Document RpQ8njG2Yxj60yV01ZvpoE24z

Industrleverband Halbzeuge und Konsumprodukte aus Kunststoff e.V. pro-K StadelstraBe 10 60596 Frankfurt am Main To the kind attention of Mr. Martin Beekman -- Netherlands Dr. Mandy Lokaj -- Germany Ms. Jenny Ivarsson -- Sweden Mr. Toke Winther -- Denmark Mr. Audun Heggelund -- Norway Mr. Mark Blainey -- ECHA @rivrri.nl ChemG @baua.bund.de Jennv.Ivarsson@kemi.se @miliodir.no Mark.blainev@echa.europa.eu Subject: Reference: September 23, 2021 PTFE/Fluoropolymers used in cookware applications PFAS - Registry of restriction intentions until outcome (Rol) dated 15th July 2021 Dear Sir or Madam, pro-K Industrieverband Halbzeuge und Konsumprodukte aus Kunststoff e. V. (pro-K) represents manufacturers of semi-finished products and consumer products made of plastic. It demonstrates the application possibilities and performance properties of plastic, and actively promote the image of plastic and its products. The members of pro-K mainly focus on processing of Fluoropolymers, part manufacturing and its applications, the involvement of downstream users in PFAS process. Importance of fluoropolymers in cookware applications: Fluoropolymers are the material of choice for food contact products and they impart unparalleled performance to these articles for end users. Nonstick properties of fluoropolymers in cookware applications have many advantages such as less energy consumption during manufacturing as well as during use, less requirement of water and detergent for cleaning of cookware coated with fluoropolymers, less usage of fat during cooking, no or reduced consumption of carcinogens or harmful substances generated by blackening of food as fluoropolymer coated articles prevent sticking.* Concerns on use of fluoropolymers in cookware applications Based on our interaction with various stakeholders, we believe that main concern of regulators is the presence of PFAS in fluoropolymers (mainly PTFE) used as non-stick coating in cookware applications. Traces of PFAS may be present in fluoropolymer coating due to their use as a polymerization aid in the manufacturing of fluoropolymer. Although, according to FEC, any residual non-polymeric PFAS are eliminated in the curing step at high temperature under controlled manufacturing processes, and there will not be any significant exposure of PFAS to consumers. StadelstraBe 10 60596 Frankfurt am Main Telefon: +49 69 271 05 31 E-Mail: info@pro-kunststoff.de www.pro-kunststoff.de *2020-August-PFAS-Position-Paper.pdf (fecassociation.eu) Tragerverband des GKV )r/ -Kunststoff Wokstcff dr.11)31,1,nderts