LLC Dr. Bruno Ameduri, Senior Researcher at ICGM, University of Montpellier UBA, German Federal Environment Agency BAM, Federal Institute for Materials Research and Testing Institute for Technical Chemistry (ITC), KIT Chemservice GmbH, Germany 2966662 Contribution of Fluoropolymer DU industry * Provide data on all uses of fluoropolymers } GF] SuiARAT FLUOROCHIMICALS * Provide details on performance criteria, function, and benefits * Provide information on standards, specifications set by end use industries * Provide information on non-availability of alternatives to fluoropolymers If alternatives exist, what are the expected tradeoffs in terms of safety and health, performance, lifespan, impact to environment, decarbonization, innovation and technology * Provide data on economic impacts due to a restriction -- loss of jobs and revenue It is important to cover the entire value chain * Public consultation period -- 22 March to 25 September 2023 https://comments.echa.europa.eu/comments cms/AnnexXVRestrictionDossier.aspx?RObjectld=0b0236e1885e69de 2966662 Key messages ! GF] GUJARAT FLUOROCHEMICALS Fluoropolymers are safe and should be exempted Instead, Intentional use of PFAS as polymerization aids should be regulated Unintentional presence of PFAS should be controlled during manufacturing and processing by investing into abatement technologies Fluoropolymers fully degrade at their end of life - incineration 2966662 Decision tree for fluoropolymer regulation FLUOROPOLYMERS GUJARAT FLUOROCHEMICALS VALUE THROUGH GREEN CHEMISTRY Essential Jse Concept QET ETI (FV ET with FPAS EXEMPTION FOR ;ALL USES SATIONS BASED ON ABATEMENT DURING LIFE-CYCLE + <25 ppb PFAS IN FINAL PRODUCT *Ameduri 2023, Fluoropolymers: A special class of per- and polyfluoroalkyl substances (PFASs) essential for our daily life 2966662 Thhaannkk yyoouu 4 V! /4 GUUJJAARRAATT FFLLUUOORROOCCHHEEMMIICCAALLSS VALUE THROUGH GREEN CHEMISTRY 296666622