Document Vm45O8ob38baZ7ZQyNgo7dbp
| + Chemours'
F-Gases and the proposed
PFAS Restriction under REACH
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June 24, 2021
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Meeting Agenda
Subject/ Presenter
Introduction Chemours overview
Alternative Regulatory Management Options for FGASs
Criticality of FGASs in a broad range of applications Illustration on key applications Wrap-up Q&A
Content * Background, objectives, participants
* Who we are and what we make
* Discussion on RMOAs, addressing potential gaps and managing circularity
* Overview applications * Overview key properties of FGAS (vs. alternatives) |llustrate application requirements and available
technology trade-offs * Key messages
| +4 Chemours
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(03 U1[1 IVICR o ET gd [of] s E1165
Name
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Alber & Geiger
w
or-Chemours.
ChemoursTM overview
5.1.2e
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Who we are in Europe
Who is Che mou rs?
~y ) 00
served Customers
across Europe's industrial value chain.
in
ll HR 0
ti
6
+900
employees in Europe across
all business units.
Driving to achieve a 60% reduction of operations-related GHG emissions by 2030, putting the company on the path to net zero by 2050.
Why are we talking to EU regulato rs?
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We are a frontrunner, committed to finding
solutions that enable our customers to become more sustainable.
We support regulation that promotes
safer and more
sustainable chemicals.
We believe key concerns
around FGASs can be
better addressed through existing frameworks,
rather than through the
PFAS REACH Restriction.
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Ol VN EIEN RLU EIRYEA ELC
Our
buussiiness
.
un Its
Titanium
Technologies
>
Advanced Performance
Solutions
[T=]
od
Thermal &
Specialized
Solutions
NY
A
7A
"ry
Onan
Chemical
Solutions
What we make
Our main products in Europe
Fluoropolymers:
Specialty plastics with a unique combination of properties that resist fire,
extreme temperatures and other high-
performance conditions.
FGASs: low GWP
refrigerants foam blowing agents and
more, which my
colleagues will cover in
more detail.
> 1bn
In R&D investments to
develop more sustainable refrigerant solutions
alongside our value chain
peers.
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Chemours.
Alternative Regulatory Management Options for FGASs
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iN o To] [[aA oT=I do T=Tol {\V/- Wolo WHCARTS
FGASs are listed under the Montreal Protocol and already regulated in Europe by the FGAS Regulation EU 517/2014, MAC Directive EC 2006/40 and REACH Regulation EC 1907/2006. FGASs have been through rigorous regulatory approval processes in the EU and have been deemed safe for their intended use throughout their entire lifecycles.
The safety profile of certain alternatives, such as propane, make them unavailable for widespread use. FGASs do not fulfill the persistence criteria as defined in the REACH Regulation.
FGASs play a critical role in delivering innovative and reduced carbon footprint technologies that enable the European Green Deal. Limiting Europe's choice of refrigerants may have unintended consequences to the implementation of societal objectives.
Low GWP HFO:s facilitate decarbonization by enabling improvements in energy efficiency that meet the long-term needs of all relevant applications.
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Sn ulatory
Taking it case-by-
case
&=
alu enfiorice i tory Wearecommitted to working with reggulators aa ndotherstakeholders
acrossthe chain ito
regulato framework.Multiple
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The revision of the FGASs Regulation is the solution to close the [oTe]"]
Improvements to the existing regulatory framework are underway. Extending the requirements of the FGAS Regulation to HFOs and other refrigerants will strengthen circularity, while avoiding overlap.
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_--
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Stronger leakage management requirements (3 & 4): prevention of unintended releases and periodic leak checks mandatory use of leak detection should be enhanced.
* End of life management (8): more effective verification and reporting tools are needed to ensure recovery of FGASs and promote circularity. FGASs are recycled, reclaimed or destroyed. Article is linked to 2006/40/EC (MAC Directive).
* Harmonized training & certification across the value chain (10): extend requirement to all refrigerants.
* Stronger enforcement: enhanced coordination across EU Member States,
=
including penalties for infractions.
While FGASs are not intended for release into the environment, there are regulatory options outside the
PFAS REACH Restriction.
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Chemours.
Criticality of FGASs in a broad range of 11 applications
5.1.2e
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FGASs enable the EU green and digital transition
gree = Commercial * Industrial * Transportation
= DX = Chillers
= Heat Pumps = Mobile
= Close cell spray
= Pour in place = HP Panels
= Molded-IS
SUB-APPLICATIONS
ma-- EL
i
} APPLICATIONS
:
YA fee Refrigeration |
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A/C
APPLICATIONS
Solvents Propellants
+ = i=
ge *
Critical cleaning
Carrier fluid
Aerosols, MDI
Flooding
Carbon
neutrality : ~f-# = Switchgear
-:
" HTHP
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NY 4 2 paa0t Eas
:
Renovation Wave
i
Mobility Smart and Sustainable
Digital Transformation
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FGASs provide functionality to a wide range of applications, equipment types and variation of heating and cooling capacity. Their unique properties enable widespread use despite geographic and ambient temperature differences in Europe.
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FGASs outperform alternative technologies
Safety and environmental criteria
* Non or low flammability * Low toxicity
* Ultra-low GWP
* Mechanical& chemical safety
HFOs
HFCs
co,
Benefits of FGASs
Optimized Total Cost of Ownership (TCO) * Investment, maintenance and operational
costs
= Energy efficiency (TEWI) = Resource efficiency = 15-20 year equipment lifetime
Non or low
flammability
Low touicity
x
x
x
x
2
x
Xa)
2
Ultra-low GWP
x
x
X
X
Medhanical &
;
;
;
chemical safety
(1) CO2 (R-744) Acute Toxicity
ATEL (Acute Tox exposure limit) is 30,000ppm (3%), 3x vs lower ATEL of HFO-(1 Ref.2 : A3 SHR4 AEy SP3f4)
i
.
Dedicated value chain
* Specialized & extended value chain has been established for several industries, including FGAS recovery measures.
oo
+ After market: producer-distributorwholesaler-service/installer-end user.
* Thousands of SME wholesalers &
.
installers rely on FGASs.
&
FGASs are required for a full toolbox across many applications -- they provide the best combination of environmental, safety and economic benefits .
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Commercial
HE Ee]
5.1.2
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Market Dynamics Overview
Retail Stores
Transport ~ Commercial
Refrigeration
Refrigeration
Industrial Food
Processing
Cold
Storage
Key Market Drivers
* Ensure Global Food cold-chain.
* Achieve lowest Total
cost of ownership. + Adapt to changing
consumer behavior.
Evolution of Retail Stores Number per Area m?
2
140
2a ss
= BE a
55
3 s 20
E
0
>
&
+1.8%
pr
9.5%
5.6%
2018
2023
more than S000 Rbetweemasysng Saale H less than 250m?
"
Retail
"
Analysis
Considerations for adaptation to
consumer behavior:
* Noise
= Available space (given urban distribution) + Safety (residential areas)
The strongest market growth is in the sector of medium & small sized retail stores, where FGASs have been shown to provide lowest total emissions and lowest total cost of ownership.
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Different refrigerants to address different needs
Q Low GWP Alternatives Where we | are now |
High ODP
$3
|
>2000
<1500
o
lg
Low cost of
ownership
ceeeeeeenen
Very low
GWP<150
Pros and Cons
* Good efficiency but high flammability and very low charge sizes. Market favors use in refrigerated cabinets (or integrals). High efficiency and low flammability but limited charge size. Cost effective solution for small &
medium sized retail stores.
Efficient in large systems but complex, expensive and sensitive to higher ambient temperatures. Viable solution for large retail stores.
Requirements of the Retailers
Higo h El fficiency
-
M
Safe
Reliable with minimum risk to trade
Easy to install
and maintain
w Sustainable
&
Several solutions, including F-Gases, are needed to effectively meet the market requirements, while also minimizing carbon footprint and total cost of ownership.
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Heat Pump segment relevance
residential New Build and Renovation
Key Applications
(gas boiler replacement and
HEAT PUMPS are a critical enabler for:
increased energy efficiency) District heating
fm, lik
Decarbonization
to achieve EU Green Deal
Inherent high efficiency.
Can enable up to 50% reduction of the
Fossil fuel replacement in
] Centralized Heating l
objectives.
Energy Efficiency
to reduce heating/cooling
related emissions.
building sector's CO2 emissionsTM. Cleaner source of electric heat replacing fossil fuel technology in house renovation and new builds. Broadly known technology (16M Fluorinated
Commercial / Industrial Increased energy Efficiency
with Heat Recovery and ORC systems
Refrigerant Heat Pumps already installed in EU).
The role of Heat Pumps in the EU economy:
Milons now
| Air to Water
| Air to Air
Vio Ground Source
Units ~now
HP
0.5
0 2018
2019
2020
2023
pil 2025
2030 Source EHPA - SME
Chemours * International Energy Agency data
Market expected to grow x3 by 2030. Strong growth in air source HP and Indoor applications.
Over 1 Million Air-Water units expected by 2025 in
EU.
Air-to-Air technology adoption keeping growing in
southern EU.
* Ground source HPs increasingly adopted in colder climates because of higher efficiency (0.10M B/W expected in EU by 2025).
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Technology Options
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210A
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nam
Air-to-Air AirtoAWater Ground source
Qualifying Factors
* System Energy Performance * Application Safety
Sustaiinnaalbyili hy * Cost effectiveness
Water Ammonia
CO2
R1234yf
R452B/R454B R32
R134a R407C R410A R404A
GWP
-
Ea
Ss
&=
|I
1000
2000
3000
> > > >
Performance Strengths/ Challenges
= Incompatible with evaporation temperatures below 0C; Limited range of applications = Good thermal capacity, major issues of toxicity, flammability material compatibility = poor energy efficiency, particularly in combination with under-floor-heating
= High energy efficiency, highly flammable and explosive (A3)
= ow volumetric cooling capacity for specific applications
High energy efficiency, high flow temperature, mildly flammable (A2L]
= High efficiency at low flow temperatures (under-floor-heating) = High pressure, high efficiency at low flow temperatures (under-floor-heating)
Safety and energy performance are the key factors Industry convergence on 2 solutions
Le (ONTIV iT I =] 1 (oJ: To Lo](=X { [X=T oo] [[o: Te] Wg L=T Te
Chemours'
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Role of HFO refrigerants and proposed Path forward
PERFORMANCE Efficiency
fs
COMMERCIAL
A YGlAobalABsIuLppIlTyY
:
Industry Requirements
A:
f :y
TOTAL COST OF
O= WCNapEitRaSl IcoIstPs
= Operation costs
* Heat Pumps equipment and technologies provide unique advantages to enable
decarbonization and energy economies.
* Regulatory uncertainty risk delaying the deployment in the region.
* Two technologies have emerged from several decades of development, each covering specific segments.
Different solutions need to coexist: HFOs
bi est address energygy ef!ficiently y and safel y in several key applications.
* A3 classified Hydrocarbon alternatives do not offer inherent safety for indoor use.
&
* Heat Pumps are enablers of the Green Deal Objectives * System efficiency and safety are key requirements for this technology to deploy * Circular economy: end-of life management, safety and installation training will be key
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\Vi[oJo| ]
(MAC)
WAN
gonditioning
Privileged & Confidential. Prepared for legal counsel revie
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The evolution of the automotive fluids
1992
Fim,
R-134a GWP=1430 | ODP=0
2013
elays. ;
R-1234yf GWP=<1 | ODP=0
* HFO-1234yf: the replacement for HFC-134a in Europe following the EU
MAC Directive
(2006/40/EC)
HFO-1234yf :
* Enables the lowest carbon footprint (High Efficiency)
* Low system Cost: near drop-in solution * Good proven safety
By 2025, the global use of OpteonTM refrigerants is expected to have
eliminated an estimated
325
MILLION TONS OF
CO2 EQUIVALENT
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Car Electrification future impacting the comfort solution
MAC have a significant impact on the energy consumption of electric vehicles (EVs).
Nd MAC can reduce EV range overall to 50%
because of supplementary heating.
MAC system linked to the
battery cooling
Bansly: =z
<>
ay Heat pump (4) supplementary heating
cooing 2 Cooling/Heating
= Heat recovery
HVAC:
EA
=)\FN
&
hd
MAC shifting to Heat Pump enables higher efficiency and longer driving distance
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Holl AVR V1 dr: R He TACKLE {[0116 [MTs Mele 1a io [=] r= 1dle]2!
oO
Good Cooling performance
Easy commercialization from current technology Lower cost with components cariy-ouer wer weight
Low Heating efficiency at low temperature
Additional heater for low T
Good heating efficiency at low T temperature range
Lower cooling g efficiencyy at hi8gher T
High pressure & leakage sensitive
Higher costs from higher specs systems
Reliability & Maintainability
All low GWP fluids alternatives are under evaluation within the industry to develop a better solution in all conditions (on going SAE work)
Key Criteria
5s EV Driving Range & Coat Competiivenasa G= Eco-nendly Alternative Refrigerant
Source: https://www.sia.fr/publications/489-challenges-confort-thermigue-automobile
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The Role of HFO in the Path Forward
=o
For original equipment manufacturers (OEMs) * Cost effective solution managing both cooling and heating without high complexity
* No legal or regulatory hurdles; no additional risk assessments; and have no effect on established service procedures or equipment.
2=UJ
For owners
%
"
_--
"
* Higher reliability, lower service costs
* Proven Safety
Tan
For communities
* Excellent life cycle climate performance considering both heating and cooling
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Foam Blowing JAY0]]8
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Low GWP Blowing Agents and Insulation
Polyurethane and Extruded Polystyrene enable energy efficiency for appliances, building insulation, pipe insulation, flooring, and automotive.
Blowing agents are trapped during foam production imparting the insulating ability.
HFOs unique physical properties enable innovation for a range of applications that cannot be achieved with CO, or
HCs alone.
HCs are low cost; however, they cannot
meet current or future energy
regulation without HFOs.
FLUID FAMILY
CHEMICAL
GWp*
FLAMMABILITY!
HFOs
HFO-1336mzz
2
Non-flammable
HFO-1234ze
<1
Non-flammable
HFO-1233zd uy
1
HCs
c-pentane
5
Flammable
Iso-pentane
5
n-pentane
5
PERFOMANC OxygenatedHCs
Blend of pentanes | 5 Propane/butane | 3
| Methyl formate <25
Flammable
Methylal
<25
Flammable
INSULATON
Carbon Dioxide
CO,
1
CO, with co-
1
blowing agent
Supercritical CO, -_
Non-flammable Flammable
Non-flammable
T Flammability as classified by UNEP.
#150 817
HFOs improve resource efficiency
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Select Applications: Construction
*
HFOs are providing resource efficiency
in construction applications.
5
:
Renovation Wave .
EU
will spur demand
for FGAS in construction to meet energy
ratings.
* Hydrocarbons are Flammable and cannot be used in this application.
* Emissions related to home heating and
cooling reduced by 1,000 to 1,500 kg
CO2/yr per home vs. fiberglass
HIH
translates to 178.94 billion kg of CO,/yr
for 115 million homes.!
Life cycle analysis
A
=
=
Q
L om
T
L
2
> c
ES
| Manion Net environmental over 75 year servicliefe
Time
>
ea impact
PR
vg
ae seoveey SPF vs 1: FG [pfs
mwiinnsuulaitzi in
1:
FG
lie
Environmental Impact of Insulation Choice
HFOs deliver a lower net carbon footprint.
1. SPF-Contributing-to-Sustainability-Reducing-GHG(-wEhmysipsrsaiyfoonasm..oprdgf)
< Ch
2. https://www.sprayfoam.org/files/Demand%20a%20Better%20Insulation.pdf
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Y=] [Tot Yo] o 1 Tor 1 A (o] s FN@o][ Ns F111
* HFO/HC blends enable energy ratings of A and B in appliances --
where alternatives cannot.
* HFO/HC foams provide 9-15%
better thermal resistance vs HC foam.?
* Similar savings through thermal efficiency in refrigerated transport trailers and cold storage can be
realized.
* HFO/HC blends are cost effective.
EU energy label for
household refrigerators and freezers
MODEL IDENTIFIER
a
XYZ wwh/annum
Energy savings!
* 200 savings over the lifetime of an appliance.
* Europe will save up to 9.6 TWh of electricity per year by 2030.
* Prevents 3.1 million
tonnes of CO, emissions
every year.
< Ch
Renovation Wave cannot achieve the same decarbonization levels
without the use of FGASs.
1. Fridges and freezers | European Commission (europa.eu 2. Whirlpool refrigerators become first commercial application for a poly (plasticstoday.com)
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TFA considerations
* Trifluoroacetic acid is a naturally occurring organic acid. More than 200 million tons
of TFA are found in the world's oceans. 11 P!
* Multiple sources for TFA: 95% of the TFA on Earth is believed to be a natural. However, 5% comes from anthropogenic sources (i.e. agriculture, pharma, some FGASs). HIP!
* The human and environmental health effects of TFA have been thoroughly evaluated in various toxicology studies that have also been used to meet the requirements of
REACH.
* UNEP Environmental Effects Assessment Panel (EEAP) scientific conclusions for TFA : "There is still NO indication that exposure to current and projected concentrations of salts of TFA in surface waters present a risk to the health of humans and the
environment."
The EU FGAS Regulation revision process is critical to ensure proper handling of refrigerants. Our proposed risk management options also help address unwanted releases of FGASs, minimizing manmade TFA in the environment.
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Privileged & Confidential. Prepared for legal counsel review
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FGASs are key to achieving the European Green Deal's objectives. Restricting FGASs in a way that generates regulatory overlap and uncertainty could slow down decarbonization of key sectors and hinder innovation.
Safety and Total Cost of Ownership (TCO) are critical considerations associated to flexibility in the choice of the refrigerant.
FGAS revision & MAC Directive are key tools to manage circular economy challenges
on FGASs.
We look forward to cooperate with you and other authorities along the various steps of this regulatory process.
We believe that a consistent regulatory approach in line with the FGASs Regulation presents the best opportunity to address your concerns and ensure that all critical application of FGASs remain available.
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QQuueessttiioonnss??
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References
1. Scott B.F,, et al., "Haloacetic Acids in the Freshwater and Marine Environment," First International Symposium on Atmospheric Reactive Substances, 14-16 April 1999, Bayreuth, Germany. 2. Von Sydow L., et al., "Natural background levels of trifluoroacetate in rain and snow," Environmental Science & Technology, 34, 3115-3118, 2000. 3. Frank H., et al., "Trifluoroacetate in Ocean Waters," Environmental Science & Technology, 36, 1215, 2002. 4. Bavarian State Office for the Environment, "F-Gases and Water Protection: Trifluoroacetic Acid (TFA)," presentation from conference, "The Way to Natural Refrigerant Technologies," WWA Nuremberg, 2019. 5. "EFCTC Special Review: Understanding TFA," European Fluorocarbons Technical Committee, 2016. 6. Neale, R. E., Barnes, P. W., Robson, T. M., Neale, P. J., Williamson, C. E., Zepp, R. G., et al. (2021). Environmental effects of stratospheric ozone depletion, UV radiation, and interactions with climate change: UNEP Environmental Effects Assessment Panel, Update 2020. Photochemical & Photobiological Sciences. https://doi.org/10.1007/s43630-020-00001-x. See sections 7.8 to 7.11 for Trifluoroacetic acid (TFA).
7. https://ozone.unep.org/sites/default/files/2019-04/EEAP_assessment-report-2018 %282%29.pdf
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