Document Ozj1kjJRE23VzJ25zqv6yOn1M

Public comment for PFAS restriction about the high-speed interface cable 1. USB 2. Thunderbolt 3. Vertual Reality Comments Our company have been actively working to comply with chemical regulations in various countries. Furthermore, we support the ambitious efforts of the European Union (EU) to reduce risks posed by hazardous substances and have earnestly taken measures to meet the requirements of EU chemical regulations such as REACH. In addition we would like to emphasize that from an environmental and health perspective, we are fully committed to replacing PFAS in our products. However, there are no alternatives available for some applications that are essential to society. Therefore, we suggest an exemption for some essential uses. High-speed I/F cables mainly used for connecting PCs and their peripheral devices (displays, storage), etc., and for connecting VR devices such as head-mounted displays (HMD). These cables require low dielectric property, thin extrudability and flame retardance and there is no alternative material to meet these all characteristics. If these cables do not work properly, they affect to the risk that are slow down data transfer speeds, blur images, and potentially catch fire. To avoid these risks, we need to continue to use Fluorine insulation wire for high-speed I/F cable. High-speed I/F cable(USB/TBT/VR) Usage High-speed I/F cables mainly used for connecting PCs and their peripheral devices (displays, storage), etc., and for connecting VR devices such as head-mounted displays (HMD). The cable consists of a multi-core cable and uses FEP/PFA for the insulation of each coaxial line/insulated line inside. Disposal method Cable Diameter: 2.0~5.0mm Number of cores: 10C~30C High-speed I/F cables are discarded as general household waste. Estimated world PFAS use:about 216t/year Estimated EU PFAS use: about 55t/year High-speed I/F cable(USB/TBT/VR) Required material properties Reason Low dielectric Low loss tangent For achieving GHz-level high-speed transmission., and it is essential to use materials with low dielectric constant and low dielectric loss tangent. If the material properties deteriorate, the transmission performance may deteriorate and accurate image transmission may not be possible. Thin extrusion (small diameter) High-speed I/F cables are important for ease of handling, and for this reason, cable diameter reduction is required. In order to reduce the diameter, it is necessary to make each signal line thinner, and thin insulation extrusion of FEP and PFA is essential. High flame retardance Flame retardancy is a very important safety parameter, especially for high-speed transmission lines wired in equipment. It is very important to use PFA and FEP as insulating materials, which are the dominant factors that determine the flame resistance of wires. High-speed I/F cable(USB/TBT/VR) Materials PFAS FEP PFA PFAS Alternatives in the Proposed Restrictions EPDM Silicone PEEK Mica Polyvinyl Polyethyl Ceramic chloride ene Based Dielectric constant () 2.1 2.1 >2.5 >3.5 3.4 >4.5 >2.8 2.3 >4.0 Loss tangent (tan) 0.0002 0.0002 - 0.001~ 0.0035 0.02 0.01~ 0.02 0.01 0.0005 0.0005~ 0.1 0.003 Thin extrusion Good Good Poor Poor Poor Poor Poor Poor Poor Flame retardance (OI) >95 >95 30 26~32 38 - 28~38 18~19 - Fluorine is the only material that satisfies all the required properties