Document OzK2Z72d9wrog5mnd770BL26j

-- PFAS in Belgium: market study and support for the development of more sustainable alternatives --Final meeting December 7, 2023 @erdyn,fr @rdcenvironment.be @rdcenvironment.be Ref : 2023-076 Objectives Conclusions Results of the priority sectors Overview of other sectors Next steps Objectives of the study Reminder ERDYN Confidential and proprietary information ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \3 Policy recommendations - overall ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \4 Overview ERDYN Confidential and proprietary information Search of PFAS-free alternatives in a wide range of sectors Challenge to find alternatives \ PFAS properties (oil repellence, biocompatibility, durability, chemical resistance...) \ PFAS enabling combination of properties ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \5 Barriers to the development of alternatives ERDYN Confidential and proprietary information Technical and knowledge barriers Lower performance, safety concerns, skills gap for use. Competing regulations imposing other demands For example concerning global warming, EcoDesign, safety requirements. Additional costs which can be prohibitive CAPEX (installations, more complex products) or OPEX (operating costs). Uncertainty as to which PFAS will be banned When and for what applications; together with which alternatives will be brought in. Concerns over sharing of innovation results Potential market power of companies finding viable alternatives). Lack of centralisation of information / coordination Reduces flow of information as to potential solution and possible duplication of work. ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \6 3 maturity levels of PFAS substitution ERDYN Confidential and proprietary information ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \7 3 maturity levels of PFAS substitution Case A ERDYN Confidential and proprietary information Case A increasing consumer / producer information on products containing (or not) PFAS short term subsidisation to encourage users to switch system ensuring the easy availability of technical information on the alternatives for users ensuring that there is sufficient competent and trained staff to install and maintain these systems place increasing restrictions on PFAS use by way of environmental permits (up until a full ban would be implemented) ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \8 3 maturity levels of PFAS substitution Case B ERDYN Confidential and proprietary information Case B Performance restrictions/limits \ R&D can help R&D subsidies, information exchange and either/or collaborative R&D or optimising private incentives to innovate. \ R&D cannot help subsidies to encourage switching to products with quality reduction or alternative products providing a similar function without PFAS High CAPEX cost to switch \ Related to purchase/installation costs subsidies that decrease over time \ Related to R&D see performance restriction limits High OPEX cost to run the alternative solution Decreasing subsidies but trade-off with other public policies (e.g. R&D) ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \9 3 maturity levels of PFAS substitution Case C ERDYN Confidential and proprietary information Case C Long-term: R&D subsidies, information exchange and either/or collaborative R&D or optimising private incentives to innovate Short-term: support measures to reduce emissions of existing PFAS systems until they can be replaced ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 10 Overview of cases in different sectors ERDYN Confidential and proprietary information While cases A, B and C are assigned to each in the following slides, given that some (in particular medical devices and HVACR) have many different applications, this status may not apply equally to each PFAS application. Policy recommendations - by priority sector Technical textiles ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 12 Technical textiles Use, properties and alternatives ERDYN Confidential and proprietary information PFAS used for: - Personal protective equipment - Automotive textile used as seats covers - Construction materials PFAS properties - water repellence - oil repellence - chemical and fire resistance - protection against infectious risk No PFAS free alternative enabling - Oil repellence - The combination of properties listed above -Washability (and therefore reusability) ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 13 Technical textiles Barriers to PFAS substitution ERDYN Confidential and proprietary information Solution likely to come from companies developing chemicals for the textile industry (ongoing R&D for years/decades from demand for alternatives) Several issues are likely to arise when the solution is found: \ Price increases and foreclosure: potential market power following chemical company solution and patent protection (essential facility), so could : Profitably raise prices; and/or Selectively choose (or exclude) recipients of solution. \ Bringing to market: Steps for technical textiles producers to be implemented (lab testing, certification and real-life testing) In the short-term, no PFAS alternatives for personal protective equipment: \ trade-off between environmental toxicity (PFAS) and the health of the people wearing PFAS-free personal protective equipment, having lower performance. \ If a single use solution for PFAS were possible: trade-off between environmental toxicity (PFAS) and circular economy (linked to other environmental impacts). ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 14 Technical textiles - case C Context and recommendations ERDYN Confidential and proprietary information No alternatives that allow sufficient oil repellence properties are currently available. Thus, there are different policy forms which may help Short term Assess the need for personal protective equipment in a public call for tenders; and potentially adapt new requirements for certain uses (to reduce the need for PFAS in the short term) Long term Once an alternative is available from the chemicals industry subsidies for testing organising a collaborative workshop to foster the development ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 15 Policy recommendations - by priority sector HVACR (Heating, Ventilation, Air Conditioning and Refrigeration) ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 16 HVACR Overview ERDYN Confidential and proprietary information Belgian (and EU) companies are not typically involved in the production of PFAS for HVACR but are rather involved in the use of PFAS in final or intermediate products Many different applications of PFAS Focus on gases in the study PFAS also used in other parts of the equipment (including PFAS polymers) ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 17 HVACR Applications and most important properties Hydraulic heat pumps Reversible static air conditioning + heating Mobile air conditioning Commercial Refrigeration + integrated heating in shops Industrial Refrigeration Waste heat recovery Foam blowing agents Sealings Compressors ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting ERDYN Confidential and proprietary information Properties \ the precision of temperature control \ range of temperatures \ life span \ low energy consumption \ consequences on the pressure of the circuit \ low flammability \ heat capacity (energy per unit of mass) \ low GWP (Global Warming Potential) P \ 18 HVACR Possible alternative products Carbon dioxide (CO2) Water Ammonia (NH3) PFAS alternative Hydrocarbons F gases without PFAS Air ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting ERDYN Confidential and proprietary information P \ 19 HVACR Heating, Ventilation, Air Conditioning and Refrigeration Alternative Performance ERDYN Confidential and proprietary information Likely uses Costs Ammonia Hydrocarbons Water Carbon dioxide F gases without PFAS elevated aquatic toxicity higher fire risk industrial applications an elevated flammability and explosion risk large chemical industrial sites currently limited temperature range appealing CO2 flammability and toxicity properties potential issue related to pressure requirements and temperature resistance requires compressors operating under vacuum which requires R&D - Used in water heat pumps refrigeration combination with ammonia for even lower temperatures, although it may not be suitable for certain applications likely to be banned with the F-Gas regulation domestic water heating in some cases similar uses to PFAS in terms of range very high GWP ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting higher CAPEX higher OPEX skills gap higher CAPEX higher OPEX skills gap Uncertain higher CAPEX skills gap P \ 20 HVACR Barriers to PFAS substitution Barriers \ Technical barriers \ Increased CAPEX or OPEX linked to the alternative \ Lack of technical capacity to implement alternatives \ Uncertainty as to what substance will be banned and when Eco-Design directive / energy efficiency ERDYN Confidential and proprietary information F gas regulation / Low GWP Safety Carbon Neutrality Circular Economy ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 21 HVACR - Case B Context and recommendations Some sub-applications have PFAS-free alternatives ERDYN Confidential and proprietary information Others do not or entail significant cost increases or performance drops/safety risks CAPEX and R&D subsidies (including modulation of existing ones) Collaboration with city planning Stimulation of collaborative R&D/private incentives to innovate Ensuring the presence of skilled workers who can install and maintain PFAS alternatives Establishment of prioritisation lists of desirable alternatives ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 22 Policy recommendations - by priority sector Medical devices ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 23 Medical devices Applications and relevant PFAS properties PFAS used in various medical devices to enhance patient safety and comfort \ Fluorinated gases: used in anaesthetic gases and refrigeration \ Polymeric PFAS (fluoropolymers): used in implants, syringes, tubing... \ Monomeric PFAS: used in a variety of medical devices including contact lenses. Biocompatibility Heat resistance ERDYN Confidential and proprietary information Chemical resistance Durability Oxygen permeability Lubrication Thermodynamic properties Deposit resistance ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 24 Medical devices Barriers to PFAS substitution ERDYN Confidential and proprietary information Performance of alternatives for medical devices Lack of consensus on viable alternatives Strict regulatory standards Uncertainty regarding passing regulatory approval and long delay to do so Segmented and sometimes small markets ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 25 Medical devices - Case C (1/2) Context PFAS are still being discovered in some parts of the supply chain ERDYN Confidential and proprietary information General lack of knowledge of potential viable alternatives at this stage Lack of significant collaborative research/information sharing Large number of applications no clear path at this stage of which applications or potential alternatives to stimulate Some applications where the solution will be relatively straightforward Others where it will be difficult ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 26 Medical devices - Case C (2/2) Recommendations ERDYN Confidential and proprietary information R&D subsidies Stimulation of collaborative R&D Private incentives to innovate Establishment of prioritisation lists of alternatives with groups of applications ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 27 Overview of other sectors ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 28 Overview of other sectors ERDYN Confidential and proprietary information Sector Batteries Case B Cables Case B & C Fire protection Case B Key point on PFAS use in Belgium - Approximatively 10 companies are likely to use PTFE and PVDF to produce materials and components of batteries in Belgium. - Debates about alternatives are only emerging and PFAS-free membranes, separators are under investigation. Specific recommendation - R&D subsidies, information exchange and either/or collaborative R&D or optimising private incentives to innovate. - PFAS mainly consist in fluoropolymers, a volume of 40 t/y have been extrapolated for Belgium. - Different alternatives have already been tested (PEEK, PC, EPDM), with currently no technically feasible alternatives for all cables. - R&D subsidies, information exchange and either/or collaborative R&D or optimising private incentives to innovate. - Provide subsidies that decrease over time to encourage substitution - Fire suppressants & firefighting foams are a well-known stream of PFAS pollution, subject to specific regulation. - PFAS play a key role and the use of less performing chemistry leads to other environmental and health issues. - CO2, hydrocarbon, siloxanes are among the best alternatives, some of them are developped in Belgium - R&D subsidies, information exchange and either/or collaborative R&D or optimising private incentives to innovate. - Provide subsidies that decrease over time to encourage substitution ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 29 Overview of other sectors ERDYN Confidential and proprietary information Sector Metal processing Case B Paints & Coatings Case A Paper & Cardboard Case A Key point on PFAS use in Belgium - Industrials widely use 6:2FTS in hard chrome plating (1-2t/y) for the automotive, aeronautic or firearm markets. - Industrials are already facing challenge with the Cr(VI)-based process and seems unaware of the PFAS use. - Various strategies have been adopted for substituting PFAS: other chemistry, plating, process... - According to IVP Coatings, PFAS-containing paints & coatings may represent up to 10% of the Belgian market (i.e., 200 million). - Industrial & transportation protective coatings are the main application of PFAS (FPs, 300t/y). - Epoxy, PU or silica-based coating already have high market share - PFAS are not essential; and widely accepted alternatives already exist, no evidence and limit hint of PFAS use in Belgium have been found. - PFAS are mainly introduced via import, increased recycling leads to spreading PFAS throughout all the paper and board market. ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting Specific recommendation - Focus on the development of alternatives that are both Cr(VI)-free and PFAS-free - Increase producer information levels - R&D subsidies - Increase consumer information levels - Ensure technical guidance for substitution - Place increasing restriction on PFAS - Gain knowledge on PFAS content of import product - Gain knowledge on PFAS incorporation during the end-of-life management P \ 30 Overview of other sectors ERDYN Confidential and proprietary information Sector Pesticides Case B Plastics Case A & B Semiconductors Case B Developpement of alternatives - Belgium is one of the largest consumers (7 kg/ha) and producers (10% of the EU industry) of pesticides in Europe, suggesting high PFAS use (529 t/y) - The subject of PFAS used as active substance in the manufacture of PPP is widely unknown in Europe & Belgium - There is very limited work on PFAS alternatives. - Numerous PFAS-free polymerisation aids and polymer processing aids are already commercialized and used, none of them have been developed by Belgian actors. - FPs-free sealings appear to be extra-challenging: PEEK, PPS PPA, ACM or nitrile rubber do not fulfil all requirements, and would lead to higher leakage risk and maintenance cost. Specific recommendation - Increase consumer/producer information levels - Encourage overall reduction of PPP Aids: place increasing restrictions on PFAS use Focus the help on the downstream actors of the value chain (R&D & substitution subsidies) - FPs and PFBS are used in highly diverse applications. However, the Belgian share of the EU industry only represent 1.5% (i.e., 66t/y PFAS used). - For a limited set of applications, HDPE, mineral oils or NF3, are potential alternatives. - Some companies do not share information on alternatives because of possible competition ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting No specific recommendation, see all Case B recommendations P \ 31 Next steps ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 32 Next steps ERDYN Confidential and proprietary information Deadline for comments on the final draft report: 14/12/23? Translation of the executive summary ERDYN-RDC \ 07.12.2023 \ PFAS in Belgium - Final meeting P \ 33  r %IP 0 Thank you for your attention tRDC: