Document XOrEV7Rbdq4GqpGzaKwVVpndw

Fluoropolymers' characteristics, in particular their excellent resistance to thermal or chemical attacks, are perfectly adapted to severe environments as required for defence applications. Fluoropolymers also present an extremely low coefficient of friction which gives them an optimal compatibility with the high sensitivities of pyrotechnic substances or mixtures. In addition, fluoropolymers are the only molecules chemically compatible with all families of pyrotechnic mixtures which ensures the highest level of safety during the manufacturing, the handling, the functioning and the storage of ammunition in all conditions. For all these reasons, companies of the defence industry have been using fluoropolymers in pyrotechnic compositions and in components which are in contact with pyrotechnic compositions since the 1980s and no extensive research for alternatives exists today. Subject to identifying substitute formulations with equivalent performances, the inclusion of fluoropolymers in the restriction would lead to a requalification for each case of use (ammunition and pyrotechnic components). The usual time to qualify a new formulation in one ammunition is around 10 years and the overall cost is assessed at several million euros. In addition, this restriction would prevent the defence industry from honouring: - the ammunition orders already committed for deliveries spread over several years (more than 10 years) leading to break contracts, - the request of the French State to constitute stocks within the framework of the war economy (Military Programming Law 2024-2030 (LPM)). Following this restriction, any sub-assembly already in stock (pyrotechnic or not, containing a fluoropolymer) awaiting to be integrated in ammunition or into another complex article to be placed on the market should be destroyed. In addition to the financial and technical impacts (for destruction of pyrotechnic products), national interests can no longer be respected. All these points will be developed and documented in the other parts of the consultation by each GICAT's members concerned by pyrotechnic activities. Nevertheless, fluoropolymers shall be considered as a distinct subset of PFAS related to chemical hazard. Fluoropolymers are inherently safe, non-mobile, non-bio accumulative and non-toxic. Fluoropolymers are different from other PFAS as they do not share the toxicological and environmental profiles associated with PFAS of concern. Fluoropolymers have a unique set of physicochemical properties, they meet OECD polymer of low concern criteria, and are considered to have insignificant environmental and human health impact. Considering the safety and reliability benefits of fluoropolymer applications for the defence industry, the very low PFAS emissions risk and initiatives being taken by the processing industry to further minimize emissions and closing the loop by implementing circular economy wherever possible, we request a full exemption of fluoropolymers from the PFAS restriction proposal to maintain our major critical uses such as: - Formulation of pyrotechnic compositions contained in military equipment and ammunition components. - Surface coating of processing tools and parts of ammunition in direct contact with pyrotechnic compositions. We remain at your disposal for any questions and exchange on issue. Sincerely yours Mazeres, the 08 June 2023 GICAT and LACROIX contact information: JoeIle PINCHOT REACH Mana ROIX and Manager of the working group REACH of GICAT ema tienne-lacroix.com tel: