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RED FLAG .I a GUJARAT RUOROCHEMICALS Ad-Hoc open BCR Meeting PFAS Restriction 28 March 2023 Fluoropolymers are safe: different from other PFAS Fluoropolymers are not harmful and pose no significant risk to human health or the environment Distinct subset of PFAS, with unique toxicological properties: Not soluble in water Fulfil the criteria established by the Organization for Economic Cooperation and Development (OECD) to be regarded as Polymers of Low Concern Fluoropolymers are safe: manufacturing & EOL During manufacturing: Today, majority of FPLs can be manufactured without the use of PFAS of concern through use of non-fluorinated polymerization aids. Advanced abatement technologies significantly reduce emissions during manufacturing. At end of life: Incineration: thermally decomposed in incineration facilities. [RIVM, GORE, GFL] no significant PFAS generation at temperatures > 850C (Municipal WI) Mineralisation at temperatures > 1100C (Industrial WI) Landfills: FPL waste is inert, non-toxic and not mobile. No threat to human health or environment [GORE] Fluoropolymers are indispensable FPLs are an integral building block of the modern world with unique properties that are essential for a wide range of societally beneficial applications: Renewable energy Electric vehicles Semiconductors Chemical process Industry Transport Food and water treatment Pharmaceutical and medical devices Fluoropolymers are mostly used to keep us safe at the performance we need Fluoropolymers are essential for the success of the energy transition and on-shoring of key technologies Fluoropolymers are very stable - key to circularity To meet climate targets, the EU needs to move away from the linear economy CIRCULAR ECONOMY DEFINITION (WBCSD) The circular economy is an economic model that is regenerative by design. The goal is to retain the value of the circulating resources, products, parts and materials by creating a system with innovative business models that allow for renewability, long life, optimal (re)use, refurbishment, remanufacturing, recycling and biodegradation. Ellen MacArthur Foundation circular economy principles: Design out waste and pollution Keep products and materials in use Regenerate natural Concluding... Fluoropolymers: Are safe and very different from small molecule PFAS Do not pose an unacceptable risk to humans nor the environment over their life Are paramount to functioning of modern society across the globe Key to reaching climate goals Should be exempted from REACH regulation Thank you