Document bBGKg11V7kqjXpwOmXLDmMRO

From: To: Cc: Subject: Date: Attachments: Dear --- On site intermediates exemptions under the EU REACH and POP Regulations 08 July 2020 15:13:06 iroageQQJ 0if Dear I hope this email finds you both well during these interesting times. As PFOA recently moved from the REACH Restriction to the POP Regulation, I am contacting you for an advice regarding the 'on site intermediates': Am I correct in understanding that under the POP Regulation the on-site intermediates are not 'automatically' exempted, as they were under the REACH Article 68(1)(2) (= "on site isolated intermediates are excluded from the introduction and amendment of restrictions"), but we would need to ask for a separate exemption for 'closed-system site limited intermediate'(Article 4 (3) of the POP Regulation(EU) 2019/1021)? We noted there is a transition period until 3 December 2020 for PFOA compounds that are currently subject to a derogation from the Annex XVII restriction(Recital 9). Would that extension apply also to on-side intermediate uses of PFOA compounds? Lastly, I would also like to understand better the conditions and sequence(+ timing) for requesting an exemption under Article 4(3) of the POP Regulation. It is not clear from that Article whether and to what extent the Commission must intervene in adopting a delegated act with such exemption, before or after notification to the POP secretariat. I would appreciate your feedback on these three questions, as 3M Dyneon plant in Germany might need to request an exemption for closed-system site-limited intermediates under Article 4(3) . I can be reached on my mobile phone ) if you would like to discuss further by phone. Thank you very much & Best regards ----