Document eNbyygOvyNwxXjpYZepzR874

Danfoss contribution for the public consultation on the proposed restriction of PFAS under REACH Summary On 13th January 2023, the five National REACH Authorities from Norway, Denmark, Germany, the Netherlands, and Sweden officially submitted a PFAS Restriction Proposal to ECHA. The restriction proposal, including a very broad definition PFAS, aims to restrict the manufacture, use, and placing on the market of PFAS across the EU. This would include most F-gases, as well as fluoropolymers. On 22nd March 2023, ECHA opened a six months' Public Consultation. Danfoss acknowledges the serious concerns about PFAS in the environment and wants through this reply to give valuable data to the ECHA responsible committees on its specific scope. Danfoss is a global leading manufacturer of a large variety of components and solutions which are pivotal in the modern society and addresses the mega trends embedded in the UN sustainability goals. Danfoss heritage and future is the core in energy supply especially heating and cooling, food supply based on the cold chain and, in general, energy efficiency of electrical motors and electrical vehicles. Furthermore, Danfoss is the global leader of components for the hydraulic appliances use for construction and machinery in agriculture sectors, which are undergoing major redesign for electrification and reduced climate impact. At Danfoss, we take our responsibility to provide safe and sustainable solutions very seriously and we are committed to delivering products that meet the highest standards of quality and safety. We strongly support the overall aim of REACH to improve the public health as well as the protection of the environment, and we acknowledge the need for appropriate restriction of PFAS substances. However, the restriction proposal in its current form will have a severe impact on European industrial production, products, markets, and competitiveness. To timely succeed in reaching the objectives of a PFAS restriction we recommend the following: Danfoss uses a wide span of PFAS-containing materials - especially fluoropolymers - in the majority of our products. To replace these materials will require a major conceptual redesign including testing, requalification and recertification. We strongly recommend taking into consideration this time-consuming transition by granting derogations for fluoropolymers with at least 12 years' validity. We suggest that a review clause is implemented to ensure updated and technology aligned derogations. We also ask for derogations on the use of F-gases as the breakdown products of these gases have no health concerns. Furthermore, they are regulated under the F-gas Regulation. We strongly encourage to consider correlating the proposed restriction of PFAS under REACH with already existing and/or upcoming regulations in order to mitigate the risk of PFAS exposure to the environment at end-of-life. We are concerned about the ability to enforce a very broad PFAS restriction and the risk of noncompliant products entering the market at the expense of compliant European industry. Use of PFAS in Danfoss Danfoss delivers an extensive range of products and solutions across our business segments: Danfoss Climate Solutions, Danfoss Power Solutions and Danfoss Power Electronics and Drives. Page 1 of 11 Danfoss uses a wide span of PFAS materials - especially fluoropolymers - in the majority of our products. Our mechanical products generally operate at high pressures and at a large temperature span. The components in general are part of systems containing operating fluids - e.g. refrigerants, oil, or water. Those systems inherently need to be tight for reasons relating to environment, safety, or energy efficiency. Fluoropolymers are outstanding materials ensuring low friction and tightness due to their strength and chemical durability and are seen as critical design parts. Danfoss Climate Solutions Danfoss Climate Solutions is the leading global supplier of components within the HVACR sector. Main sectors in which our products are used include: 1. Cold chain 2. Air conditioning 3. Heat pumps 4. Process cooling 5. Hydronic heating flows in buildings 6. District energy In general, the sectors account for 60% of final energy use and serve basic demand within food supply and necessary wellbeing like heating. Products in the vapour compression process The bullets 1-4 above relate to the vapor compression process, where energy is moved from a cold volume to a warmer volume. Figure 1: Basic principle of vapor compression system comprising the energy flows and the basic components. The system relies on a `refrigerant' fluid, which for some types - the F-gases called HFCs or HFOs - are classified as PFASs as well as their breakdown products known as TFA. Refrigerants can also be non-PFAS Page 2 of 11 substances, e.g., naturally occurring gases like CO2, ammonia, or propane. Danfoss delivers full product programs for natural refrigerants as well as for F-gases. The main reason for using F-gases is safety. Safety is a concern if the gases are toxic or flammable and usage is regulated through complex safety standards. Not all F-gases are PFAS-classified as they break down to HF (no CF3 part). Some of the PFAS-classified HFOs have very small TFA yields from breakdown, while others have 100 % TFA formation. Danfoss uses minor amounts of F-gases directly, but the components are designed to contain F-gases in the use phase. It is important not to exclude all F-gases. The newly applied HFO gases like R1234ze and R1336zd have negligible amount of TFA formation [Environmental Effects of Stratospheric Ozone Depletion, UV Radiation, and Interactions with Climate Change ; UNEP 2022 Assessment Report of the Environmental Effects Assessment Panel], and, combined with the questionable negative impact, it is overdone and harmful to the green transition to exclude all F-gases in one basket. Figure 2: Compressor (left) and solenoid valve (right) exemplifying various critical fluoropolymer elements. Fluoropolymers: The components comprising the vapor compression systems for refrigeration, air conditioning and heat pumps are based on at least 40 years of incremental design improvements, where the fluoropolymers are regarded as critical materials. The temperature demands inside the systems are dynamically varying from -50C to 150C, while pressures are ranging from 1 to 150 bar. The industrial usage of heat pumps has just started and will imply more extreme conditions on temperatures, which means the need for durable strong fluoropolymer materials. The containment of refrigerants is a major factor, but accidents can happen. Safety is ensured by numerous standards constraining system location, human occupation and the charge size of specific refrigerants. Systems losing their refrigerant charge over time will underperform on energy efficiency. Leakage and tightness demands are all top priority issues in the industry. Reliable (long-term) gaskets and sealings are necessary as many systems are not `hermetically sealed'. PFAS materials-fluoropolymers-are used for these applications (see table). Majority of valves are containing these sealings and gaskets. Page 3 of 11 The market using vapor compression systems is enormous. According to the IEA about 10% of the global electricity production is consumed by air conditioners and similar numbers can be estimated for food refrigeration. That percentage number will increase with the green transition towards heat pumps and the increasing food cold chain. The green transition will demand up to 60 million new heat pumps by 2030 [`Europe's Leap to Heat Pumps' ; European Climate Foundation ]. A compressor uses bearings, sealings and gaskets based on fluoropolymers. Valves for controlling refrigerant flows are using the fluoropolymers for the same reasons. Besides the mechanical components, temperature sensors are necessary for avoiding burnouts of the compressor. Likely, the compressors will not last a week without those temperaturedetecting components. To avoid usage of fluoropolymers in compressors and mechanical controls is a problem without solutions for the present state of materials if efficiencies and safety should be maintained at high levels. Key Key products Key properties/requirements in components relation to the materials used Bearings Compressors Lifetime / reliability Gaskets Expansion valves High to low temperature Seals Heat exchangers performance Seal rings Solenoid valves Lubricant resistance Coatings Ball valves Dimensional stability Bushings Service valves Sight glasses Pressure regulating valves Non-return valves Table 1: List of fluoropolymers used in Danfoss vapor compression components. PFAS materials PTFE FEPM PFA FEP FKM PVDF PFPE FEPM Hydronic heating flows in buildings and district energy In hydronic heating systems, water is used to move heat from heat sources to where it is needed, e.g., from heat pumps or boilers to radiators, heating mats, etc., while district energy systems are networks of hot and cold-water pipes used to efficiently heat-e.g. using waste heat-and cool buildings and using less energy than if the individual buildings were to each have their own boilers and chillers. The safety of transport of water through pipes in such systems are highly dependent on the stability and tightness of components to be energy-efficient; hence, temperature and pressure are of utmost importance. Components containing PFAS in sealings and bearings are an essential part of securing this. Heating and cooling of buildings represent 40% of global energy demand. Balancing and control valves ensure energy-efficient and reliable operation of such systems (district heating, HVAC, residential heating) by distributing energy from sources to consumers. The design life of such systems is 15-20 years. We cannot offer products enabling comparable system efficiency and lifetime without the use of PFAS materials. Page 4 of 11 PTFE coated o-rings PTFE guide/scraper Figure 2: Pressure flow controllers ABQM (left) and AFQM (right) pressure-independent control valves exemplifying various critical fluoropolymer elements in hydronic heating and district energy system components. Figure 3: Ball valve for district heating and manual balancing ball valve (LENO) with critical fluoropolymer component. Page 5 of 11 Figure 4: Radiator thermostat exemplifying critical fluoropolymer element. Fluoropolymers: The components comprising the control valves and pressure regulators for heating and district heating are based on at least 40 years of incremental design improvements, where the fluoropolymers are regarded as critical materials due to high operating demands. The temperature demands inside the systems are dynamically varying from -50C to 180C, while pressures range from 1 to 40 bar and up. With the spreading of district heating there is an increasing need for more reliable control elements with lower hysteresis, i.e., increasing the need for durable, strong fluoropolymer materials. 1) Safety and 2) energy efficiency are major factors of the products with specific attention to properties of tightness, dimensional stability, wear resistance, and low friction. Re. 1), safety is directly related to unintended leakage of high-temperature liquid or gas to the surroundings as a potential danger. Reliable guide gaskets and sealings are necessary to prevent these risks. To ensure 2) energy-efficient systems, low friction is critical, as friction in valves, especially in pressure regulators, causes increasing hysteresis, meaning decreased regulation performance. PFAS materials-fluoropolymers-are used for these applications (see table). The majority of valves contain these guides and coated o-rings. Key components Bushings Guides/scrapers Coated o-rings Grease Key products Pressure regulators Pressure-independent control valves Control valves Pressure regulating valves Key properties/requirements in relation to the materials used Lifetime/reliability High to low temperature performance Dimensional stability PFAS materials PTFE Lubricant Gas filled self-acting radiator thermostats Secure acceptable handle torque PTFE-based dry-film lubricant Page 6 of 11 Seal rings Ball valves Lifetime/reliability Washer High to low-temperature Greases performance Lubricant resistance Dimensional stability Table 2: List of fluoropolymers used in Danfoss hydronic heating and district heating. PTFE PTFE+C (compound) Compressors and intelligent controls of the systems all relate to PFAS-based electronics. This will be covered under the section from Danfoss Power Electronics and Drives below. Danfoss Power Solutions Danfoss Power Solutions is the global leader in mobile and industrial hydraulics, fluid conveyance, electrification, and software. The business segment designs, manufactures, and provides a complete range of engineered components and integrated solutions to various industries in: off-highway on-highway marine offshore, and industrial. The product portfolio includes motors, pumps, valves, steering components and systems, electronic controls, electrical systems, PLUS+1 software, former Eaton Hydraulics products, and hydrostatic drive systems. Figure 3: Example - Relief valve with PTFE and FKM Page 7 of 11 Figure 4: Example - Hydrostatic variable displacement axial piston motor with PTFE and FKM Fluoropolymers: The use of PFAS substances in indispensable components such as seals is essential for the functionality of the products, especially in safety-related areas where resistance to high temperatures, pressure, abrasion, and to other extreme working conditions are required. PFAS-containing seals and coatings play an important role in many product lines that convey hydraulic fluids (e.g. pumps, hoses, etc.). These components are supplied individually or as advance solutions for integration into final machine applications with no direct exposure to the environment. The identified essential use of fluoropolymers in seals, coatings, and bushings is a stopgap situation in which replacements are actively sought. The essential use concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by new technologies and be targeted by innovation toward alternatives. Unfortunately, fluoropolymers are the only comparable alternative to comply with a variety of official safety regulations applicable to Danfoss Power Solutions today. Key Key products Key Properties/requirements in components relation to the materials used Seals Axial piston pumps & motors Resistance to physical effects Seal rings Gear pumps & motors (e.g. heat, pressure, resistance, Coatings Steering abrasion, etc.) Bushings Valves Safety in high-power and Electronic Controls extreme work conditions Hoses Table 2: List of fluoropolymers used in Danfoss Power Solutions PFAS Materials FKM PTFE Page 8 of 11 Danfoss Power Electronics and Drives As a result of the recent partnership between Danfoss Power Electronics and Drives and SEMIKRONDanfoss, we have become a global technology leader in power electronics and AC/DC and DC/DC power conversion. Our innovative solutions for electric motors, automotive, industrial, and renewable applications enable the world to utilize energy more efficiently and sustainably, significantly reducing overall CO2 emissions. With the world's largest portfolio of power converters, VLT drives, and VACON drives, we offer a comprehensive range of semiconductor devices, power modules, stacks, and systems. As the world goes electric, our technologies are more relevant than ever, and we are committed to helping our customers meet one of the biggest challenges of our time. Low-voltage single- and three-phase drives Medium-voltage drives Motion drives Low-harmonic drives Intelligent drives Decentral drives Semiconductor/chip production. For the applications we are serving industries like HVAC (Heating, Ventilation, and Air Conditioning), Water - Wastewater treatments, Food & Beverage industries, Heavy industries, Textiles, Automotive, Electrification & Marine. Figure 5: Example - Frequency Converter with PTFE-containing components Page 9 of 11 Fluoropolymers: The use of PFAS substances in components such as relays, soft starters, power modules, capacitors, LCL filters, conformal coating PCBAs (Printed Circuit Boards Assembly), cables, batteries, semiconductors, chip, and charging resistors is essential for the functionality of Danfoss Drives products. These components are essential for safety-related areas where resistance to elevated temperatures, pressure, abrasion, and other extreme conditions are required. Semiconductor parts, cables, and coatings play a critical role in ensuring the reliability and performance of Danfoss Drives products - especially in heavy industry applications. While some of these components may contain PFAS, they are supplied individually or as advanced solutions for integration into final machine applications, with no direct exposure to the environment. These components are essential to the success of the European Green Deal, as they enable the creation of essential technologies like PV systems and wind turbines. While fluoropolymers are currently the only comparable alternative for complying with official safety regulations applicable to Danfoss Drives, the company actively seeks replacements for identified essential uses of PFAS. The essential use concept expects that PFAS uses considered essential today should be continually reviewed for potential removal or replacement by innovative technologies and targeted by innovation towards alternatives. Key components Key products Key Properties/requirements PFAS Materials in relation to the materials used Power module Relays Capacitors LCL filters Conformal coating in PCBAs Cables Batteries Charging resistor O-Rings Semiconductors Computer chips Power modules Soft starter Variety range of drives Electric converters Safety in high-power and extreme work conditions Resistance to physical effects (e.g. heat, pressure, resistance, abrasion, etc.) PTFE ETFE Potassium nonafluoro-1butanesulfonate Methyl perfluoroisobutyl ether Methyl nonafluorobutyl ether PFA (perfluoroalkoxy) PVDF (polyvinylidenfluorid) ECTFE (ethylenchlortrifluorethylen) PFPE (perfluorpolyether) Table 3: List of fluoropolymers used in Danfoss Power Electronics and Drives. Conclusion At Danfoss, we take our responsibility to provide safe and sustainable solutions very seriously and we are committed to delivering products that meet the highest standards of quality and safety. We strongly support the overall aim of REACH to improve the public health as well as the protection of the environment, and we acknowledge the need for appropriate restriction of PFAS substances. Page 10 of 11 Derogations Danfoss' current product portfolio has been developed and improved over decades and as described in previous sections, different types of PFAS, primarily fluoropolymers such as PTFE, FKM and PFA are key for the performance and lifetime of our products. There are currently no known, suitable alternatives to our PFAS applications, and substitution of PFAS from our products would require a complete re-design of thousands of parts in close collaboration with our complex, international supply chain - a very timeconsuming, iterative process involving several rounds of testing, re-qualification and, in many cases, recertification of the new designs. The validity periods of the derogations currently proposed vary between 4 and 12 years, and this is far from enough time for industry to make proper redesigns. We strongly recommend taking into consideration the trial-and-error nature of the redesign phase by granting derogations for fluoropolymers with at least 12 years' validity. We suggest that a review clause is implemented to ensure updated and technology aligned derogations. We also ask for derogations on the use of F-gases. The scientific evidence of the harmfulness of the breakdown products of F-gases seems very doubtful based on the official main institutions as the UN expert panels. Furthermore there is a tremendously big span of the TFA amounts depending on the type of the Fgases. Very important refrigerants like R1234ze, R1233zd(E), R1336mzz(Z) are negligible in their TFA formation and it will not make sense to ban them. Correlation with other regulations The main concern for all PFAS in scope of the REACH restriction proposal is their very high persistence and consequently their potential accumulation in the environment and in living organisms. We believe that the risk of exposure of PFAS to the environment can to a large extent be mitigated by ensuring well-established processes for handling products at end-of-life. We therefore strongly encourage policy-makers to consider how the proposed restriction of PFAS under REACH can be correlated with already existing and/or upcoming regulations such as the Waste Electrical and Electronic Equipment (WEEE) Directive (2012/19/EU) and the Ecodesign for Sustainable Products Regulation. Refrigerants (F-gases) should be controlled through the EU F-gas regulation through delegated acts ensuring a proper handling of system in operation and the coherence to the WEEE Directive. Enforcement At Danfoss we are concerned about the authorities' ability to enforce a very broad PFAS restriction covering more than 10.000 substances - in particular, we see the lack of laboratory capacity and suitable analytical methods as limiting factors for proper enforcement. Inefficient enforcement will make it easy for `free riders' to place non-compliant products on the European market, thereby compromising the competitiveness of European industry. Page 11 of 11