Document ZnaZvNLwBZnEvBR15nNO33NB8

Hydrogen industry and the proposed [SY CHT] [ro i kd E: Fd | Hydrogen Europe in a nutshell . 500+ Members We encompass the entire value chainof the hydrogen ecosystem: from production, distribution to end uses, including Industry,EU regions & H2National Associations. i Employees 45 + 4. aly WE AT syorogen a 23 120k+ Followers onSocialMedia ~ LRFollow us on: 9 yy in 3 3 ril = NN Al Ny q 4 rT,3 NNol 8 # Fluoropolymers are used everywhere in the hydrogen and energy/industrial ecosystem > Hydrogen > Batteries Semiconductors > Water management and water 3 rA 0 As Ce > treatment > Electricity grid insulation > Aerospace and defense < * Heat pumps + Medical equipment etc. $C Rope" A ANn RR Fluoropolymer joint letter with associations 15 associations co-signing (energy and digital transition, focus on NZIA sectors) Aiming for an exemption for fluoropolymers under the PFAS restriction Annex with short overview of fluoropolymer use per sector Sent on 3 October to Commissioners Sinkevicius, Simson, Breton and EVP Sefcovic Orme QUIS rt The H2 industry uses fluoropolymers all across its value chain Gu [Dy a= __ Aw =0 48 =h @ & 2] Olas x wrpenasanee ED 3) rrr pvETe || Ra em m==E . %0%,.panne pn Hh | su Why are fluoropolymers relevant for H2: PEM fuel cell example Membrane - PFSA ionomers: perfluorinated copolymers that carry sulfonic acid groups (SO3H); most commonly reinforced by PTFE (therefore, fluoropolymers) it separates protons and electrons and provides the proton conductivity (thereby producing electric current) while separating the reactants: hydrogen and air (oxygen), in the case of a fuel cell - Examples: Nafion; 3M ionomer, Solvay Aquivion ionomer... - In PEM Fuel Cell and Electrolyser, DMFC, chloralkali Electrolysers... Figure 2: Schematic representation of a fuel cell's Membrane Electrode Assembly (MEA) Gas Diffusion Layers (GDL) - These consists of carbon fibre paper or felt. The GDL substrate currently contains PTFE. It is used as hydrophobic agent and - depending on the GDL type - also as binder. Microporous layers (MPL) - GDL are often equipped with an additional layer at the interface to the electrode, an MPL, made of PTFE due to its hydrophobic properties It equalizes the GDL surface and, therefore, prevents damage of the membrane and improves electrical and thermal contact between GDL and the electrode. Source: Umicore's website Why are fluoropolymers relevant for H2: entire value chain oC op Some typical sealing materials, such as gaskets, in fuel cells, as well as in equipment in the distribution network (regulator membranes, meters, etc.) Coating materials: PTFE to protect against harsh processing conditions. Alkaline electrolysis technologies introduce warm caustic solutions Infrastructure: aboveground storage and salt caverns, gas grids, cryogenic liquid hydrogen carriers, liquid organic hydrogen carriers, road and water transport of bulk [Ee Hydrogen Refueling Stations: PTFE bands used in valves, flow meters, dispersers and key in compressors. What is the potential for alternatives and research? Material properties of perfluorinated polymers are unique and technically impossible to replace in the near future. Restrictions on fluoropolymers (including PTFE) would render several critical applications from water electrolysis, fuel cells, to H2 transport technologies unfeasible, or would dramatically reduce their service life and increase the probability of malfunction. Performance of alternative such as hydrocarbon membranes, is still very low because they suffer from reduced thermal and chemical stability and extremely short durability, lasting only dozens of hours against lifetime requirements (at the very least) of >25,000 hours. There is a potential for research in fluoride-free materials (e.g. Hydrocarbon membranes...), but they need to take the same KPIs of today's technologies as a benchmark. PFAS restriction proposal - rationale Qu + Main issue with PFAS is persistence ("forever chemicals") As the substances persis inthe environment, th longer the tock i allowed to increase i. the restriction is not in force), the less effective the aimed emission reduction will become: > Additonaltypicalfeatures... mbit, accumulation in plants, bioaccumulation,long:ane transport potential, ecotoxiity endocrine acti, inducing rsks for human health and the environment. * 10 000+ PFAS exist, "regrettable substitutions" by industry have been commonplace as a consequence of individual-substance restrictions. BUT Fluoropolymers (the PFAS subgroup used by hydrogen sector) are only persistent and are "polymers of low concern" according to the OECD > Yet, not treated in a differentiated manner in the proposal. > Their alleged lifecycle emissions is the other main rationalefor thei inclusion in the restriction PFAS restriicctiion proposal --_ hydrogen sector P$S e ycrogen Hydrogen industry uses get a full ban after 18-month transition, except fluoropolymers and perfluoropolyethers for use in PEM fuel cells until 6.5 years (Sy + 18 months) after entry into force > Proposal only derogates on PEM Fuel Cel, not on Electorroothelryhydsroegern tech L [fanE ts--_-- vEarEioEus componentsin Ee E pr L E DIe CE Ee obioo e an i -- Socio-economic impacts of a ban $C rte Due to 1) essentiality of fluoropolymers for the H2 value chain and 2) the absence of alternatives... a precipitous PFAS ban without granting any derogation for applications in the hydrogen sector would have destructive effects on the industry, jeopardising... 3 2030 0 + 30-billion worth of investment in a decade (only including electrolysers &fuel cells), Qo "up to 200k direct jobs and over 260k indirect jobs within 10 years, and oe + 2030 climate target (-55% GHG + renewable H2 targets in industry & transport) and phasing out fossil fuels (REPowerEU) 2050 0 + Amarket with a potential value of 820 billion... + ..employing 5.4 million workersby the middleof the century, and e * The EU's climate-neutrality target, energy security, strong industrial base. Key messages from Hydrogen Europe 0 nce A [QE 1chainoroestsfounnctthieoensisnegnotfialetuecsteroolfysfelruso,rofupeollcyemlerssaonfdteonthier tzechaenolodFgAieSsactcergoons)s. the H2 value ow fpJ no siternative to fluoropolymers today comes cose to the same KP in the Ha sector N EEJ) a Eonlvyimrerosnmofei onawtnacdlonhcuemrr na)nahreealetxhtriesn mkresltoyfli filmuitoerdopsolymsehressh(coonsnidearleod bhyiOnECoDisasin ems La Ee pe Fee T dd P es ns an \ fi Nhyodtreoxgeemnpitnidnugsttrhyeanusde oitfs fgllouboarlopcoolmypmeetristiivnentehsesH,2assecwetlolrawojuelodpatrhdriesaetetnhethaechwiheovleemeEnutroopfetahne EU's climate, energy security, and industrial objectives. Thank You -- 8 woe &) vy oD