Document brjM32oM52pN6zOY7nkEmgDZ

EuMBC IMPLICATIONS OF THE PFAS RESTRICTION FOR EUROPEAN PLASTICS MASTERBATCHERS, COMPOUNDERS AND CONVERTERS : PRELIMINARY COMMENT Brussels, 13 July 2023 EuPC is the leading EU-level Trade Association, based in Brussels, representing European Plastics Converters. EuPC now totals about 51 European Plastics Converting national and European industry associations, it represents close to 50,000 companies, producing over 50 million tonnes ofplastic products every year. The European plastics industry makes a significant contribution to the welfare in Europe by enabling innovation, creating quality of life to citizens and facilitating resource efficiency and climate protection. More than 1.6 million people are working in about 50,000 companies (mainly small and medium sized companies in the converting sector) to create a turnover in excess of 280 billion per year EuMBC (European Masterbatchers and Compounders) is an association representing more than 70% of the masterbatches and compounds manufactured in Europe. EuMBC is a sector group of EuPC (European Plastics Converters). Plastics masterbatchers, compounders and converters rely on per- and poly-fluoroalkyl substances (PFAS) for a diverse range of applications. The current list of considered derogations is omitting many of the identified applications. We will at a later stage of the consultation submit more specific information on those applications and the basis for further derogations. We would first like to highlight some principle position that we would like to share : Fluoropolymers should not be covered in the proposed restriction on PFAS Fluoropolymers of high molecular weight components meeting the OECD definition as polymer of low concern should not be considered in this restriction. Those represent by far the major use in the plastics industry. Substances used solely in industrial settings should be derogated with appropriate risk management measures at manufacturing plant level if appropriate. Uses In a recent survey we identified more than 44 applications not having readily available alternatives, the list not being exhaustive. For more than half of the respondent companies, their PFAS-related production represents 50% or more of their operations. Functions Chemical resistance, lubrication, polymer coatings, processing aids-- including mold release, resistance to oil/water, surface tension reduction, and additives in plastics. Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 41 24 Fax: +32 (0)2 732 42 18 @eupc.org www.plasticsconverters.eu Page 1 of 4 EuMBC Field of Application of : fluoropolymers and elastomers Field of application Automotive, transport, aerospace : plastic energy systems building and construction Safe conveyance and dosage of chemical media in manufacturing plants', transport and distribution facilities conveyor systems drinking water electronics & semiconductors Description (PTFE, FMACP, FVMQ, (VDF, HFP) FKM, TFE, FEP): component of Adblue fuel delivery module and fuel systems. (THV) fuel system seals. (FPE) wire for Adblue heating. (other) fuel delivery modules. (VDF, HFP) fuel system seals (VDF and FHP in FKM). (PTFE and PVDF): window profile films, glass fabric coatings (PTFE/FEP); PVC-coated polyester fabric with PVDF or THV lacquer; PVDF-covered mesh fabric; glass fabric coatings (PTFE); polymer processing additives; polymeric compression sleeves in underfloor heating (PVDF); lubricant coating for PE-X pipe extrusion; sealings for production machines; linear bearings; construction site machines; processing aid fordrainage pipes and fittings. (PVDF and ECTFE) rigid plastic pipes, fittings and valves and controls/meters. (PTFE) manufacturing equipment. (FKM and FFKM) sealings in piping systems. coating/mold release in manufacturing of plastic products. glass fabric coated with PTFE and FEP finish; slide rail. (PTFE and PVDF): multilayer pipes; fittings (PVDF); compression sleeves in sanitary piping system (PVDF); (PTFE): sealing rings; pipes, fittings. (PVDF): valves, pipes and fittings for ultra-pure water systems (UPW). Potential derogation identified in annex XV dossier Yes No No No No Yes -- for PFAS used in the production of semiconductors, except PFAS used in the equipment used to produce semiconductors. Conveyance of chemicals used for many applications fields: energy, semiconductor, food, life sciences, metal pickling, ... Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 41 24 Fax: +32 (0)2 732 42 18 @eupc.org www.plasticsconverters.eu Page 2 of 4 EuMBC food contact materials & packaging lubrication for injected molded modules (PFFE); processing aids for plastic films from masterbatch based on PTFE PE-TFE and PVDF/HFP. Derogation 5ee does not apply to other electronics No furniture & automotive (PVDF): artificial leather; polyester fabric with PVC coating and PVDF lacquer (for durability and soiling resistance); polyester fabric with PVC coating (water resistance). lubricants (PTFE): industrial fluoropolymer lubricant coating used for production tooling. marine polyester fabric with PVC coating and PVDF or THV coating. medical devices pen injector; Catheters, drug powder inhalers; process fluid connectors; and packaging (PCTFE) petroleum (oil & gas) & mining multilayer plastic pipes and all other piping components (fittings, valves, gaskets/membranes) for the conveyance of hydrocarbons. No No No Yes Yes, but only for fluoropolymers renewable (FKM): O-rings, seals and joints. Yes energy, oil & gas (Ethene, 1,1,2,2-tetrafluoro-, homopolymer): self- thermoplastic lubricant thermoplastics compound for engineering No compounds applications. Life Sciences PTFE Labware (Beakers, Funnels, Spatulas, Stirring (Pharmaceutical, Bars, Scoops, Bottles, Fittings, Clamps, Valves. Biochemistry, Connectors, Racks, HPLC Safety Caps, HPLC Liquid Research) Waste Handling, Joints, HPLC Syringes, LC/GC No Microsyringes). PFA Labware (Bottles, Fittings, Beakers, Containers, Measuring Cylinders). Field of Application of Low Molecular Weight PFAS Field of application Description building and construction (PFHxA): Polyester fabric with PVC coating. Potential derogation identified in annex XV dossier No Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 41 24 Fax: +32 (0)2 732 42 18 @eupc.org www.plasticsconverters.eu Page 3 of 4 furniture (PFHxA): Polyester fabric with PVC coating. marine (PFHxA): Polyester fabric with PVC coating. membranes and waterproofing (PFHxA): Polyester fabric with PVC coating. EuMBC No No No Substances in Scope The substances in use mainly include PTFE, with one-quarter of the reported uses; and PVDF, with another quarter. Implications and Challenges A substantial number of applications lack viable alternatives, raising concerns about their operations and ability to meet market demands. In some cases, the industry could meet the restriction, but provided additional transition time. Transition period We cannot provide required granularity in this summarized statement for specific transition periods and further input will be made either by EuPC, EuPC subsectors or individual companies. Whilst there would be variation across applications, we would like to highlight based on the received feedback that typical timescale of the R&D process - from discovery to commercial upscaling - is at least 10 years for critical applications. EUPC is therefore asking for allowing sufficient transition periods to look for adequate substitutes in case specific applications would not be exempted from this restriction based because they are based on fluoropolymers, used in industrial settings, their use being essential or emissions would be limited combined with disproportionate economic impact (proportionality). Contact : Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 41 24 Fax: +32 (0)2 732 42 18 @eupc.org www.plasticsconverters.eu Page 4 of 4