Document ZnJOrbjEErzqBQ9xGdwXXQoXJ

federal public service HEALTH, FOOD CHAIN SAFETY AND ENVIRONMENT Preparation of meeting Chemours PFAS REACH restrictions What are PFAS? PFAS = Per- and Polyfluoroalkyl substances Very diverse group of substances (5000 plus substances) Characterized by C-F bond Man made chemicals Water and grease repellent characteristics Stability and thermo resistance Used for a wide variety of products: Firefighting foam Textile treatment Food contact materials Coatings Construction articles Electronics ... Source: OECD draft terminology report Concern Toxicological effects Main concern: Persistency Wide-spread pollution Legislative action on PFAS PFOS restricted since 2006 Industry replaced PFOS with other PFAS (PFHxA) regrettable substitution Now PFHxA is being restricted (2024) This warrants the need for a group approach PFOS PFHxA Universal PFAS restriction under REACH February 2023: 5 Member States proposed a universal PFAS restriction under REACH All PFAS in scope If CF3 or CF2 in the structure most likely a PFAS All uses of PFAS in scope Also "essential uses" Temporary derogations are being proposed PTFE (Teflon) Main concern for industry: Fluoropolymers Subgroup of PFAS Long carbon chain (polymer) that is (fully) fluorinated Very stable molecules Do not interact with other molecules and can't pass the cell barrier Up to now no evidence of toxic properties has been found Used in many "essential" applications Fire resistant electrical wiring Medical packaging Fire resistant personal protection equipment Batteries Etc. Industry askes for complete exemption from the restriction Main arguments by industry "Fluoropolymers are inert and do not have toxic properties" However: During production of fluoropolymers other (toxic) PFAS can be used Also concerns on the end-of-life during incineration they might break down to shorter-chain (toxic) PFAS, some of which are also potent greenhouse gasses "Fluoropolymers are used in essential applications" However: many of the fluoropolymer uses are not essential (e.g. non stick pans) For many essential uses alternatives are available Even if the use is essential only specific uses should be temporarily exempted until alternatives are available "Fluoropolymer producer can make a voluntary commitment to minimize emissions during production" However: this will not have any legal certainty and will not tackle the end-oflife concerns Main concern industry: fluorinated gasses Gasses containing fluorine Used for: Heating pumps Insulation sprays Refrigerants Etc. Main Industry argument: "Fluorinated gasses are already regulated under the Montreal Protocol/F-gas regulation" However: main concern under F-gas reg is the greenhouse gas potency, while the REACH restriction focus is on wider concern of persistency Also several fluorinated gasses are not covered by the F-gas regulation Why is the industry contacting us? REACH restriction process: February 2023 March 2023 - September 2023 2023-2025 2025/2026 Public consultation on the proposal is running until 25 September In this consultation stakeholders can provide info and data to the scientific committees RAC and SEAC Our role in the Public Consultation Belgium coordinated comments are being submitted to the consultation Include data on emissions and monitoring from the regional authorities Also market studies from federal authorities Coordinated via the CCIM PFAS Working group Subgroup of the CCIM Chemicals steering group Belgian input is being approved by the Belgian REACH Committee (BCR) BCR already organized 2 stakeholder meetings on the PFAS topic Main message we give the Industry: send you info to the Public Consultation Chemours Spinoff of former company DuPont Producer of fluoropolymers and fluorinated gasses Fluoropolymer production site in Dordrecht (NL) Production of coatings and other advanced materials in Mechelen (BE) In 2017: pollution of Gen(X) (specific PFAS) was uncovered in Dordrecht Since then: Chemours have invested in safer production and water purification at Dordrecht site However concerns remain on certain waste streams and end-of-life of their products