Document O1ejG7XDVgbYB6Lxeo70qbk6Q

LANXESS Energizing Chemistry LANXESS Statement on the PFAS Restriction Proposal 1 Table of content 1 Introduction........................................................................................................................ 3 1.1 Importance of LANXESS products................................................................................ 3 1.2 Sustainability at LANXESS ............................................................................................ 3 1.3 We support a targeted regulation of PFAS.................................................................. 3 1.4 Showing the affectedness by means of an example ................................................... 3 2 Importance of fluoropolymers in components in chemical production............................ 4 2.1 General importance of fluoropolymers....................................................................... 4 3 Example chlorine value chain............................................................................................. 6 3.1 Implications for LANXESS as a downstream user of chlorine...................................... 6 3.2 Importance of fluoropolymer-based components in the production of chlorinated aromatics ................................................................................................................................ 7 3.3 Importance of fluoropolymer-based components in the production of phosphorus trichloride. .............................................................................................................................. 9 3.4 Impact of a ban on fluoropolymers on plant permitting .......................................... 12 4 Special features of multiple synthesis in the batch process ............................................ 13 5 End-of-life management of fluoropolymer-containing components .............................. 14 6 Evaluation of substitution possibilities ............................................................................ 14 7 Conclusion ........................................................................................................................ 15 2 1 Introduction 1.1 Importance of LANXESS products LANXESS is a leading specialty chemicals company headquartered in Cologne, Germany. Our products are the result of multi-step synthesis processes to provide our customers, which represent a wide range of value chains, with diverse solutions for current challenges, e.g.: e-Mobility: Battery materials for lithium-ion batteries Climate protection: lubricants and coatings for wind turbines, heat transfer media for solar cells Biosafety: disinfectants for use in medical facilities, industry, public facilities and farms Sustainable and safe buildings: flame retardants for insulation materials Water treatment: Ion exchange resins 1.2 Sustainability at LANXESS Sustainability is a core element of the LANXESS business strategy, and we therefore support the EU Commission's Green Deal ambitions. As part of our product stewardship, we foster the continuous improvement of product safety, which is anchored as a core issue in our corporate policy and in the company-wide management system. We are committed to avoiding risks to people and the environment along all phases of the product life cycle through safe research, manufacturing, storage, logistics, use and disposal. 1.3 We support a targeted regulation of PFAS We support a differentiated and risk-based approach to regulating PFAS in uses with high exposure potential, for which technically and economically suitable alternatives already exist. However, a blanket ban on non-hazardous fluoropolymers in industrial plants is disproportionate, as is shown here, and would lead to a massive weakening of Europe for industrial operations, along with investment and employment opportunities. With this submission, we want to demonstrate that an unlimited exemption of non-hazardous fluoropolymers in industrial applications is necessary and justified. 1.4 Showing the affectedness by means of an example Elemental chlorine is an important raw material for the chemical industry and serves as a building block for a variety of life-improving and consumer products. In this article, we will use the example of a value chain - starting with the raw material and the further processing of elemental chlorine - to illustrate how LANXESS and our customers would be affected by a ban on fluoropolymers in the components of our various facilities. 3 2 Importance of fluoropolymers in components in chemical production 2.1 General importance of fluoropolymers Fluoropolymer-based materials and components play an important role throughout the processing industry, e.g., in the manufacture and handling of basic chemicals and numerous specialty chemical products. They can withstand extreme temperature and pressure fluctuations and are particularly resistant to acids and alkalis without jeopardizing functionality or performance. Many fluoropolymers relevant to industry meet the OECD criteria for "polymers of low concern" (PLC). Due to their high molecular weight, they are chemically stable, nontoxic, non-bioavailable, non-water soluble and non-mobile. In many cases, they are absolutely necessary to ensure the functionality and safety of industrial plants and to operate facilities in compliance with licensing requirements. Fluoropolymer-based materials and components are also essential in many cases for the safe transport and handling of chemicals (see chapter 3.3). LANXESS operates a total of 61 plants in the European Union in five countries (Germany, Belgium, France, Italy, Netherlands), all of which would be affected by a blanket PFAS ban. In an internal study, we estimate the number of affected components at over 110,000 out of a total of over 340,000 units, which corresponds to a share of about one third. The use of fluoropolymers runs through almost all classes used. As expected, this primarily applies to product-carrying lines including fittings and pumps. Particularly worthy of mention is also the large number of pieces of equipment used in process control. Due to their importance for the safe operation of chemical plants, very high demands are placed on measuring equipment and control valves in terms of reliability and availability. Equipment affected by the ban of fluoropolymers by category Others 13% Pumps 6% Valves and accessories 31% Devices for process control 8% Flexible hoses 8% Piping 8% Instruments 26% 4 Functional properties of the components containing fluoropolymers are required in equipment throughout many chemical plants. The following components are particularly important to LANXESS: 2.1.1 Seals Due to their chemical resistance (safety aspect) and physiological safety (FDA approval 1/ USPClass 2 ), fluoropolymer-based seals are used as standardized industrial products in the chemical and pharmaceutical environment. Fluoropolymer-based seals are mandatory in many cases to enable the safe and permit-compliant operation of equipment for the production of basic chemicals or other chemical products. Beyond manufacturing, the use of fluoropolymer-based seals also affects chemical handling facilities and the means of transport onto which they are transferred (rail tank cars, tanker trucks, tankers, containers, etc.). 2.1.2 Fittings (general) and pressure-bearing accessories (e.g., valves) Fittings and pressure-bearing accessories in facilities that produce chemicals and pharmaceuticals are very often exposed to aggressive and corrosive media, which they have to withstand reliably and permanently in order to avoid a very high safety risk. Virtually all valves that place high demands on tightness are either made entirely of fluoropolymers, are lined with them, or at least require fluoropolymer seals in order to be effective. The discontinuation of fluoropolymer-based materials would jeopardize the very high tightness requirements of environmental law (e.g., the German Technical Instructions on Air Quality Control (TA Luft) against fugitive emissions). 2.1.3 Lined pipelines and hoses Many processes in the chemical and pharmaceutical environment place high demands (e.g., corrosion resistance) on the material to be used. In these cases, lined pipelines made of fluoropolymers (polytetrafluoroethylene (PTFE) /perfluoroalkoxy alkanes (PFA)) are used, among other things, to prevent corrosion or other reactions with the material of the pipelines or hoses and to prevent contamination in the product. In addition to these special requirements, these pipelines and packaging materials must meet the external legal leakage requirements (WGC BREF3, IED4). 1 FDA: Food and Drug Administration (USA) 2 USP: United States Pharmacopeia 3 Common Waste Gas Treatment in the Chemical Sector Best Available Techniques Reference Document 4 Industrial Emissions Directive 5 2.1.4 Membranes Membranes made of fluoropolymers are used in electrolysis processes, among other applications. Their use in the production of chlorine from sodium chloride, for example, has largely replaced the asbestos and amalgam processes in recent decades and modernized the process towards a mercury-free and less energy-intensive method of producing this important basic chemical. In the membrane process, the best available technology today due to product purity (chlorine and sodium hydroxide) and energy efficiency (BAT), the cathode and anode compartments are separated by a hydraulically impermeable, ion-conducting membrane. Under the conditions prevailing in electrolysis - strongly alkaline level and high temperatures - only fluoropolymer-based membranes are resistant. Standard practice includes the use of perfluorinated polyethylene backbones with side chains containing sulfonic acid groups and/or carboxylic acid groups (e.g., Nafion, DuPont or Flemion Asahi Glass). In the second common process for the production of chlorine, the diaphragm process, the cathode compartment is also separated from the anode compartment by a current- and cation-permeable porous partition wall. Following the replacement of asbestos, fluoropolymers, usually PTFE, are now used exclusively for this purpose. 3 Example chlorine value chain 3.1 Implications for LANXESS as a downstream user of chlorine LANXESS purchases chlorine as a raw material on a large scale from external suppliers in Europe. If suitable membranes were no longer allowed to be used in their manufacturing process in the future, production at the manufacturers in Europe could not be maintained. This would mean the loss of European chlorine production and the associated caustic soda production, and therefore, the elimination of nearly the entire value chain based on it. Furthermore, a ban on fluoropolymers would also have a direct impact on LANXESS, as the unavailability of adequate substitute materials for PTFE would prohibit us from further processing chlorine in the synthesis of intermediates and specialty chemicals. When chlorine is used, high demands are placed on the materials used in chemical conversions and downstream processes (storage, filling, transport, etc.) in terms of the resistance of piping, fittings and seals, for example, so that safety risks in the form of product leaks (risk of accidents, risk of environmental pollution) or unauthorized emissions or exceeding approved exhaust air values (TA Luft) can be minimized. As a leading manufacturer of chemical intermediates and specialty chemicals, LANXESS requires chlorine on a large scale. Chlorine is directly or indirectly involved in at least one 6 production step in approximately 50% of the entire value chain at LANXESS. In many cases, chlorine is initially introduced to a low-reactivity compound, such as toluene, and then exchanged for other functional groups further down the synthesis chain. Without the intermediate step of chlorination, the downstream products would not be directly accessible. Introducing chlorine creates the by-product of hydrogen chloride, which is largely reused as aqueous hydrochloric acid in numerous processes or marketed as a basic chemical. Several products have added value based on chlorine, including flame retardants and hydraulic fluids (phosphoric acid esters), biocide products, cresols as versatile intermediates for the production of, for example, vitamin E, specialty resins for the electronics industry, disinfectants, preservatives, antioxidants and crop protection agents. Further synthesis chains within LANXESS, starting from cresols, lead to thymol and menthol for use as fragrances and flavorings and to antioxidants for polymers. The synthesis of hydrazine hydrate for use, for example, as an active ingredient in crop protection products is also based on chlorine chemistry. The direct use of chlorine in production at LANXESS as the first step in a corresponding value chain is illustrated by the following processes: Production of chlorinated aromatics (see chapter 3.2) Production of phosphorus chlorides (See chapter 3.3) 3.2 Importance of fluoropolymer-based components in the production of chlorinated aromatics 3.2.1 Safety-relevant requirements for fluoropolymers in the manufacturing process of chlorinated aromatics At a LANXESS plant in Leverkusen, chlorine is obtained directly from a neighboring plant in the CHEMPARK and transferred through steel pipelines that are resistant to chlorine due to the properties of the raw material there (anhydrous, ambient temperature). However, at higher temperatures and under the influence of moisture and especially chloride ions, unprotected steels tend to corrode. This applies wherever hydrogen chloride is formed from chlorine in synthesis processes - both in the gas phase and in the form of liquid hydrochloric acid. In this respect, special linings/coatings are required in affected apparatus or pipelines - usually on a plastic basis, many of which are fluoropolymers. The same applies to a wide variety of seals that are used here. In LANXESS's chlorinated aromatics plant, benzene or toluene are reacted with chlorine to produce various chlorobenzenes and chlorotoluenes. The resulting products are purified by distillation and stored in tanks. The by-product is HCl gas, which is reacted with water to form hydrochloric acid. 7 During the production of the above-mentioned chlorinated aromatics from benzene or toluene by reaction with chlorine, hydrogen chloride is formed as a by-product. This is very corrosive, especially in the presence of moisture, so that normal steel or various stainless steels would be damaged over large areas or by pitting. For this reason, fluoropolymers such as PVDF (polyvinylidene difluoride) or PTFE are used extensively in LANXESS plants. In addition to linings for pipelines and fittings, this also applies to numerous seals used in the production area, e.g., in measuring and control equipment or pumps. Below are examples and applications for the individual component groups, and possible substitutes for fluoropolymers. 3.2.2 Fluoropolymer-based components used in the production of chlorinated aromatics 3.2.2.1 Pipelines The previously-referenced LANXESS production plant mainly uses fiber reinforced plastics with linings made of PVDF (polyvinylidene fluoride) as well as steel pipes lined with PTFE. In addition, these materials are also used for wastewater pipes in pipe bridges. Suitable alternatives for fluoropolymer-based components are not available. 3.2.2.2 Fittings In the aforementioned plant, for example, valves lined with PFA are used. At present, the only known alternatives are fittings made of highly corrosion-resistant nickelmolybdenum alloys such as the Hastelloy B2 type. Without fluoropolymers, this process would require expensive metallic sealing systems, which is not economically viable. 3.2.2.3 DCS devices/sensors PTFE-coated sensors are also used for measuring and control equipment in the plant, e.g., level probes and flow meters. Lined sensors are used in the operating area as well as in the acid tank farm. As an alternative to fluoropolymer-based linings, analogous to the fittings, versions of the gauges in highly corrosion-resistant nickel alloys can be used in each case, but this is associated with unreasonably high acquisition costs. 3.2.2.4 Pumps Pumps with corresponding fluoropolymer-based linings are also used in chlorinated aromatics operation. As an example, the repeatedly used magnetically coupled pump type MNK/F can be mentioned. 8 This pump contains further components and seals made of fluoropolymer-based materials. In addition, there are five comparable pumps with mechanical seals. In individual cases, zirconium oxide can inserts are mentioned as fluoropolymer substitutes, but we are not currently aware of any fully suitable alternatives. We have no empirical data on the suitability of pumps without magnetic coupling, such as graphite pumps. The same applies to ceramic or silicon pumps. 3.2.2.5 Seals In addition to the applications already described, nearly all LANXESS plants utilize a wide variety of fluoropolymer seals in the production of chlorinated aromatics and downstream products. These are currently critical for the safe, efficient and permit-compliant operation of production plants, as there are no equivalent or acceptable alternatives. 3.2.3 Impact of a ban on fluoropolymers on the production of chlorinated aromatics Easily replaceable components such as seals, which have a thermal and chemical resistance comparable to fluoropolymers, are not currently available and will not be for the foreseeable future. If inferior substitute materials were used, there would be unacceptable risks regarding plant safety or hazards of emissions to the environment that do not comply with permit requirements. Facilities would not be able to maintain the current state of the art air pollution control (TA Luft). Replacing pipes, valves or pumps coated with PFAS, for example, with technically suitable, highly corrosion-resistant alternatives would result in the installation of a large number of completely new plant components, which would be cost equivalent to building new plants. The necessary investment and maintenance costs would probably be so high that further production in Europe would no longer be economical. De facto, a ban on fluoropolymers would mean that the production of the chlorinated aromatics mentioned could no longer be continued economically or at the current state of the art. This would affect not only the production of the chlorine-based downstream products, but also the entire value chain for a large number of products and applications (see section 3.1). This would result in the relocation of chlorine chemistry and the downstream chemicals to countries outside Europe. 3.3 Importance of fluoropolymer-based components in the production of phosphorus trichloride. LANXESS operates a plant for the production of phosphorus trichloride in the gas phase process at CHEMPARK Leverkusen. Phosphorus trichloride is a basic material used in the chemical industry for the production of numerous crop protection agents, such as insecticides and herbicides, as well as pharmaceuticals, di- and trialkyl phosphites, phosphoryl chloride, 9 thiophosphoryl chloride and various flame retardants. Phosphorus derivatives play a particularly important role in crop protection. In the underlying process, phosphorus trichloride is produced directly from the elements phosphorus and chlorine in a reactor in the gas phase. The resulting gaseous crude product is passed through a column and liquefied in a condenser. The liquefied crude product is freed from impurities in a two-stage distillation process. The purified product is placed in intermediate storage and can be shipped either directly to in-plant customers via pipelines or, transported to customers via small containers (drums) or large containers (ISO tank containers and rail tank cars) for further processing. In addition to the product path, the plant has an elaborate multi-stage off-gas cleaning system (exhaust air scrubbing), in which the non-condensed vapors containing mainly phosphorus trichloride and chlorine from the various plant sections are collected and rendered harmless. Chlorine is supplied at CHEMPARK Leverkusen via an on-site pipeline through the neighboring chlorine plant. The importance of fluoropolymer-based materials in the production of chlorine has already been demonstrated in the previous section. Fluoropolymer-based sealing materials also play a central role in the handling of the other raw material, "white" phosphorus. Phosphorus is available on the world market only from Kazakhstan and Vietnam. Therefore, phosphorus is delivered as a solidified melt in ISO tank containers by rail or ship over many thousands of kilometers. When transporting phosphorus, the exclusion of atmospheric oxygen plays a central role due to its pyrophoric properties ("H250 - Catches fire spontaneously if exposed to air "). Here, seals made of PTFE have proven particularly suitable due to their temperature and chemical resistance, durability and excellent mechanical properties. On arrival at the plant, the ISO tank containers with phosphorus are connected to the transfer station on the product and exhaust air side, melted by means of steam and transferred to the storage containers by means of an overpressure process (without using a pump). Due to the high hazard potential of both phosphorus and phosphorus trichloride ("H300+H330: Fatal if swallowed or inhaled"; "EUH014: Reacts violently with water"; "EUH029: Contact with water liberates toxic gas"), both chemicals are stored exclusively in containers without bottom outlets. This necessitates the use of submersible pumps. The replacement of these pumps is very costly due to the direct contact with the media, requiring very durable, robust pumps. PTFE is found as a sealing material in various components, specifically in the housing seal and the mechanical seal, where it is a guarantor of permanent tightness even under the high stress caused by these extremely demanding media. 3.3.1 Exhaust air systems in the production of phosphor trichloride For low-emission operation of plants, permanently technically tight and low-maintenance exhaust air systems are essential. Although phosphorus trichloride itself is highly toxic in the 10 anhydrous state, it is comparatively non-corrosive to metals and other materials. In combination with water, however, hydrochloric acid is formed abruptly, which places very high demands on the materials used. In the parts of the plant that come into contact with the product, PTFE is used primarily because of its good suitability as an inert and resistant sealing material, where it is intended to prevent the ingress of atmospheric moisture and the release of phosphorus trichloride itself. In the exhaust air system, however, the waste air containing phosphorus trichloride is specifically washed with water or diluted sodium hydroxide solution in so-called washing towers and converted into hydrochloric acid and phosphorous acid with the generation of heat. Under these conditions, most metallic materials, but also plastics such as fiber reinforced plastics, PE and PP, are not permanently resistant. In this case, PTFE-lined components are the only option. In the production of phosphorus trichloride, there are several columns completely lined with PTFE, such as in the exhaust air scrubber. This is an approximately 10 m high column with an internal diameter of 300 mm, all of which is lined with a 4 mm thick PTFE lining, including the area of the column head and sump. The high chemical resistance of PTFE has provided several decades of safe, efficient use for this column. Similar requirements naturally apply to the other equipment in this part of the plant. At this point, the exhaust fan, which ensures a directed flow in the process, should be mentioned as an example. 3.3.2 Filling and transport of phosphor trichloride PTFE and other fluorine-containing polymers are also used in the final stage of the process, the filling of the product phosphor trichloride into small and large containers. The largest proportion of the product, in terms of volume, is filled in bulk containers like rail tank cars and ISO tank containers. In the course of connecting and disconnecting the lines required for the filling process, usually a product line and a line for pressure equalization of the gas phase (gas swing process), contact of the product-carrying lines with atmospheric moisture cannot be completely ruled out. Therefore, these areas can present a highly corrosive environment, similar to the conditions in the exhaust air scrubber, which is why PTFE-lined piping is used. The same applies to the connections on the containers to be filled, explained in more detail using ISO tank containers as an example. Phosphorus trichloride is delivered to customers on almost all continents. During transport, the containers are often exposed to high temperature fluctuations and adverse external conditions, making the permanent tightness of the containers critical for safe transport. Therefore, this process uses particularly high-quality fittings, which contain different types of fluoropolymers on numerous components that are particularly relevant to safety. This aspect is also evident from the elaborate preparation of the transport containers prior to filling. All seals are replaced at great expense before filling and all containers are pressure tested for leaks. 11 3.3.3 Impact of a ban on fluoropolymers on phosphorus trichloride production. The highest degree of reliability is not least also a decisive argument for many customers to purchase critical, difficult-to-handle raw materials from established European manufacturers. The selection of materials is the result of decades of experience in handling these substances. Polymers containing fluorine play a key role here. On the one hand, an abrupt ban on these materials in Europe will have a massive impact on the chemical industry based there; on the other hand, demand for the products will continue unabated. This will inevitably result in a shift of production to non-European countries, in some cases under considerably worse and potentially unsafe conditions. 3.4 Impact of a ban on fluoropolymers on plant permitting Beyond the relevance to process technology, a ban on fluoropolymer-based materials also has a significant impact on the permitting situation of many LANXESS plants in Germany and the entire European Union. For years, the competent permitting authorities have been demanding increasing concretization and specification of plant documentation, particularly in the scope of application of the German Federal Immission Control Act (BImSchG) as well as the Water Resources Act and comparable national regulations in Europe. For example, the use of PTFE as a sealing material in pipelines, fittings and apparatus for hazardous substances is explicitly described in the plant-related safety report in the application in accordance with the German BImSchG. Similar concrete descriptions can also be found in documents from the area of the Water Resources Act. The plant documentation according to 43 of the German Ordinance on Plants Handling Substances Hazardous to Water (AwSV) provides for a concrete specification of the suitable materials in the area of the primary and secondary barrier. An example of this is the water-legislative installation "Production of phosphorus trichloride in building R46"; in the corresponding chapter, PTFE is explicitly mentioned as an approved sealing material. Similar information can be found in various other plant documentation. The change of sealing materials represents a significant change to the plant, which must be approved. An impending ban on fluoropolymers therefore not only entails the risk of significantly reduced safety for operators of chemical plants, but also massive overloading of national competent permitting authorities due to a barely manageable flood of application procedures. 12 4 Special features of multiple synthesis in the batch process LANXESS operates an integrated production network at the CHEMPARK sites in Leverkusen and Dormagen, where, among other things, agrochemicals, pharmaceuticals and fine chemicals are produced on a contract manufacturing basis. The research cluster in Leverkusen works on multi-step syntheses and develops highly-efficient processes and procedures. In contrast to basic chemicals (see chapters 2 and 3), the production of fine chemicals, crop protection agents, biocides and pharmaceuticals is carried out in batch productions. Suppliers of this exclusive synthesis have a predefined plant structure, which is adapted to the respective requirements in accordance with the laboratory processing via process development and piloting in a regular production in campaign mode. In order to implement this competitively in terms of economy and safety, the following facilities are necessary: - Raw material storage (small containers, tanks, container stations, solid silos, rail tank transfer) - Dosing equipment (pumps, solids locks, manual transfers) - Reaction area (stirred tank, tubular reactor, fluidized bed, etc.) - Reconditioning and separation (stirred tank, nutsches, etc.) - Cleaning (crystallizers, distillers, dryers) - Filling (solid, liquid, former) These facilities have to be partially adapted and reconnected for each new synthesis chain. In order to offer a broad portfolio, the plant components and connections must be designed in such a way that keeps conversions during production changes to a minimum. This is made possible thanks to modern fluoropolymers, which in piping, seals, fittings, aggregates, boilers, etc. ensures chemical and thermal resistance in different productions. Batch plants are exposed to very high stress due to pressure fluctuations, temperature variations and various chemicals. Corrosion, (e.g., due to acids and alkalis or oxidative or reducing properties of the chemicals used, mechanical deformation due to pressure and temperature differences, as well as friction and manual intervention) must be considered. Today, a technically tight and safe production plant is only possible by using fluorinated polymers. New productions mean changing chemicals and mixtures, which have to be investigated from a corrosion point of view and can only be handled safely in substance-compatible plants. The numerous production changes in recent decades show that fluorinated polymers are the only known polymers in seals, for example, that are resistant, do not swell and do not require additional, potentially defective structural components (e.g., comb seals). Furthermore, they withstand higher pressures and temperatures, thus ensuring safe production, especially reducing incidents. 13 5 End-of-life management of fluoropolymer-containing components The handling of waste is comprehensively regulated by law. The producers, owners, transporters, collectors, brokers and traders of waste are subject to extensive waste legislation both in Europe and in Germany. The same applies to waste management, waste recycling, waste disposal and the transboundary shipment of waste. These legal regulations naturally also apply to waste containing PFAS. The disposal of waste containing PFAS is therefore already ensured by the existing legal regulations. One acceptable way of removing organic waste - and thus also fluoropolymers - from the recyclable material cycle is waste incineration. In the chemical industry, this is usually done in hazardous waste incinerators. In the municipal sector, waste incineration takes place in municipal waste incinerators. Regarding waste incineration, EU environmental legislation provides clear rules via the Waste Incineration BREF requirements, according to which plants must comply with the current limit values and thus the required POP destruction efficiency. Waste fluoropolymers are suitably disposed of in waste incineration plants with appropriate waste gas purification systems and in accordance with regulations without any environmental pollution or PFAS release. 6 Evaluation of substitution possibilities As explained in the previous chapters, fluoropolymer-based materials and components cannot be replaced in production plants in the chemical industry in the medium to long term. A LANXESS survey of the top 40 suppliers of fluoropolymer components, such as pumps, valves and sealing systems, revealed that there are currently no technically suitable alternatives that primarily meet component requirements for chemical, thermal and low-friction resistance and durability. Several suppliers indicated that they are evaluating or have evaluated alternatives to fluoropolymer materials, but that they have not yet been able to identify an adequate substitute material. However, even if technically suitable alternatives were available in individual cases in the future, both the testing of each individual component by the manufacturers, the amendment of relevant permits (see Chapter 3.4) and the conversion of plants and production processes would probably take more than fifteen years. 14 7 Conclusion As shown in this submission, fluoropolymers are essential for the safe and low-emission operation of plants in the chemical industry and thus for the production of a variety of critical goods (see Chapter 1). It is currently not foreseeable when and whether technically and economically suitable alternatives will be available on the market. Fluoropolymers are high-priced materials that are only used when no other material can fulfill the required combination of properties to protect production employees and facilities, as well as the environment. Replacing fluoropolymers with materials with lower performance would have a negative impact on the safety of the plants and thus on the safety of people and the environment, thus jeopardizing important sustainability goals. A comprehensive ban on fluoropolymers would mean that many plants in the EU chemical industry - and potentially further down the value chain - could no longer operate after a PFAS ban. The economic and social impact can hardly be estimated. For this reason, an unlimited exemption for fluoropolymers for industrial use is appropriate and necessary. 15