Document XR8Ran6g3oxzmOeRE2qO09JQ4

September 24, 2023 PERFORMANCE FLUOROPOLYMER PARTNERSHIP Re: Comments for the REACH Annex XV All PFAS Restriction Proposal Submitted via the European Chemicals Agency's webform at https://comments.echa.europa.eu/comments_cms/AnnexXVRestrictionDos sier.aspx?RObjectld=0b0236e1885e69de This information is submitted on behalf of the American Chemistry Council's (ACC) Performance Fluoropolymer Partnership (hereafter "PFP"), whose members include some of the world's leading manufacturers, processors, and users of fluoropolymers, including fluoroplastics, fluoroelastomers and perfluoropolyether polymers.' The PFP's mission is to promote the responsible production, use, and management of fluoropolymers. We invest in research to support our mission and inform a scientifically sound, risk-based approach to regulation. This submission describes a project to analyze a set of perfluoropolyethers (PFPEs) against criteria used widely to identify polymers of low concern to human health or the environment. PFPEs are large polymeric compounds that are highly insoluble in either water or octanol and are therefore not mobile, bioaccumulative, or bioavailable. They do not contain meaningful amounts of residual monomers or low molecular weight oligomers due to efficient manufacturing processes. PFPEs are also highly resistant to thermal, chemical, and physical challenges. The PFPEs analyzed in the project are described in Table 1. The study manuscript, including study methodology and results, will be published in a scientific journal and is currently undergoing peer review. The anticipated citation will be Javed, H. et al. A Critical Review of the Application ofPolymer ofLow Concern and Regulatory Criteria to Perfluoropolyethers. Integrated Environmental Assessment and Management. Vol., No., pp. TBD. Based on the evidence presented in the forthcoming manuscript, we respectfully request a full exemption for the use of these PFPEs. Thank you for the opportunity to provide these comments. Please contact me if you or your colleagues have any questions. Sincerely, Jay West Executive Director Performance Fluoropolymer Partnership @americanchemistry.com 1 https://fluoropolymerpartnership.com/ 700 2nd Street, NE Washington, DC 20002, USA Performance Fluoropolymer Partnership Perfluoropolyethers - Annex XV Restriction Report | September 24, 2023 Page 2 of 2 Table 1. PFPEs analyzed against polymers of low concern criteria. Common Name PFPE D Chemical Name Oxetane, 2,2,3,3tetrafluoro-, homopolymer, fluorinated CAS# 11311419-5 Structure F-(CF2CF2CF2O)n-CF2CF3 n = 10 to 100 PFPE Z PFPE K PFPE Y Ethene, tetrafluoro-, oxidized, polymd Poly[oxy[trifluoro(trif luoromethyl)-1,2ethanediyl]], (1,1,2,2,2- pentafluoroethyl)-[tetrafluoro(trifluoro methyl)ethoxy]1-Propene, 1,1,2,3,3,3- hexafluoro-, oxidized, polymd. 69991-613 60164-514 69991-679 CF3O-[CF2CF2O]p-[CF2O]qCF3 p/q = 1 CF3CF2CF2O-[CF(CF3)CF2O]nCF2CF3 n = 6 to 100 CF3-[(OCF(CF3)CF2)m(OCF2)n]OCF3 m+n = 8 to 45 Linear/ Branched Linear Linear Branched Branched 700 2nd Street, NE Washington, DC 20002, USA