Document Ozan9p4mkxvo2m0EEqG9rOVYj

PFAS RESTRICTION PROPOSAL IMPACT ON THE AUTOMOTIVE INDUSTRY FPP4EU = |] aced WHO WE REPRESENT www.acea.auto 2 "LEONE > Piobr -- yroT eEeaaEeiNe | deh la e | E SR E EESE NEaNy 2 a AE EN EER Ne Tamms From This To this - = =I --u : -SEE.. - Noderogations for vehicles means no new vehicles on the market in the near future Existing vehicles could not be repaired as spare parts are also impacted  These include guaranteed vehicle safety, reliability under large temperature fluctuations, flame retardancy and high durability over the whole lifecycle of 15 to 22 years! PFAS and mainly fluoropolymers are deployed in all these key roles because of their unique special properties. Without the capability of these unique properties, both existing vehicles and future automotive technologies would be inconceivable. MAKES IT A HUGE CHALLENGE TO MAKE THE PANAROMA WITH AN OUTCOME THAT THE ENTIRE VEHICLE IS IMPACTED semi-conductors, sensors, PCB, display, passive components, poly-switches, cables & connectors, binder for electrods, Separator membrane coat, sealings, edge coating on electrods, electrolyt Proton exchange membrane, electrods, humidifier membrane, H2 sensor Lines and hoses, sealing systems (static and dynamic), gaskets, membranes (valves, sensors) oil, grease, bearing, bushing, guides, ball-joints, control cables screws, nuts, clips, ... Process additive..... REQUIRES ORGANISING PER SUBDOMAIN = 5 Lb Gouiwvimo lA CeER he: G= reen| Tes =2 UNP DN S edN Ra " AGEN SY @ee tnd Ta PWgPF. P trn em wy OA )pvHioegh prerfoormmancae lunbriccantse. riams| $2 NON EXHAUSTIVE LIST The wide variety of impacted applications will make dessubisgtnitution very complex and will affect the entire Most vehicle designs take about 3 to 5 years to move farnodmpirnoitviealn ctecohnnoltocogyfeiinsp iasvhtaeidlacabrlei=f mmeaatnuirneg maaltteerrinaatliv~e~ | substances. Lo ra a " TM| 4~ = || = Py iiyb y To modify existing cars takes even a coupleofyears. longer Today, for most impacted applications there are no technically mature alternatives available, design can not even start. 8 AEJ) LP / . -- A J . SiO A Unless we bring vehic3 les buck rom the S tr 1Scrt tt te ADEQUATE LEAD TIME FOR SUBSTITUTION WILL BE OF ESSENCE Ee ee, ES EZ. step 1 Aernatves ||step2Prototyping Fiewo, NNER | wfoirlalbleaapnpliimcamteinonsse ||||+Ailntceorrnpaotriavteeswdiilnl be i Ak | fea impacted parts N wiF t Hd = Ret+= || + Aaltberlnaetivienssumfufsictiebnet|||| =Thbeesteesptaerdtasnndeheadvteo quantity acceptable|| to pass for durability, cquoamlpiettyiatnidve price qsualaityf.andeovterayll ocroimgipnaarlemdatteortiah,e | + Tahbeonutwaescuiatnabtallek alternative Bdoetfhinsitnegpsadaerqeuiamtpeorttiamnetfofror substitution, as the proposal only looks at step 1 EVEN ELECTRIFICATION IS AT STAKE emans trainer] teSnTaAnNt dope _-- "OSA ARAL sue earn sven vem eens vases an - an a5 a a = a " - an a a Recent years have seen exponential growth in the sale of electric vehicles The key technologies used to decarbonise road transport, improve range, and increased performance are hfiiguholryopdoelpyemnedris.ng on PFAS, specially Transformation to a full electric vehicle fleet can not - a - a be achieved by 2035 with the current restriction proposal Ea 0 TO REFLECT UPON \i [The current prs restriction | aPurtoopmoostailvseniantdumsatnraygeable for the >Nmoarnkeetw vehicles could enter the >rCeuprariernetdvehicles cannot be > Atrahnusgiteiocnhamlolbeinlgietyfor green ; A = +ACEA fully shares the desire to rinedduuscteryt.he uses of PFAS in our + A balanced restriction will be cirnudcuisatlrfyorttshgeraeuetnotmroatnsiivteion and its end users. Two dossiers submitted during the public consultation (May and Sept) with known uses and current knowledge on alternatives WHAT COULD BE A SOLUTION Need for segmentation of the PFAS family A reduction of scope excluding non-hazardous PFAS such fluoropolymers and fluoroelastomers is required. This would help to focus first on priority issues for which urgent action is needed, thus bringing a rational, efficient and methodological approach to the discussions. Addition of derogations Application of a derogation for vehicles is crucial. This prevents that vehicles and millions of existing sub components that are already legally approved would have to be completely re-designed, retested and re-approved. Adequate lead time for searching alternatives and the need for review clause. Adequate lead times where no alternatives are in place need to be respected together with implementing a revision clause to evaluate the progress after several years. The repair-as-produced principle shall be applied. We believe the restriction should also not apply to spare parts produced after the rules enter into force. Parts should be repaired or replaced in line with the `repair as produced' principle in order not to contradict the overall strategic goals of the circular economy ABOUT THE EU AUTO INDUSTRY 13.0 million Europeans work in the automotive sector 11.5% of all manufacturing jobs in the EU 374.6 billion in tax revenue for European governments 101.9 billion trade surplus for the European Union Over 7% of EU GDP generated by the auto industry 59.1 billion in R&D spending annually, 31% of EU total www.acea.auto 14 J) REPRESENTS EUROPE'S 14 MAJOR CAR, VAN, TRUCK AND BUS MANUFACTURERS epee [TS European Automobile. Manufacturers' Association [I [EE [] lL [YT -- [ee