Document ZnBE5Dbog4ORZgv1GwKBE7D6Z

2967650 Meeting with stakeholders on PFAS restriction dossier Short report to be shared with PFAS restriction group and the relevant stakeholder Date: 23/03/21 Place: Online (1 hour) Reporting Member State: o NL Participants (names and organization): o Member State: NL [8] ICE vv) oO EE vwvv)) o IEEE o Stakeholder: 3M o o 3 o o 3M Benelux Electronics Materials Solutions Division - 3M Dyneon LLC luor Stewardship Role of stakeholder/company: o Producer Specific PFAS substance (if applicable): o Diverse PFAS (polymers, liquids, etc.) as well as articles containing PFAS Specific subject (if applicable): o 3M''s recent environmental stewardship commitment: https://news.3m.com/English/3mstories/3m-details/2021/3M-commits-to-achieving-carbon-neutrality-reducing-water-useand-improving-water-quality/. o Those commitments do apply also to PFAS manufacturing sites in Europe: Dyneon site in Gendorf/Germany and Zwijndrecht plant in Belgium. Stakeholder invited to provide the information presented in call for evidence or public consultation? Oo n/a. o But 3M gave a presentation about their activities in Europe and their commitments. 2967650 Report 3M is a producer of chemicals but mainly of products. The portfolio covers > 1.000 products. In Europe there are two fluorine material producing factories; in Belgium (Zwijndrecht) and in Germany (Gendorf/Burgkirchen). The Gendorf facility was originally a Hoechst facility but in 1996 a joint venture between 3M and Hoechst was started (named Dyneon). Currently it's a 100% 3M factory with a separate legal entity. In Zwijndrecht the facility is 50 years old. 3M is starting with some circular initiatives. In Burgkirchen, 3M recycles PTFE, FEP and PFE. The capacity is 500 tons / year and currently only production and processing waste is recycled. The yield is about 90%. Immersive cooling is an important use of PFAS for 3M. 3M uses NOVEC cooling liquid and indicate that computer hardware is fully submerged in the liquid. The liquid can be filtered but at a certain moment is likely needs to be replaced. This is a growing market. Some of the PFAS 3M uses are replacements for strong Greenhouse gases such as SF6. According to 3M their PFAS containing liguids are biodegradable and not PBT, CMR etc. Questions: e 3M asks about the potential narrowing down of the restriction scope. RIVM explained that at least up till the Registry of Intention the scope will be as broad as during the CfE. 3M explains that there likely might be a thousand of derogation requests. eo 3M asks about essential use. RIVM explained that COM explanation / definition might be too late for the PFAS restriction file. An exemption per use is too simple as i.e. in medical uses there are examples of uses which might be substituted quite easily. e 3M is working on an Application of Benefit Framework instead of Essential Use. It's being finalized now and a meeting with RIVM could be prepared for the 2" half of April. 3M is also (going to) talk with other Member States.