Document VKjDxgkxg8gDEr95v22LM9vVZ

AXOR ANALYSIS OF ALTERNATIVES SOCIO-ECONOMIC ANALYSIS CHEMICAL SAFETY REPORT Provided as Comments to the Public Consultation on the REACH Restriction Proposal on Per- and Polyfluoroalkyl Substances (PFAS) Public Version Submitted by: Date: Substance: Hansgrohe SE AvestraBe 5.9 77761 Schiltach 22.09.2023 Per-and polyfluoroalkyl substances (PFAS] AXOR TABLE OF CONTENT Declare Uist ofABBIOVHONS...... cs -------- on crmss---------- To IOOUCHON -- wn mmm-- 2. AncolfAyllrsnaiivess. m-- RATT W. | 2.1. Explanation ofanelectroplatingplantforthecoatingofsanitaryengineering products. . . . . 2 22. Electroplating............ sn---- ------ h.- 22.1. Input moterials for eloctoploling plonis.............. -- mm 222. Condlusion....... n------ TR amon 2.3. Useof materiols containing PFAS inthe electroplating plor......... Remo 2.4. Potential Alternatives. Em sm---- -- 3. SocioEconomic Anclyss........... wssem-- somo 3.1. PFASbanscenario. swns-- sa wo? 32. Anclysisof pot... sn " mR--0 3.2.1. Impact brass electroplating plant and production line based in Schitach wns} 322. Impact onthe Offenburg plastic etching and elocioplating PION... n 323. Imonpassaembcly t lnes..... wi ws warns}} 32.4. ImopnHaanscgrothe workers in the EEA...... sosm---- wri} 3.25. Imponarcegiton Schiltach, Offenburg, Wasselonne........ ---- gonnneltl 33. Summary... s---- TT snl 4. ChemicalSclely REPO... s---- ww 40 Monufachting......ce n---- aml 42. UsePhase... --A nnd 43. EndofIfe sage. wi TA -- er 5. References... s-- smn VG VHooiwsee,rCAinaocnGoStonSoHs87e40o79A+eUWSe.hbeGE YTT7eEITt25 o+sYAoriksHaoKigs oKdoa nda, fk orig Foor AXOR FORREIEIE Justification for confidentiality claims Demonstration of Commercial Interest 1. Internal business information is included in the document which is concerning material consumptions, technologies and development and thus should be held away from competitors, therefore it shall be marked as confidential. 2. Internal economic information related to turnover, production costs, expected losses and implementation costs is confidential business information being part of the commercial strategies of Hansgrohe SE ("Hansgrohe"). This financial and commercial information meets all of the following requirements: (a) it is notpublicly availableor readily accessible ctoonsatnityubtoesdyaneexccoenptamiHcanasssgertoohfe'Handsegcrioshieo.n makers (b] it has commercial valve and Demonstration of Potential Harm 1. Should it be shared with competitors, this disclosure could prejudice the competitive position of Hansgrohe in the conduct of their business. Information could be used by competitors, in conjunction with what is already known, to advance their position in the marketplace. Competitors would benefit from the knowledge on the alternatives and also from the ones that failed in testing. 2. Disclosureof this information could prejudice the competitive position of Hansgrohe in the conduct of their business. Indeed, information on the production costs and future expenses/efforts to maintain production in Europe can be used by competitors in conjunction with what was already known, 1o advance their position in the marketplace. tThheiisr cmoaurlkdetoveproasiltliohnave a negative impact on Hansgrohe's competitiveness and endanger Limitation to Validity of Confidentiality 1. As a consequence, these data should be protected indefinitely os confidential business information. 2. Information like investments required to implement alternative technologies or development of manufacturing costs after implementation of alternative technologies will not significantly change in future. Consequently, all data shall be protected indefinitely as confidential business information. Vee Comin Got soi bi bet vee oe AXOR CLEFT Overall, in the submitted document Hansgrohe provides dept information on its financial position in the marke, as well as on core dota about fs products and production technologies. This information, which is blanked out in the "public version", cannot be made available to the public, as it would result in substantial competitive disadvantages for Hansgrohe. Hansgrohe SE poe - Thorsten Pohl Vice President Technical Engineering & Technology iv. Christoph Heizmann ManagerTechnical basics and applications V SSoarreosd,5e+CrieAtcrgboheGoS5tuhS7K7B61v7h47b75Aob=+tSGWhairenmkan6<1VBY4o73S7rL0T3aE5S51 0Vt+orr18.o07ne8s3o8sn3s1 o15S3ol0-oob Nobrnes orroknSonhg oBreenry AXOR LIST OF ABBREVIATIONS eB ECHA EEA Efe ess Fp KM 3 HaPFOS HGB HSE OECD PEHD PFA PEAS ee PVC PTFE PVDF PVDF.coHFP RAC R&D 505 SEAC SVHC Earnings before infest ond foxes European chemicals agency European economic area Eihylene felofivoroethylene Easy Sanity Solutions Flvorinated ethylene propylene Fluorine rubber material Flvorpolymer 62 fluorotelomer sulfonate German Commercial Code Brish Health and Sofety Executive Organisation for Economic Cooperation and Development Polyethylene high densi Perflvoroalkoxy alkanes Per-and polyfluoroalkyl substances Polypropylene Polyvinyl chloride: Polytetrofivoroathylene Polyvinyiidene fluoride Polyinylidenfivord-cohexafluorpropylen) The Comittee for Risk Assessment Research & Development Sodium dodecyl slfole Comite for Socio-economic Analysis Substances of very high concern ToyotaSE +Awa $9 +77761Soho +Geary + +437838 510+ +437836511300 + ohompategrorpcon + orgegormion re cn Got od te,eb ttn ome nme ear, Wel. Font Serr Shred AXOR CORED The present document is part of the submissions of Hansgrohe for the public consultation on the PFAS restriction proposal. This document solely has its focus on the use of fluoropolymers (FPs) in electroplating plants for high quality chrome plated components for sanitary products. Noneof the herein discussed FPs remains in the finished products, but is necessary for the safe operation of an electroplating plant. Hansgrohe operates three electroplating plants in Germany. One fully automated and one manual electroplating plant for brass parts in Schillach and another electroplating plant for plastic parts in Offenburg. A third plant is in operation in China and a fourth electroplating plant is currently under construction in Serbia. FP are high-performance materials with exceptional properties, such as chemical resistance, thermal stability, fouling resistance, material flexibility and anti-friction / gliding properties. There is no other available material that combines this wide range of functions and therefore 00 suitable alternatives exist af this fime for various use-case scenarios. Many fluoropolymers have been scienifically evaluated as "polymers of low concern (PTFE, ETFE, FEP, PFA, PVDF and PVDF-coHFP). They have been proven fo be chemically stable, non toxic, nonbioavailable, non-water soluble ond nonmobile. For these reasons, the fluoropolymers are also approved, for example, as food contact materials or in medical devices, including the use as implants. In addition, Henry et al. state that all flvoropolymers should be considered "polymers of low concern". Cross reference / Additional information As an important side note, it should be notedthat someFPsare alsodirectly sed in Hansgrohe products. A detailed statement on this subject was submitted in bundled form via the German *figawa e.V." association, together with other association members in cluster 2 [water supply). Consequences of a ban on fluoropolymers for the operationof electroplating plants A wide range of chemical substances are used in electroplating plants. Without the use of high-performance plastics, such as high-performance fluoroelastomers, PTFE, PVDF, etc., the safe operation of electroplating or chemical plants would no longer be possible. Possible substitutions must be carefully weighed up and checked in terms of operational safety when operating the plants. The replacement or the conversion fo less dangerous process chemicals would no longer be possible, which would ultimately result in the decommissioning of the existing plants in the EEA. Such decommissioning would be associated, among other things, with the dismissal of direct and indirect employees. Von,CoosGoiotneb ot Vor SR en Hk Se kr AOR COCR Request: Exempt fluoropolymers from restriction projects Hansgrohe considered therefore "polymers calls for the general exclusion of fluoropolymers, which of low concern" according to the OECD definition," from are the also PAS restriction project. In addition, manufacture substances such and production sashoumlodnobmeeresxeamnpdtepdrofcreosmsinthge abiadns,repqruoivrieddedfotrhaHtuosraofepoulsyemeirs Tenhseurreefdo.re,Thgirsoiuspsalwsiotehnvlioswagriesdk (bey.gt.heflsutourdoyeolfasttohmeeBrrsi,tifshluHoeraolptohlyamnedrs,SaefveatlyuEaxteecdutoisve"p(oHlSyEm)e.r"s! of be low concern') excluded or use-cases without relevant risk (e.g. in closed systems), should generally T HVoarno bd,5aarAssrpo cohoniSonu,7r7n78i61b7Sc4h3h7,a73AdtGSWHer.b0T78VV8/eV3Sr731o35bo1AV0o4dr9e:7n4i30o3nft7s1o3K9leoesbNoorsne.earyosnSregeeennes AXOR 1. INTRODUCTION Hansgrohe is showers, and a German manufacturer similar sanitary products of high-quality sanitary products such as ~ focusing on applications for bathrooms, faucets, showers, and kitchens. Products manufactured by Hansgrohe are known worldwide for their high quality and serve as an important high-functional design element for the sanitary industry. In Germany, there are production sites in Offenburg ond Schiltach, the latter is also the headquartersof the Hansgrohe Group. fairs ond exhibitions departments, Our Innovation as well as the Park in Alpirsbach prototyping and is home rapid to the trade prototyping departments. Shower hoses are produced in Willstatt near Offenburg. Shower channels are produced in Bad Bentheim with Easy Sanitary Solutions (ESS). There are international production sites located in France (Wasselonnel, in the USA (Atlanta) ond in China (Shanghai). Another production sie is currently being built in Valievo, Serbia. With 33 subsidiaries and Hansgrohe, as a globally 20 sales offices supplying products in active company in the sanitary industry, more than 152 countries, is a reliable partner for its customers in all regions of the world. In the manufacture of sanitary durability of the product or to products, guarantee various coating this during use. methods are The galvanic sed to coating ensure the of sanitary products fulfills both a functional and decorative aspect, such as abrasion resistance, resistance customers to cleaning and disinfectant agents, expect, also plays an important role ease of care, ofc. in the purchase The decorative process aspect, which It is important to note that Hansgrohe is neither a manufacturer of per- and polyfluoroalkyl substances (PFAS) nor electroplating plants, of fluoropolymer (FP) which are assembled row from materials. Hansgrohe oporotes many components. Hansgrohe customized is therefore not directly involved in the development process of PFAS.free alternative materials for electroplating plants, which need to fulfill the complex physicochemical requirements for a safe operation of such plants. TVHaoyridrire5e:CvAhamoipissGoSk5u,gS7Wd7A8S1e74Ss57o79Ae +GUSWayh01819Y27r8727s258o+s3VAaFnd8d1i.4o35H7o8rms31ng3te10sP13K0e0 le oteregineg oboorSeTieopbeern AOR EIR 2.1. Explanation of an electroplating plant for the coating of sanitary engineering products In the manufacture of sanitary products, o wide variety of coating methods are used fo establish the durability of the product or to ensure this during use. The galvanic coating of sanitary products fulfills both a functional and a decorative aspect, such as abrasion resistance, resistance to cleaning ogents and disinfectants, ease of maintenance, important role eifnc.theThpeurcdheacsoeraptriovceesasspect, which customers expect, plays an additional The following brief explanation will specifically address the need for using high-performance fluoroelastomers or high-performance plastics in an electroplating plant. 2.2. Electroplating The surfaces produced in the sanitary sector from electroplating are metal surfaces deposited in individual and also very special electrolytes. The plating process consist of chemical as well as electrochemical steps. As a rule, electroplating is divided into several steps, starting with pretreatment, followed by between 2 and 3 metallic layers until the product is finished. Individual rinsing cycles with different rinsing systems complete the process. The methodology depends on the specific substrate to be plated. Generally, electroplating can be operated manually or fully automatically. Electroplating is a precisely coordinated and highly complex system between software, electronics, electrical engineering, safety engineering, process tanks and the actual analytically monitored chemical process. The process chemistry is located in special plastic containers made of PP, PVC, PE-HD or PVDF, the actuol chemistry used determines the correct material of the container. Metal tanks are mainly used in the area of pre-cleaning of the workpieces, here also the material of the tank depends on the chemistry used. 5Th0e10taonvkserar7e0 bpuirlotceinsssetrainekssaccording to the specified process sequence and can range from Asa rule, before the constructionofan electroplating plant, all input materials, mainly plastics, are determined according lo the resistance per chemistry used. In order to ensure o stable process, the electroplating requires a lot of peripheral aggregates such as valves[of different types), filters, pumps, electrolyte movements, etc. These aggregates are exactly matched to the process chemistry, just like the plastics of the process tanks. The ners AXOR FI main components are mainly sealing materials made of highly resistant plastics such as FKM, PVDF, etc. Without these materials the operation of an electroplating plant would not be possible. Sealing materials such as FKM are high performance fluoroelastomers, which show a wide acidic, temperature spectrum as well as oxidative and highly concentrated chemical resistance. chemicals PVDF is used for particularly 2.2.1. Input materials for electroplating plants A large number of chemical substances distinction is made between inorganic and are used in electroplating. organic chemicals. In electroplating, a Examples of inorganic chemicals are nitric acid, sulfuric acid, hydrochloric acid, caustic soda, fblouroartiedea-nbdasseidliccahteemiccoamlpso,unmdest,aletsca.lts (copper sulfate, nickel sulfate, nickel chloride, etc. } Organic chemicals are mainly the additives, these produce, for example, a homogeneous surface during deposition, os well as the resistance and texture. Organic compounds are e.g. benzene, naphthalene and alkyl sulfonic acids, sulfonamides and imides as primary additives. In parallel, secondary organic compounds are also used, such as coumarin, butandiol, etc. In copper electrolytes, for example, polyethylene glycol derivatives are used as brighteners, and sulfur-containing organic compounds with high surface affinity are used as brighteners. In addition, wetting agents are employed to improve thesurface wettofathbe miatelriails twhiych are plated. Here, PFAS containing (e.g. 6:2 fluorotelomer sulfonate (H4-PFOS)), as well as PFAS-free welling agents (e.g. sodium dodecyl sulfate (SDS)) are available. It should be stressed out, that Hansgrohe has been working on the substitution of PFAS-free wetting agents since 2019 and will implement this soon (see also chapter 4) Depending on the electrolyte or treatment step, these substances (inorganic and organic) are used in different pH ranges from strongly acidic to highly olkaline and in different concentrations. Temperatures various treatment steps. between room temperature and 80 C are required for the 2.22. Conclusion Without the use of high-performance plastics such as the above-mentioned high-performance fluoroelastomers, PVDF, etc. the safe operationofelectroplating or chemical plants would no longer be possible. Possible substitutions must be carefully weighed up and examined from the point of view of operational safety when operating the plants. 2.3. Use of materials containing PFAS in the electroplating plant As described in section 2.2, the material requirements for the components installed in the electroplating system are very high due to the chemistry used, as these must ensure the safe operation of the system. operation is not possible Without the use of these resistant fluoropolymers, electroplating VVoeng,iCAhnggerGovStuntSo1ta74Ke0,79el+tSWheet5 8V1 3e73n5 + tAiodonosKenneKtoebo Noms, Fok Soi terri A x Oo R ansgrohe Table 1 system. provides an overview of which FPs are commonly used in a typical electroplating Table 1: Nonexhaustive overview on relevant Fs and their field of application in electroplating plants. [ Valve technology, [roe]Process fank Decaptate piping Valve technology, Preparation tank Decopitate piping Valve technology, piping Resharpening lank Decapitate Valve technology, piping Valve technology, piing Process tank Drain tank Bright Ni Valve technology, Vpaiplivnegtechnology, pViaplinegtechnology, = Chromium Chromium piping Valve technology, CuNistrip piping Valve technology, Cu Nistrip piping Valve technology, piping Valve technology, piping Resharpening tank Cu activation Cu aciivation Valve technology, ping Valve technology, piping Valve technology, piping Process tank Drain tank Solvent fank, Acidic Cu `Acidic Co `Acidic Cu [Pute[Seyongvae Valv ehrleay TVaarenreoEs+CAAonmteeCoSuto9tS7100o S787s7i +diGUaeen rk.eyaOTF 3oT7n0Y7t350 d+ otn eTA Kr5eno0iemo n erieoTrag ernr roists AX\ OR EER [trie Buttery valve Jo[ni Grin Sealing Valve technology CuNistrip Aecoivnoted carbon, Filration Sigh Ni pr |Activated carbon Sealing Chromium [MPoowserse: [[SSeaolningg [[MF--ievoasi--roarm[sn Co[singhtis ap|| [[ovmser [S[ooMngacsronant[Ghomiom| [fovrser [Seog [Mecsronen _[GiNiwp | a:TcON [Fownser [Sod [Wecsroren [Goataion | Cofnlrdsaloon [Sockg [Flaten [Dueopiote | a SJ y r [oPaoltovfolohrodion [[SSooodnngg [[FVoillvetrdnoogy ||CShoovraidom || [orsconmoer [Sod |Crelofondooge [Geno | [erbrogme [Seong [Veetedeclony [Seve | [orbmvahe [Soong [Flerardfonps [Sod [[cterchonger [Sods Bog fier sation [Poof olor [Seclog Valvelednlogy [Sov | [F_hat_on__[Seved| [Feng/Coorg [Severe | Ulirasonication, [Flaten |Fpown | degreasing PTFE Plugin resistance Thermometer Several thermometer [(oolrodpabe [Soolog [Macarena [Seve | [Pesb[Sorongogm|Fpampuingencclpogy [sI esing--[Sedil ng [seoing L [sows | I AXOR FIRE UV disinfection [Bollvalve Case [Ses Cleaning Several [Valvetechnology [Several | woter Both heat exchange [Heolexchangers [Healing/Cooling Agalor [Congagiotor_[Uphooval [Several [several | | Dosage [Scrowinfiting [FioseComecion [Several | PVDF/ | Dosing valve FM Vo/lSevalieng PVD/F Level switch Level switch / FKM sealing Dosing pumps, flow |Component, meters, metering | sealing valves PVDF, PTFE, FKM | t[oSposl,eneoticd. valves, cow |Dosage. Valve technology Valve technology Several Several 2.4. Potential Alternatives Due to the chemicals used in electroplating plants, there are currently no suitable alternative materials that cover all process steps, as these would need to meet the special requirements etocowniothmsitcanbdutolallpsrooscaefseslychsepmeicctalsspilnauysoeninitmhpeordtiafnfterreonltepirnoctehessseslteepcst.ioInn this context, of materials. not only Due to its high costs, FPs are already only used in cases where other materials fail. As such, the amount of FP-containing materials in an electroplating plant has already been reduced to an absolute minimum. In Table 2, several electroplating process steps are listed, together with the main process chemicals, as well as pH values of the process solutions. For the FPs in use in these processes, there are currently no alternative FP-free materials available on the market. It must be stressed at this point, that all potentially developed alternatives in the future have to be tried and validated to ensure the applicability in praxis. This validation has to be done in cooperation with the electroplating plant manufacturers and can only start, once such materials are available for purchasing on the market. Tderemee p$+ Veer, eAcorgccehSubg37786714S07adsg Got in 4SGWheaekr,rOyCT8V1197o77287s130531+ 0Ve7d0o7n7a8R0e5o1se3K0ei0mdbr o owehse,geo Fyokbo obroeim -- AXSeOR Een eTmapblloey2e:dNPounsexfheaoussbtliev.e overview of electroplating process steps, for which currently no substitution of the 5 Cu Ni strip Decapicte Acidic Cu Eching Chromium (hexavalent based) ak 1 None,duefo the high oxidative and acidic environment Suricodd | <3 | FKM |None, due tothe hgh oxidative ond acidic environment CuSO, H:SO,, NaCl, methanol None, due fo the high corrosive solution, as well as the swelling capabiles of the present methanol, acsomwpelolneonstosther smal organic: HO KMnO,, Cr{VI), civ mso, | <1 aNcoindeic, ednuveirtoontmheenhtigh oxidative and None, dus fo the high oxidative and ocidic environment As an example, upon transition from a Cr(VI) towards o CrlIll) process, substitution of the PVDF material in the chromium process towards PP is already possible. However, the necessity to employ PVDF in the etching process remains, regardless if the chromium stop is based on Cr{llN) or Cr{Vi). aFilntaelrlnya,tiivt ehaasvatiolabbelep,oitnhattedwoouutl,dthaaltlothwetrheeiscocumrprleenttelyrneomoevcaolnoomfiFcPa-lcloyntoarintiecnhgniccoamlploynfeenatsisblien electroplating plants for chrome plated brass and plastic parts. As such, an electroplating plant as a whole would not be operable upon a complete ban of FPs, since all process steps are required. T0 TCooemeeesC ARoeteGp o5Stot7See n70d3aP0Tssb SaarnA AoAbebdr.otrrott9eCetaShneoye ek Seeer rats AXOR EOE In 2017, Hansgrohe submitted a comprehensive socio-economic study on "the use of chromium trioxide for electroplating of different types of substrates with the purpose to create a long-lasting high durability surface with bright (shiny) or mate look (Functional plating with decorative character)" in the course of an application for authorization (ID 0114-01 and 0114.02). This application resulted in positive approval decision by the RAC and SEAC until February 14, 2031.%7' In the socio-economic study, o nonuse scenario with a corresponding exit strategy and the associated consequences for the business capability and employees of Hansgrohe, as well as the far-reaching further effects that would be associated with a shutdown of the electroplating plants located in Schiltach and Offenburg, were extensively discussed. Since an electroplating plant cannot be operated without components, some of which are made from fluoropolymers, the same effects and consequences as described in the socioeconomic analysis of thot time are also applicable in the current comment on the PFASrestriction proposal. However, it should be noted that Hansgrohe hos experienced very profitable growth since 2017, which again significantly increases the scope of an exit strategy. The business developmen in termsof revenue, EBIT and employees is shown in Table 3. These data were generated on thebasisof the German Commercial Coda (HGS). The share of sales, EBIT, and employees generated in production sites located in the EEA with respect 10 the worldwide sales, EBIT and employees, which aro presented in Table 3approximately amount to [II Table 3: Business development of Hansgrohe (worldwide] according to German Commercial Code. Developomfesanlets| DevelopmofeEnBItT| Devaloofpemmpleoyneets [mEUR) [mEUR) (per31.12.) - | =m mm | =m Hansgrohe takes the safety of their workers and the sustainability of the company as a whole, combined with the applied processes very serious. Therefore, Hansgrohe continuously invests in the substitution of SVHC substances. Hansgrohe has a clear growth strategy and o commitment to the German production sites in Offenburg und Schiltach. The existing plastic etching and plating line in Offenburg (build in 1990) had nearly reached the end of its Maosvsgrobe SE +AAvwmwatb $S9ur+77H7EB617S4c0u7h7ch+ +UGaSm.ony O+1E +1247987187236551+ 0V+ero+n497a8n3 g5e11n3K00i+moovaMsogrraonboe],roowkcomSo+rbionrgoyobbegoep onn. roars A XO R ansgrohe economic and technical lifetime, as well os its capacity limit after 25 years. Therefore, in 2015, Hansgrohe has decided to invest 30 Mio in a new electroplating line for the plating of plastic products at the Offenburg plant, which went operable in 2019. Wenivtihrothnimseinntvaelstimmepnatc,tHoafntshgeroehtcehihnags afnurdthpelratiimnpgroprvoecdestsheboypearpaptliyoinnaglstsaatfeet-yo,f tahned-orrtediundcuesdtrtihael hygiene and safety technology standards and also faking into account future requirements. Al this point, it hos to approximately 30-40 be mentioned, years. tha electroplating plants typically have a life-time of 3.1. PFAS ban scenario A complete ban on PFAS would mean that the existing electroplating plants located in Schiltach and Offenburg could no longer be operated in the future. In addition, a relocation of as electroplating plants outside of the EEA such plants are currently supplied with o would most high degree probably also not lead fo a solution, of customization from companies with many parts being produced in the EEA Hansgrohe currently has a high vertical range of production depth, especially in the German plants. As such, there is currently a complex interaction between the various production steps, starting from the for electroplated raw die material up to the casted brass parts finished includes product. As an example the following steps a simplified process - Purchase of brass raw materials - Low pressure die costing = Machining - Grinding ond polishing - Electroplating - Assembly These complex interactions during the manufacturing process would be disrupted through o PFAS bon. This process os described for the brass parts, is also valid for chrome plated plastic parts. For the plastic parts, molding machines directly Hansgrohe next to the currently operates electroplating plant. an injection Currently, molding facility with [ll the production capacity between moterial cdoencsourmapttiiveon,anwditthecohnnliycalthepladsetciocraptairvtes is [IMM rected plastic parts undergoing 10 the plastic raw the electroplating step. VfaosA Vuonrg,ohse$8CvAhngt giGo3ne on9s37rS V7d851S74t077Aeh ++UGWSarNrChy O<C1 8Y+1o4297t70o82b7328s55i+10aArd+ri45sa7r3i3og0rs5so13Fw0a0ebodngoh oeogoe,nprot mSonpg ohgopenmetn ransonts AXOR ansgrohe It remains uncertain, if the up- and downstream processes would still be economically feasible in such a scenario, when the central manufacturing step, i.e. the electroplating process, would be relocated outside of the EEA, As many of the necessary spare parts of the existing elactroplating plants are mode from FPs, such parts could also no longer be procured. As a result, the operational lifetime of the existing electroplatingplantswill be limited to the lifetimeof the FP parts, which are currently installed. Currently, the transition to chromium-frae pretreatment and coating that would be required in 2031 is investigated at Hansgrohe." This complete R&D project would be rendered obsolete, as both pretreatment steps require process materials out of FPs. Another possibility, beside building up new electroplating plants outside of the EEA, is the purchasing of electroplated components from non-EEA job shop laters, which can achieve the required product quality. Such job shop platers can request a maximum of o [lll mork up, which Hansgrohe cannot fully poss on fo the customers. As a result, such outsourcing of the plating process would result in significant reduction of the achievable profit margin of Hansgrohe, as well as higher prices for the customer. Such an outsourcing scenario, however, is only feasible with the assumption, that the reputational impact associated with the use of fob shop platers outside of the EEA remains acceptable by the customer. The reduction in Honsgrohe's EEA electroplating costs would therefore provide the business with a financial saving. However, such savings would not offset the loss of EEA profit margins associated with the outsourcing to non-EEA job shop platers. 3.2. Analysis of impact Most of the former socio-economic analysis for Chromium trioxide, which was based on the values available in the yeor 2017 [see soction/page XX], are also applicable for this discussion regarding the PFAS restriction proposal. This is due to the fact, that in both cases, a complete shutdown including the disassembly of all electroplating plants in the EEA would be the unavoidable consequence. Since 2017, certain changes with potential impact on the values from 2017 need to be considered. In the following, a non-exhaustive lst of changes with major impact on the transferabilityof the values from 2017 are listed: - Inflation rate - Energy costs = Material costs - Labor costs - Toxes for municipalities - Tumover and EBIT = Number of employees T Hanoi5g +Aomonce $+5171887LS707609 1UGabrer.y OTF1S0Z77E81235551V0e4o57h03i03g1t1K30o0rb , Mop utp Foononrg egesennt AXOR CIR However, the social impact consequences for the Hansgrohe company, for the local region around the plants as in well as e.g. the economic Schiltach and Offenburg and ore Acosmaplalrarebsluel.tinIgn caollstcsasfoers,Hathnesgarboohveefmreonmtithoeneadbopvoientlsiscteadnpboientsscailnecdretaosetdhesciunrcreen2t01si7t,uaetivoenn the best-case scenario presented in the former for the current situation would result in values socio-economic analysis for Chromium ioxide." higher than those The following subsections are only summarizing the individual parts, which need fo be considered in an impact socio-economic analysis assessment. For o detailed for Chromium trioxide. description, the reader is referred fo the 3.2.1. Impact brass electroplating plant and production fine based in Schiltach The electroplating plants in the EEA would continue at full capacity until thesunsetdate. Then, the brass electroplating plant in Schiltach will equipment would be 100 specialized to soll in be the disassembled and permanently EEA, especially if, os result of closed. The o complete 7? ban, all EEA electroplating plants would not be operable any more. The recently built electroplating plant, which went operational in 2019, has not yet been depreciated. As a resull the investment of Hansgrohe in (back then) future sustainable production technology would be completely rendered obsolete. proof and more 32.2. Impact on the Offenburg plastic elching and electroplating plant The etching and plostic electroplating plant in Offenburg will be disassembled and permanently closed. 323. Impact on assembly lines Bross. and plastic-plated parts need fo be shipped from outside the EEA to Offenburg, Schiltach or Wasselonne for an assembly inside the EEA. 3.2.4. Impact on Hansgrohe workers in the EEA Both the directly employed staff necessary for the operation of the electroplating plants and the employed staff in the adjacent specialist departments would lose their jobs os a result of the closure of the electroplating plant. The reason is that a predetermined process chain is necessary fo ensure economical and competitive production. Impacts (number of employees and associated unemployment costs) can be provided upon request. However, it can be assumed that this affects over approx. [Ill employees in the EEA. 32.5. Impact on region Schiltach, Offenburg, Wasselonne Loss of local taxes resuling in a significant social impact. FVVoeersnstaeenlg,$o+CrAeecteetsrSbu3 tSToVAn4n8TR74Si077r9Ac+sUGWSoreImean614$V92a77rEt0Ta3TnS6o3+s1Va0o4nr97o8nK3o6o5n1io13X00eld.emerreosonSeW in og onon AXNZ,OR II 3.3. Summary For the exit-scenario the costs are dominated by the disassembling of the plants in Schiltach and Offenburg and the investment and relocation of the production to non-EEA. The social impact, quantified as the loss of EEA wages, does not have a significant impact on the overall results. By comparison, the monetized human health impact is negligible. The economic and social benefit of Hansgrohe products on the EEA market, as well as on the international market, is very high. The benefits were explicitly confirmed during the Corona crisis, as Hansgrohe products were classified as systemically relevant. The products are indispensable for personal hygiene, e.g. in private environments, hospitals, clinics, kindergartens or retirement homes. For the unlimited use of fluoropolymers in electroplating equipment, it is therefore concluded that the net benefit of Hansgrohe's business to the European economy far outweighs the potential risk of exposure to fluoropolymers. AXOR 4. CHEMICAL SAFETY REPORT At the outset, it must chemicals containing be emphasized that PFAS in the baths in in its the near future, Hansgrohe does not electroplating plant (see also section use 2.1). any As such, in the near future instolled components, the PFAS usage in the electroplating plants relates exclusively to the 4.1. Manufacturing Hansgrohe 10 sections require FPs for 2.3 and 2.4]. the All safe and durable components are operation purchased of their on the electroplating open market. plants (refer In addition, Hansgrohe is only involved to a limited extent in the design of the used components as the emmaiisnsitoanssk fcroonmdutchteedmanautfatchetiurrisnitgesphisosteheofopperroadtuicotns oafretheconesleicdterroepdlattoingbeplcaontnst.rolAlsedsuacnhd, negligible. 4.2. Use Phase FPs have remarkable properties and are chemically stable." As an example, litle effect on PVDF is expected by acid exposure, becouse PVDF is considered fo be stable in acidic echnevmiircoanlmeenxtpso.s"uBreasoefd PoVnDFmahraksetnoetxpbeereinenrceecoagnndizleodngeavsitayn oifsspureodoufctcso,ncdereng.radIantaidodnitdioune, foit has to be attributed to Hansgrohe, that expert knowledge on the applicability of their products - not only containing PVDF the market experience ond but also customer other FP-bosed components satisfaction no significant - is extensive. degradation Based on has been described under standard operation conditions. It cannot example, be excluded that wearO-ings or sealings may and tear-effects may contribute to be exposed fo friction or pressure emissions of FPs. during use. While For no quantitative dota is available, it is imporiant fo note that the servicelife of components used ifnuncetlieoncatlriotpyl.atiCnognsipdlearntisngisthelonvgeryanldowocoehfifgihciednutraboifliftryictiison raenqudirheidghfomrecchoarnrieccatl asntdabilsiatfye, which leads to minimal wear and extended service life, the environmental impact of PFAS. based O-rings, valves, pumps or sealings is rated very low. Furthermore, not all components come into contact with water, which is emilted to wastewater nd has a wear- and higher potential tear-effects will for 10 a release into the environmen. In this regard, i is expected that lesser or no proportion contribute fo environmental emissions if industrial solutions or air/gases are processed by end-products. In general, it hast to be mentioned, thatelectroplating plants have a life-time of approximately 30-40 years. Heuis Aeg Stt 88 743779 Si 6 BT7E272 + Vr: Hos re Kl Norn Fo Sig Iehnesnt ANXeOR ansgrohe 4.3. End of life stage For the end-of-life phase, data regarding emissions from waste treatment are scarce. It is acknowledged that during incineration the generation of by-products may occur. Incineration is nonetheless considered a valid treatment option os complete degradation of FPs is possible. Iis assumed that new information regarding waste treatment will be published in near future, driven by the restriction proposal by ECHA. A solidified understanding of the emission potential may correlate in an improvement of abatement technologies, if required. While regulation of emissions is endorsed by Hansgrohe, it is emphasized that more data are required for an appropriate regulatory approach Toamar h $+ AAnsghrteSS5t717843174S07n9 ++UGtem.anGE<A4I3ZF7E8TT3201+ 0V%erFe57N3o38r5g113K00t.soMdaboryvtiegnconSmogoogreee Vine, Cueshe Goto Sos chs AdWb Yottnt, iAcoso nt oe AXSCOR CIEE [1] B.J. Henry, J. P. CarlinJ,. A. Hommerschmid, R. C. Buck, L W. Buxton, H. Fiedler, J. Seed, O. Hernandez, Integrated environmental assessment and management 2018, 14, 36 [2] OECD, "Data analysis of the idenification of correlations between polymer characteristics and potential for health or ecotoxicological concern, can be found under hiips://www.oecd.org/env/ehs/risk-assessment/4208126 1.pdt. (3) "Analysis of the most appropriate regulatory management options RMOAJ", can be found under hitps://www.hse.gov.uk/reach/assets/docs/pfas-rmoa. pd, 2023. [4] Hansgrohe SE, "Socio-Economic Analysis. Chromium Irioxids", can be found under hitps://echa.europa.eu/documents/ 10162/98d59467-5b87.0287-856e-5cl0bbblc9b (5) ECHA, "Adopted opinions and previous consultations on applications for authorisation. Chromium Irioxide", con be found under hips://acha.europa.eu/de/applications-orauthorisation-previous-consultations/-/substancerev/26304/1eWrAmR_?ech_orevvsiubsetawncespourtlbel_sSEtARCaH_nCRIcTEeRIAs_E C_NUMBER=215-607-84_viewsubstances_WAR_echarevsubstanceportlet_DISS=rue. [6] Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC], "Opinion on an Application for Authorisation for the use of Chromium Trioxide for electroplating of different types of subsirates with the purpose to create a long: lasting high durability surface with bright (shiny) or matte look (Functional electroplating with decorative character)", can be found under hitps://echa.europa.eu/documents/10162/d3611bfa.03dR.3267-0d 1-625c6102 400, 2017. (7) European Commission, "Zusammenfassung von Beschlissen der Europaischen Kommission ber Zulassungen fir das Inverkehrbringen zur Verwendung und/oder fur eine Verwendung von Stoffen, die in Anhang XIV der Verordaung (EG) Nr. 1907/2006 des Europaischen Parlaments und des Rates zur Regisirierung, Bewertung, Zulassung und Beschrankung chemischer Stoffe (REACH) aufgefihrt sind", can be found under hitps://eut-lex.europa.eu/legal-content/DE/TXT/PDF/7uri=CELEX:52019XC0221(01), 2019. (8] 5. H. Korzeniowski, R. C. Buck, R. M. Newkold, A. E. Kossmi, E. Laganis, Y. Matsuoka, 8. Dinolli, 5. Beauchet, F. Adamsky, K. Weilondt et al., Integrated environmental assessment and management 2023, 19, 326. [9] J. E. Marshall, A. Zhenova, S. Roberts, T. Petchey, P. Zhu, C. E. J. Dancer, C. R. McElroy, E. Kendrick, V. Goodship, Polymers 2021, 13. TVVoneageart,nSEC+AoaneoglnrcsGoSt5 S7Ve7361n4S6.7c7A5tbUGWSoelr.oanSETV14Zr377EE8732655b+0+Vrono3.s3Hoa38s3310o1K30oe0no,hMoorganoog,mgFoorShriooghaanreon