Document bOg02MxkmMx5dB9GmoypEqJ6Z

EXCHANGE WITH THE BRC PROPOSED PFAS REACH RESTRICTION Fluoropolymers Product Group 7 December 2021 The Fluoropolymers Product Group (FPG) The Fluoropolymers Product Group represents Europe's leading fluoropolymer producers and experts. As the voice of the industry across Europe, the Fluoropolymers Product Group advocates for a balanced regulatory environment based on scientific facts to ensure that European industries remain competitive and sustainable. Part of PlasticsEurope, the group's members are 3M, AGC, Arkema, Chemours, Daikin Chemicals, DuPont, Gujarat Fluorochemicals, Honeywell, W. L. Gore & Associates, and Solvay. Some facts Fluoropolymers are irreplaceable in many uses without reliable alternatives. Fluoropolymers are different to other PFAS. Fluoropolymers are characterized by their high stability. They do not degrade in the environment when used as intended. The main fluoropolymers meet the OECD Polymers of Low Concern (PLC) criteria. An industry with responsible manufacturing at its core. WHY FLUOROPOLYMERS ARE CRITICAL TO BELGIAN COMPETITIVENESS AND INNOVATION ? Irreplaceable fluoropolymers ONE-OF-A-KIND POLYMERS Fluoropolymers are unique chemical substances used across numerous technologies, industrial processes and everyday applications from the aviation industry to transportation, medical devices and energy production and technical apparel. With a unique set of properties, they are durable, chemically inert and mechanically strong. Fluorpolymers help to keep us safe and enable innovation. WHY DO WE USE FLUOROPOLYMERS? Ensure safety, reliability and performance across a variety of sectors Low-risk polymer for human health & environment Help drive EU industry competitiveness and innovation Critical to numerous technologies enabling the Green Deal, reducing waste and emissions Few, if any, viable alternatives Uses of fluoropolymers Promoting sustainable and smart mobility through electric vehicles. Extending the lifespan of medical equipment and devices, reducing the need for replacements, risk of failure and cross infections. Enabling a data driven economy though the manufacturing of microprocessors and semi-conductors. Facilitating the Renovation Wave and the construction of energy efficient buildings. Driving innovation and helping decarbonise the aviation industry. Assisting the chemicals industry in preventing corrosion in harsh environments. Ensuring food and pharmaceuticals remain fresh and uncontaminated. Protecting workers in professional protective and high-performance clothing. Fluoropolymers in Belgium Cutting-edge Belgium economic sectors including: The chemical industry The pharmaceutical industry The machinery and equipment The manufacture of transport equipment rely on the unique set of properties unobtainable with other polymers and critical for their growth and innovation. HOW ARE FLUOROPOLYMERS DIFFERENT TO OTHER PFAS? ---- * PLAST CS EUROPE G PFAS have many different properties SIMILARITIES F C F 1 fully fluorinated carbon or CF2-CF2-CF2or ... GASES LIQUIDS SOLIDS DIFFERENCES Stability Toxicity seconds thousands of years low high Mobility Size Insoluble/ Non-volatile Highly mobile MW less than 1,000 Daltons MW multimillion Daltons Date Fluoropolymers are different - Example of PTFE * . PLASTICS EUROPE Enabling a sustainable future Fluoropolymers Product Group l . Polymer .C0m pc Won 1.4%,01,, 1,MWD wt% a igorner Elect r1C. I Charge Reactive FunLtIc nal G GroupsFG) Polymer Suliry Therma15ml:tiller Aattic Stability Blotk Stability FunCtional Group Equivalent Weight IIFGEW) Low MW LeactialDles 9 Waterit pl cl SOIL bit i Octan'0/ate Pa rtition SI2e Per-and PofluoroalI Substances -- -- ' , PTFE Key Attributes / / r / / -0 Small -0 Bloava liable -0 mister"t l'hip0lle O 2021 W L. Gore a.Associates The challenge Five members states are looking for an universal restriction that would include all PFAS. Two main issues GROUPING "Although fluoropolymers can be categorized as PFAS based on their structure, their properties are distinctly different from other PFAS substances. This broad and diverse family of substances should not be grouped all together". ESSENTIAL USES "Essential use should not be used as a tool for EU chemicals regulation until a concept has been sufficiently debated, challenged, assessed and approved by stakeholders". HELPING THE EU REGULATORS TO TAKE DECISIONS BASED ON FACTS AND EVIDENCE RMOA key takeaways EU PlasticsEurope Fluoropolymers Product Group GREEN DEAL A full PFAS REACH restriction would put at risk key applications that are necessary to ensure competitiveness of the EU industry, as well as the very ambitious goals set forward by the European Green Deal. _+ PlasticsEurope Fluoropolymers Product Group FPs, along with their relevant monomers, should be derogated from the PFAS REACH restriction. The use of polymerization aids should also be allowed by regulators to enable continued EU manufacture of FPs. PFA REACH RE RICTION PLASTICS EUROPE Enabling a sustainable future Fluoropolymers Product Group PlasticsEurope Fluoropolymers Product Group IND STRY COMMITMENT The industry should commit to efficiently address the concerns related to the manufacture and purity of FP products and pursue R&D programs for the advancement of technologies allowing for the replacement of PFAS-based polymerization aids and their implementation when proven technically feasible, environmentally sound and viable. PlasticsEurope Fluoropolymers Product Group EU legislation dealing with industrial emissions and waste should be reviewed and updated to ensure that adequate technical controls are put in place to minimise any risk EU LEGISLATION PlasticsEurope Fluoropolymers Product Group COMPETITIVENESS It is expected that any regulatory action that may lead to limiting the market access for fluoropolymers could result in the complete relocation of this industry outside the EU. fluotopolymers.pIasticseurope,org Development of data and evidence on fluoropolymers 01 RESPONSIBLE MANUFACTURING 03 END OF LIFE 02 USE PHASE PLC PROJECT Fluoropolymers Product Group @plasticseurope.org Website https://fluoropolymers.plasticseurope.org LinkedIn https://www.linkedin.com/company/fluoropolyme rs-product-group