Document ZnnXazmoGpG7zQ8x01yR1no8O

PFAS Content: Request for exemption Org. name: Zhejiang Juhua Hanzheng New Materials Co., Ltd. General Comments: Our company is a manufacturer of fluorinated fine chemicals, and we would like to greet the five countries that have proposed the ECHA and PFAS control draft. Our company has always made unremitting efforts to comply with domestic and international regulations, and continuously conducts strict self review of the compliance of products exported to the European Union. For a long time, our company has supported EU proposals aimed at reducing the risks caused by toxic and harmful substances, and has taken practical measures to meet EU chemical regulatory requirements, including REACH. Our company is a manufacturer of fluorinated fine chemicals, involved in the production of electronic fluorination solutions, mainly including hexafluoropropylene oligomers, hydrofluoroethers, and other products. As a composite raw material, it is supplied to enterprises for precision instruments, electronic etching, immersion cooling, and other fields. The company strictly follows environmental requirements for production activities, and the PFAS substances involved will not be discharged into the environment. Our company produces electronic fluoride liquid products that do not belong to the chemicals listed in the "Hazardous Chemicals Catalogue" (2015 version). After testing by Zhongke Testing Technology Services (Jiaxing) Co., Ltd., the ODP value is 0 (according to the technical requirements of Environmental Records, ozone depleting room substitute HJ/T225-2005), and the GWP value is 120 (according to Climate Change 2013-IPCC (100th year)). Data centers are the backbone of communication in today's world, and air-cooling and cooling these powerful servers requires expensive costs, consumes a large amount of electricity, and is detrimental to the environment and economic budget. Immersion liquid cooling using electronic fluoride solution can significantly reduce energy consumption costs, while increasing server density and reducing data center size. Semiconductor manufacturing requires high precision, and small temperature fluctuations may have a significant impact on yield. Compared with traditional coolants, fluoride solution has a wider operating temperature and requires less maintenance. Even if there is a leak, it will not damage electronic devices or chips. Due to the characteristics of electronic fluorinated liquids, many downstream applications cannot find products with the same effect to replace them. If forcibly prohibited, it will inevitably bring huge economic losses and the regression of high-end industries.