Document RJOqv2MZJM0Exy8bnqwwKwGgE
DOWNSTREAM USER QUESTIONNAIRE FOR PLASTICSEUROPE FLUORO
Background information
On 14 October 2020, as part of the EU's zero pollution and circular economy ambitions (key commi `key actions', one of which is to phase out per- and polyfluoroalkyl substances (PFAS) in the EU, unl At the time of publication of the CSS, REACH competent authorities for Denmark, Germany, the Ne at ECHA and the recent Restriction proposal submission date by the Competent Authorities of 13 Ja to collect information and arguments for potential derogations / exemptions or other changes in th about the impacts of the Restriction proposal during that public consultation, as all comments are c In anticipation of this public consultation, and of subsequent advocacy activities to communicate th prepare a socioeconomic impact assessment (SEIA) on the importance of fluoropolymers to the EU critical for the EU economy and society. To prepare the SEIA, it is important that ERM is provided with information on the substances, uses robust the data, the stronger the support of arguments that FPG can use in this PFAS Restriction Pr We therefore kindly request that you answer the questions below. Providing comprehensive respo Please send your responses to the highlighted in orange priority questions and any questions you
[1] There is as yet no definition, clarity or methodology on how to demonstrate "essential use".
Confidentiality
Note: Part of the information that is requested in this questionnaire may be business sensitive or c you consider necessary to support the confidentiality. Any confidential information provided will be suitably aggregated and anonymised prior to inclusio ERM premises. ERM operates strict and robust IT management processes globally to ensure that ou Management System (QMS). PERriMvawcyilnl boeticperocessing personal details you provide to us as part of this survey (i.e. contact person https://www.erm.com/privacy/. Scope of survey
This survey is relevant to all manufacturing and use of fluoropolymers (FP) taking place in countries which includes the 27 EU Member States in addition to Iceland, Liechtenstein and Norway. The U
[2] https://www.gov.uk/government/publications/uk-reach-rationale-for-priorities-in-2022-to-2023/rationale-for-p
Fluoropolymer definition
The draft restriction proposal on PFAS defines PFAS as: substances that contain at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon ato Fluoropolymers are polymers consisting of a polymeric fluorinated carbon backbone. Fluoropolymers are divided into two subsets: `fluoroplastics' and `fluoroelastomers'. Fluoroplastics vinylidene fluoride (VDF), chlorotrifluoroethylene (CTFE), vinyl fluoride (VF), trifluoroethylene (TrFE heptafluoropropyl trifluorovinyl ether (PPVE). In the case of copolymers, monomers that do not co ethylenes. Fluoroplastics that are produced by homo- or copolymerization of the monomers listed above inclu (PCTFE), polyvinyl fluoride (PVF), the ethylene-TFE copolymer (ETFE), the ethylene-CTFE copolymer perfluoroalkyl trifluorovinyl ether and chlorotrifluoroethylene (CPT), terpolymers of TFE, HFP and e tetrafluoroethylene with either trifluoromethyl trifluorovinyl ether (MFA) or other perfluoroalkyl tr Fluoroelastomers or `fluorocarbon elastomers' are rubbery materials based mainly on several of th hydropentafluoropropene (HPFP) and 2,3,3,3- Tetrafluoropropene (HFO-1234yf). They are produce commonly used are multi-nucleophiles (diamines, bisphenols, diisocyanates (e.g. triallyl isocyanura on many of the same monomers as those used for synthesizing fluoroplastics, the main difference b glass transition temperatures (Tg). The definitions provided above would include, but not be limited to, the following:
ECTFE: ECTFE is a copolymer of ethylene and chlorotrifluoroethylene having the formula [(CH2-CH2 pellets and as a fine powder.
EFEP: EFEP is a copolymer of ethylene, tetrafluoroethylene, and hexafluoropropylene, with the form
ETFE: ETFE is a copolymer of ethylene and tetrafluoroethylene of the formula [(CF2-CF2)x-(CH2-CH2 form.
F-TPV (fluoro thermoplastic vulcanizates): "Ready to use" fluoro thermoplastic fluoroelastomers w flexibility), and excellent processability with a melting point about 230C.
FEP: FEP resin is a copolymer of tetrafluoroethylene and hexafluoropropylene with the formula [(C pellets, powder, or as an aqueous dispersion. HTE: HTE is a copolymer of hexafluoropropylene, tetrafluoroethylene, and ethylene. HTE is melt pr
MFA: MFA is a copolymer of tetrafluoroethylene and perfluoromethylvinylether. It belongs to the g PCTFE: PCTFE is a polymer of chlorotrifluoroethylene with the formula [CF2-CFCl]n. It has a melting
PFA: PFA resins are copolymers of TFE fluorocarbon monomers containing perfluoroalkoxy side cha CPT: CPT is terpolymer of TFE, perfluoroalkyl trifluorovinyl ether and chlorotrifluoroethylene. CPT h PTFE: PTFE is a polymer consisting of recurring tetrafluoroethylene monomer units, whose formula 18 (330 C 15). Once processed, the gel point (often referred to as the melting point) is 18oF (1 manner. PVDF: PVDF is a homopolymer of vinylidene fluoride having the formula [CH2-CF2]n or a copolyme produced with (1) chlorotrifluoroethylene, (2) tetrafluoroethylene, and (3) tetrafluoroethylene and are supplied in the form of powder, pellets, and dispersions. THV: THV is a copolymer containing tetrafluoroethylene, hexafluoropropylene and vinylidenefluori aqueous dispersions.
1.1 Stakeholder details and substance ID
Organisation name
Contact person
Stakeholder details and
Q.1: Please list below products or group of products made by your company using Fluoropolymers (FP) (
Product
Field of application. (Please select one from the drop down menu or the list on the right by adding the relevant descriptor number)
Magnetic Drive Pump
Food contact materials & packaging
Mechanical Sealed Pump
Ball Valves Butterfly Valves Diaphragm Valves Sight Glasse
FP manufacturing Petroleum (oil & gas) & mining Electronics and semiconductors Transportation Industrial applications (chemical industry)
Control Valves Check Valves Sample Valves
The products are used in all industries
Stakeholder details and substance ID Contact email
Contact telephone number
g Fluoropolymers (FP) (please add rows as required). Short description of the product Centrifugal Pump to convey fluid Centrifugal Pump to convey fluid On / off Valve or control Valve for fluids On / off Valve or control Valve for fluids On / off Valve or control Valve for fluids Fitting Control Valve Fitting Valves to draw a sample for quality check
Industrial, Professional, Consumer use (or a combination thereof)?
All products are used in specific application (plants, skids, dangerous goods transportaton, ...) to convey
highly aggressive or ultra purity gases or liquids. The wetted parts (fluid contact) are made of PFA, PTFE or SSiC to protect the envirment for spills or
to fluid itself for dilution.
tries
priority question Products' field of application Use / Application
Cleaning agents, polishes and waxes (non-industrial)
Descriptor number
1
Cosmetics & personal care
2
Food contact materials & packaging
3
Construction materials and products
4
Lubricants
5
Medical devices
6
Medicinal products
7
Metal plating & manufacturing of metal products
8
FP manufacturing
9
Ski treatment (waxes)
10
TULAC (textiles, upholstery, leather, apparel and carpets)
11
Petroleum (oil & gas) & mining
12
Electronics and semiconductors
13
Energy applications, including batteries and hydrogen
14
Transportation
15
Waste & recycling
16
Consumer mixtures
17
Aerospace
18
Industrial applications (chemical industry)
19
Water and wastewater treatment
20
Other... (please describe)
21
1.2 Use mapping
1.2.1 Volumes of FP
Q.2: In what form are you using FP in your products? (e.g., resin, pellets, pre-form, fully formed artic description of the fluoropolymer product you use.
Fluoropolymer
Form
PFA
Resin
PTFE
bar, parts
FFKM
elastomere
FKM PVDF
elastomere Resin
resin, pellets, pre-form, fully formed article). Please provide a brief
Description The PFA resin is melted and injected in the mould PTFE supplier (intermediate manufacture) sinter and machine the parts according to own drawings Component connections are seale with FFKM Component connections are seale with FFKM The PFA resin is melted and injected in the mould
Q.3: Please provide information of the origin of the FP r
Substance
PFA PTFE FFKM, FKM Total
priority question
provide information of the origin of the FP relevant to your organisation (in tons).
Manufactured
Origin of substance Purchased from inside EEA Imported from outside EEA
100 to
70to
30to
10 to
10 to
0 to
0,1 to
0,1 to
110
80
30
Comment Due to Dyneon exit it will be moved to 100% ouside of EEA
1.2 Use mapping
1.2.2 Market information
Q.4: For each product or group of products containing FP, please provide information on the sales and If you do not want to provide spec ific numbers, please use a range as suggested below. - For value of sales: < 1 million, 1-5 million, 5-10 million, 10-50 million, > 50 million - For volumes sold: <1 million units, 1-5 million units, etc. / < 10 tons, 10-100, 100-1,000, 1000-5,000, >5
Volumes sold (please specify Product or group of products units; e.g. tonnes or no.
items sold)
All Products
2500 Pumps 35000 Valves
Add rows as needed...
priority question
ng FP, please provide information on the sales and market share of products relevant to FP. (For 2021) se use a range as suggested below. million, 10-50 million, > 50 million etc. / < 10 tons, 10-100, 100-1,000, 1000-5,000, >5,000 tons per year
Value of sales (in )
Estimated EEA (%)
market
share
in Estimated future trends
10-100
55%
Deindustrialization in EEA and industrial revival in US, Asia Pacific, MENA
Q.5: Please provide information on the extent that your operations are relevant to FP? Number of facilities using FP in the EEA One
hat your operations are relevant to FP?
Share of your operations (in terms of volume) relying on FP
1.3 Information on function and alternatives
Q.6a: What is the function of the FP in your products?
PFA + PTFE All products are used in specific applications (plants, skids, dangerous goods transport, ...) to convey highly aggressive or high purity gases or liquids. Wetted parts are made of PFA, PTFE or SSiC to protect the environment from contamination or to protect the liquid itself from contamination.
FFKM, FKM Elastomers are used to seal components and prevent environmental and health damage.
Q.6b: Why do you need to use FP in each of your (groups of) products? Are there certain desirable properties the FP provides to your products, and which cannot be substituted by other materials? Please describe. For example, does the material have certain technical properties or strengths that cannot be met by other materials (e.g., resistance to radiation, resilience to the conditions of sterilisation, flexibility, water resistance, etc.)
The compound between carbon and fluorine is the strongest compound in organic chemistry. Other polymers do not achieve the corrosion resistance because the chemical compound is destroyed earlier
Specific FFKM grades guarantee general corrosion resistance to seal components
Q.6c: Are there specific requirements by your customers or (regulatory or industry) specifications that FP contribute to meeting? For example, the automotive industry often has very strict technical requirements (on waterproof, heat and stress resistances) that have to be met. Are there any such customer/ industry/sector/regulatory specifications that only FP materials can meet them?
Corrosion resistance for toxic liquids up to 200C and 16bar. Maintenance of purity and avoidance of liquid contamination according to SEMI standard. Compliance with the German Clean Air Ordinance and global fugitive emissions standards for valves and flanged connections.
Corrosion resistance for toxic liquids up to 200C and 16bar. Compliance with the German Clean Air Ordinance and global fugitive emissions standards for valves and flanged connections.
priority question Q.6d: Are you producing or aware of similar / competitor products that do not use FP? Can they replace the ones that do? If not, why?
No, we would be happy to know alternatives material.
No, we would be happy to know alternatives material.
1.3 Information on function and alternatives
Q.7: What R&D efforts have you carried out (alone or in cooperation with other companies) so far to ident alternatives (literature review, laboratory trials, extensive collaborative research, etc.)? What was the outc
We are in contact with - customer from the chemical, pharmaceutical and crop science industrie. - association like Pro/K - Universities - Compoundeur If FP as corrossion protector would be replaced by email, ceramic, graphite the sealing out of PTFE, FFKM products. We hasnt found alternative materials for same application.
Q.8: Are you aware of any alternatives that may be technically and/or economically feasible for your pro Please also consider the possibility of alternative technologies, i.e., not just a replacement chemical or po When assessing the technical feasibility of the alternatives, please describe what are the critical reasons
Potential alternative
Steel & other metals
High nickel alloys
Polypropylene
PVC
Glass / Ceramics / Mica
Polyether sulphone Polyimide
EPDM rubber Nitrile rubber (NBR)
Hydrogenated NBR
Acrylic rubber Ethylene-acrylic (AEM) rubber Other (please describe)
Q.9a: What steps would be needed to test, prove and adopt an alternative in your (groups of) products? How long will such a process take? For example, do you need to follow a strict procedure, involving long feasibility testing, consultation with customers and/or suppliers and regulatory submissions?
companies) so far to identify potential FP-free etc.)? What was the outcome?
sealing out of PTFE, FFKM are missedfor robust
cally feasible for your products or product groups? Have you considered them for use in your products? If they are not suitable, why is tha placement chemical or polymer. t are the critical reasons for not being acceptable, e.g., it does not meet an essential specification.
Products or product groups examined
Technical feasibility (performance, technical characteristics, etc.)
Pumps and Valves Pumps and Valves
Issue with corrosion resistinace
Specific grades are suitable for specific application. Without PTFE and/or FFKM sealing no appropriate design possible. All sealing surfaces have to be welded.
Pumps and Valves
No, low corrosive resistance.
Pumps and Valves Pumps and Valves
No, low corrosive resistance.
Glass, email and specifc ceramic grades are suitable, but without PTFE and FFKM as sealing not possible. The freedom of design is less than to polymeres. The materials are more brittle (Risk of cracks)
Pumps and Valves Pumps and Valves Pumps and Valves Pumps and Valves Pumps and Valves Pumps and Valves Pumps and Valves
A quick google research indicates weakness in the corrosion resistance Better resistance than PVC, PP, but not sufficient to replace PFA, PTFE. Same, the sealing are FFKM or PTFE Medium corrosion resistance
Medium corrosion resistance
Medium corrosion resistance
Medium corrosion resistance
Medium corrosion resistance
Q.9b: Are there regulatory approval / certification processes that must be considered in case alternatives are to be used? What is the average / typical approval time?
priority question
r products? If they are not suitable, why is that so? ation.
Economic feasibility (cheaper, more expensive, reason)? cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available The pricing depending on the high alloy grade Pumps an Valves are in the market
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
more expensive, Ceramic pumps and valves are in the market for niche applications - corrosive and abrasive applications
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
cheaper than FP, if this were an alternative it would already be used Pumps and Valves are available
1.4 Impact assessment
1.4.1 No-derogation scenario
The draft restriction proposal states that PFAS: 1. Shall not be manufactured, used or placed on the market as substances on their own; 2. Shall not be placed on the market in [another substance, as a constituent, a mixture or an article], in a concentration of o a. 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFASs excluded from quantification) b. 250 ppb for the sum of PFASs measured as sum of targeted PFAS analysis, optionally with prior degradation of precursors c. 50 ppm for PFASs (polymeric PFASs included). If total fluorine exceeds 50 mg F/kg the manufacturer, importer or downst measured as content of either PFASs or non-PFASs.
Q.10: In a no derogation scenario, in which the restriction will apply fully, what will be the most likely response by your organisation? Please provide clear explanation on why you cannot follow a different response path (e.g., if you anticipate shutting down all EEA operations, why is this the most likely scenario as opposed to a partial shut-down?). Examples of responses can be: - Substitution of FP in your products by 20XX, resulting in X years of disrupted supply - Shutdown of certain product lines (with loss of respective sales), but continue other operations (no plant resizing or shutdowns) - Shutdown of whole plants in the EEA (which may impact products not relying on FP) - Shutdown of all operations in the EEA
- Move operations to non-EEA countries - Other?
Our sales is focusse to 100% to FP pumps and valves. If there is no alternatvie material available to support the business today German site will be shut down and move the production to US, India and/or China. The final location depends on the local PFAS restriction.
a concentration of or above: tification) adation of precursors (polymeric PFASs excluded from quantification)
importer or downstream user shall upon request provide to the enforcement authorities a proof for the fluorine
Q.11: In case of a no-derogation scenario, in which the restriction will apply fully, what will be the most likely r your customers? Examples of responses can be: - Substitution with products not using FP from inside the EEA - Supply of products from outside the EEA - If using your products as components, stop offering the specific product lines - Stop operations altogether - Other (please describe)
We assume that the full PFAS restriction will support the deindustrialization of the EEU. Global companies will their production to countries with adequate PFAS restrictions.
priority question t will be the most likely response by U. Global companies will relocate
1.4 Impact assessment
1.4.2 Economic impacts - estimates for all products using FP
Q.12a: Please describe the potential economic impacts for your company in case there is no derogation for the affected product lines.
Q.12b: Please select the range of expected losses Please rate the impact of those losses to your com being zero/very low impact and 5 being very high
> 1 million
1 5: 100% of the business
Range of profit l Rating o
Q.13a: If you were to shut down one or more facilities or production lines, would there be a decommissioning cost? If so, how much? What are the steps you will have to take to shut down the plant or a production line?
As a PfA granulate processor, we do not expect any PFAS contamination according to the current REACh regulation.
select the range of expected losses for your company. e impact of those losses to your company on a qualitative scale from 1 to 5, with 1 y low impact and 5 being very high impact?
business
Range of profit losses ( per year)
1-10 million
Rating of impact
2
3
>10 million
4
5
Q.13b: Will there be other costs for your company not mentioned above?
e.g., unrealised depreciation of equipment, losses of sales in other businesses
Q.12c: If you were to lose product sales, would this market (share) be gained by the competition and why? If so, how much of the sales would go to EEA and non-EEA competitors?
The competitor will have the same issue
Q.12d: If you were to halt production/sales, would you be able to reenter the market once you have a new FP-free product? How long would that take and how would your overall sales be affected? Are there products for which this process would be easier?
Products make up only a small part of the industrial application. If science finds a polymer that has a stronger or equivalent link to FP, it too will be restricted. The question is rather whether EU society is prepared to live with the consequences of restricting PFAS. Applying today's saftey standards with a 1950 material portfolio, the choice of goods is likely to be severely limited.
1.4 Impact assessment
1.4.3 Social and wider impacts - estimates
Q.14a: How many of your employees will be affected in case of a restriction with no derogations? If possible, break these down by area of operation (manufacturing, supporting plant operations, sales and marketing, administrative)? Total No of workers (Full-time equivalent)
200
Q.15a: Can you describe how consumers in the EEA will be affected? For example, will they be faced with higher prices or a lack of important / critical products?
The entire EMU population is affected. All industries are affected. Even artists, since paint and canvas have their origins in chemical plants. (Even FKM O-Rings will be banned..)
l be affected in case of a restriction with no derogations? If eration (manufacturing, supporting plant operations, sales and
Number of redundancies
in the EEA will be affected? er prices or a lack of important / critical products?
ll industries are affected. Even artists, since paint and canvas
priority question
Q.14b: Will it be possible to transfer workers to a different plant or production line to avoid redundancies? If not, why not?
No, hence our products 100% PFAS contains
Q.15b: Are your products or group of products performing a critical function or meeting a critical need (e.g., environmental: climate change mitigation/adaptation, circular economy, water sustainability, pollution prevention or biodiversity; human health: protection of public health) in the EEA society? If so, which one(s), and how will the society be impacted from a no-derogation restriction?
Most FP-based products have been developed to support the EU concept of high safety in the chemical industry, e.g. in chlorine and sulfate production itself and in downstream intermediates such as MNB, TDI, MDI, VCM, HF, etc. The end products are used for all critical purposes, such as environmental protection: climate change mitigation/adaptation, circular economy, water supply sustainability, pollution prevention or biodiversity; human health: public health protection. Society, governments and the military are affected by the lack of the above products, resulting in missing products and significantly reducing global power.