Document gBR0oBDbXbY1D161jdB1y2yG

Report summary construction products 1 Contents 1. Uses / Applications.......................................................................................................................... 3 2. Main PFAS ........................................................................................................................................... 4 3. Manufacturing & Market price + market development ..................................................................... 8 3.1 Market price.................................................................................................................................. 8 3.2 Market development .................................................................................................................... 8 3.3 Production sites ............................................................................................................................ 9 4. Emissions product manufacturing and product use ........................................................................... 9 4.1 General.......................................................................................................................................... 9 4.2 Emissions baseline year ................................................................................................................ 9 4.3 Emission estimates time-series...................................................................................................10 4.4 Overview of the emissions..........................................................................................................11 4.5 Emissions product manufacturing .............................................................................................. 13 4.6 Emissions product use ................................................................................................................ 15 5. Exposure (workers, consumers)........................................................................................................16 5.1 Workers.......................................................................................................................................16 5.2 Consumers .................................................................................................................................. 17 5.3 Indirect exposure of humans via the environment .................................................................... 17 6. General discussion on emissions and exposure................................................................................18 7. Alternatives ....................................................................................................................................... 18 8. Economic impacts in case of a full PFAS ban .................................................................................... 21 8.1 Economic impacts ....................................................................................................................... 21 8.2 Environmental impacts ............................................................................................................... 21 8.3 Social impacts..............................................................................................................................21 8.4 Other impacts ............................................................................................................................. 21 9. Uncertainties.....................................................................................................................................22 2 1. Uses / Applications The uses, sub-uses and functions of PFAS identified by Glge et al. (2020)1 act as a starting point for categorisation of PFAS uses in construction products. These uses have therefore been grouped into three tiers of hierarchy: Parent level Sub-level Application specific level. At parent level, two categories are defined: Coatings: This covers PFAS containing mixtures applied to a pre-existing article. Products: This covers the use of PFAS or PFAS containing mixtures used within a complete product (article). In Table 1 the identified uses are given. Table 1. Identified uses of PFAS in construction products. Parent level Sub-level Construction Products (products) Building and construction Definition: This category covers products that already contain PFAS to provide a specific function. Examples may include PTFE, PVC, other plastics, and cabling. The distinction is that the article comes as a complete item that already contains PFAS. Application specific level Architectural membranes e.g. in roofs, greenhouses, flexible solar panels Windows and window frames (containing e.g. ETFE & PTFE) (e.g. greenhouses) Cement additives2 Cable and wire insulation, gasket hoses Skidways for constructions (e.g. PTFE) Bridge bearings (e.g. PTFE) Sealants and adhesives Pipes, pumps, fittings, and liners Household application Processing aids Pipe linings Working fluid/vacuum pump oils PTFE tape (also PTFE tape for professional applications like for drinking water and compressed air systems) DIY sealant and adhesive products Processing aid in the manufacture of construction products 1 Glge, Juliane & Scheringer, Martin & Cousins, Ian & DeWitt, Jamie & Goldenman, Gretta & Herzke, Dorte & Lohmann, Rainer & Ng, Carla & Trier, Xenia & Wang, Zhanyun. (2020). An overview of the uses of per- and polyfluoroalkyl substances (PFAS). 10.31224/osf.io/2eqac. 2This use was identified by Glge et al. (2020) but note that the cement industry suggested during the consultation that they are not aware of intentional use of PFAS in their industry. 3 Construction Products (surface coatings) Definition: This category covers the use of coatings (including sprays, paints, mixtures and fully PFAS based thin film technologies) added to pre-existing articles at the time of use or at the end of production as a finishing process to give the component desired water, oil and dirt repellent properties. It also includes the addition of PFAS within other coating mixtures (such as paints) as a surfactant/wetting agent/levelling agent. Wood industry sector Glass industry sector Metal industry sector Construction sector plastics Outdoor electrical components Stone, concrete, and tiles - Semiprofessional aftercare Coatings, paints, and varnishes Domestic / semiprofessional aftercare Coatings-paintings-varnishes Wood substrate Coatings-paintings-varnishes Resin for particleboard Surface treatment of glass Coatings-paint for metal protection Professional coatings for finishing step of plastics used in construction Surface coatings for wind turbine blades Surface coatings for solar panels Surface treatments DIY durable water repellent (DWR) impregnation Paints Coatings (glass, ceramic, and metal) Linoleum, laminated plastic floor 3 Aftermarket floor protection 2. Main PFAS Construction products (articles) 32 different PFAS species, both polymeric and non-polymeric were identified as being used within construction product applications in articles, according to stakeholder input during the Call for Evidence (CfE) and the targeted stakeholder consultation, as well as literature review. For the majority of cases, the CfE has yielded sufficient data to identify the substances used at the application-specific level (not shown to protect confidentiality) with a few exceptions. At the parent level (articles), Glge et al. (2020) estimated by volume approximately an even split between polymeric and non-polymeric PFAS in use. Construstion products (mixtures used as coatings) 57 different PFAS species were identified from the CfE and the targeted stakeholder consultation, as well as the literature review at the sub-level use category, as data on the more detailed applicationspecific level was less complete. For all uses except paints, only polymeric species were identified. 3This use was identified by Glge et al. (2020), but note that the flooring industry suggested that the only significant uses of PFAS in their industry have been phased out since the early 2000s. 4 2.1 Tonnages bands Based on SPIN Database (not specified per substance group) Based on the SPIN (Substances in Preparations in Nordic Countries) database, Glge et al. (2020) estimated that around 1,500 t of PFAS4 were used in building and construction in Sweden, Finland, Norway, and Denmark between 2000 and 2017. Additionally, a further 3,500 t of PFAS were used in paints and coatings for the same countries and timeframe. Extrapolating the tonnages yields an estimate of around 1,600 t of PFAS used in building and construction and 3,700 t of PFAS used in paints and coatings in the EEA per year on average. Information from various other sources It is noted that official statistics on production and trade (e.g., Eurostat Prodcom or Comext data) are not sufficiently detailed to identify PFAS-based construction products. As polymers are exempt from registration under REACH, and a lot of PFAS-based construction products are based on polymeric PFAS, tonnage bands from ECHA's database of registered substances are considered not useful. The CfE identifies approximately 20 non-polymeric PFAS substances in use, but with no tonnage data provided. Based on stakeholder consultation Table 2 shows an overview of the tonnages of PFAS manufactured or imported into the EEA, based on the CfE and targeted stakeholder consultation. 4 Note that the definition of PFAS used in Glge et al (2020) is largely consistent but not identical to the definition used for the present study. This may lead to differences in tonnages of PFAS identified in the uses in question. Glge et al (2020) focuses on polymeric PFAS with the -CF2- moiety and non-polymeric PFAS with the-CF2-CF2-moiety. This does not include non-polymeric substances that only contain a - CF3 or -CF2-moiety, with the exception of perfluoroalkylethers and per- and polyfluoroalkylether-based substances. For these two PFAS groups, substances with a -CF2OCF2- or -CF2OCFHCF2- moiety are also included. 5 Table 2. Total tonnages of PFAS manufactured or imported into the EEA for use in the construction sector, based on the CfE and targeted stakeholder consultation. PFAS PFAS in construction products manufactured in the EEA (tonnes) Mid-value of range PTFE EFTE PVDF PFA FEP Acrylate based side chain fluoropolymer FKM / FFKM THV HFP other non-polymeric PFAS 3,950 2,040 Confidential 75 Confidential 26.6 8 Confidential Confidential 6 Range 1,715 - 6,185 1,950 - 2,135 Confidential 65 - 85 Confidential 13 - 40 1.2 - 15 Confidential Confidential 1 - 12 Number of respondents providing data 9 4 2 3 2 4 5 1 1 12 PFAS in construction products imported into the EEA (tonnes) Mid-value of range 148 444 Confidential 5 Confidential - Range 60 - 235 398 - 490 Confidential Confidential - Number of respondents providing data 4 4 1 1 - Suppliers reported to manufacture/import PFAS containing construction products or PFAS for use in construction products Chemours, 3M, Trelleborg, HaloPolymers, AGC 3M, Membrana, Solvay Chemours, 3M, Arkema, Solvay 3M, Solvay Chemours, 3M Chemours, Daikin, Maflon, Wacker chemie AG - - - DuPont, Fluorocarbon, - - - 3M - - - No data 1 - - Solvay (PFPE, and sulfonic acids), Chemours (sulfonic acids), Gore (sulfonic acids + additives), Delta-seal (unclear - potentially resins), 3M (<C6 chemistry), Moeller (unknown - stone protection product), Confidential stakeholder ("C6 fluorosurfactant") 5 Note that for the emission scenarios a quantity for the imported amount of PVDF is calculated. 6 Based on time-series estimations Table 3 shows the estimated uses of different PFAS-species between 1990-2050. Note that, although some data was available, various assumptions were made to develop the estimates. Below the table more information can be found on the assumptions for the past and future usages. Table 3. Tonnages used in the EU for construction products. Group 1990 PTFE (Granular) PTFE (Micropowder) EFTE PVDF Other Fluoropolymers Non-polymeric PFAS (all substances) 1: BAU Business as Asual 1,551 0.0 819 221 192 6,309 2000 1,715 0.0 1,002 271 213 8,555 2010 2,331 76 1,227 332 235 9,854 2020 (baseline) 3,895 205 2,480 550 260 10,900 2030 (BAU)1 6,341 8 4,658 902 333 12,036 2040 (BAU) 8,118 9 5,963 1,155 426 13,295 2050 (BAU) 8,967 10 6,587 1,276 471 14,686 Backward-looking time series PTFE: growth 1990-2005 increases at 1% per annum. From 2005 - 2020, growth accelerates to 5% per annum, as the advent of PTFE micropowder accelerates potential use, particularly in mixtures. EFTE: growth 1990 - 2010 increases at 2% per annum as EFTE becomes a strong alternative to PTFE. 2010 - 2014 growth at 5% per annum. 2014 - 2020 growth at 8% per annum as indicated by the Statista (2020)6 reference. PVDF: growth 1990 - 2010 increases at 2% per annum as PVDF becomes a strong alternative to PTFE. 2010 to 2020 growth at 5%. The EEA (2020) report suggests that PVDF is one of the most rapidly growing fluoropolymers due to its hard wearing anti-abrasion properties. Other fluoropolymers: growth 1990 - 2020. In lieu of data assume growth of 1% per annum. Non-polymeric PFAS substances (note that this covers a very wide range of substances): 1990 - 2002, assume growth of 3% broadly in line with inflation. Assume growth between 2002 and 2020 is 1% per annum as tighter regulation suppresses the market. Forward-looking time series PTFE: asssumed continued growth at 5% per annum until 2030, after which growth slows to 2.5% between 2030 and 2040 and slows further to 1% per annum between 2040-2050. EFTE: assumed growth of 8% per annum until 2025, after which growth slows to 5% (in line with PTFE) until 2030. The growth pattern then mirrors PTFE as growth of 2.5% annually between 2030 and 2040 and 1% per annum thereafter between 2040-2050. PVDF: mirrors the growth pattern for PTFE (5% annually between 2020 and 2030, then 2.5% between 2030 and 2040, and 1% between 2040 and 2050). Other fluoropolymers: assumed growth of 2.5% per annum between 2020 and 2040, after which it falls in line with the other fluoropolymers as a rate of 1% per annum between 2040 and 2050. Non-polymeric PFAS: is assumed to have a flat increase of 1% per annum from 2020 to 2050, assuming the market continues to be suppressed by the existing restrictions on a number of PFAS species. 6 https://www.statista.com/statistics/732029/ethylene-tetrafluoroethylene-market-volume-worldwide/ 7  Other contaminants: The production of PTFE using processing aids can contain PFOA as a trace contaminant (Wang et al, 20147). Equally, the CfE highlighted the possible presence of PFHxA as a contaminant in EFTE. o PFOA emissions are calculated at 2% w.w based on the work by Wang et al (2014) from 1990 - 2015. The projections assume that after 2015, remaining sources of PFOA in PTFE fall to 1,000 ppb (which covers the restriction for PFOA and its related compounds). o PFHxA is currently subject to a REACH restriction process which commenced in late 2019. For the projections, it is assumed that the transitional period under the REACH restriction will have concluded by the 1 January 2026. After this date it is assumed any further emissions would be negligible and therefore are assumed to be close to zero Note that no considerations of changes in technology, abatement, or unpredicted events (such as Covid-19) are included within the estimates. 3. Manufacturing & Market price + market development 3.1 Market price No information is given on market price. 3.2 Market development PTFE micro-powders The EU is currently in the process of implementing a restriction on the intentional use of microplastics with the combined opinion of the RAC and SEAC presented to the Commission in February 2021. Based on this some applications of PTFE micropowders, that are believed to exist in the 0.25 - 500m (0.5mm) range, fall well within the scope of the microplastic restriction. 8 The implementation of the restriction for the intentional use of microplastics is conservately estimated to be 2026. ECHA indicate that a vote on the restriction will likely take place in 2022 (assuming that current timetable is upheld). The implementation of a restriction would also likely include a transition period of 3-5 years to allow industry to transition away from current uses. PTFE can be used as a granular product, a micropowder and potentially a dispersion. A review of publicly available data on the internet (including SDS) suggests that PTFE micropowder is primarily used in mixtures for surface coatings and sealants. It is also possible to use PTFE micropowder as a raw material in `melt processes' to produced moulded products. However, insufficient data has been identified to help provide market splits. It is assumed that PFTE micropowder could be subsituted by PTFE as a granular prodct if they were not already using it in this form. The impacts of the restriction on construction articles is therefore unclear. EFTE-powders Review of company websites and SDS have also identified limited data that suggests EFTE could also be used as a fine powder within construction mixtures. The prevalence of fine powder EFTE use within the market has been challenging to estimate. 7 Wang et al, 2014, `global emission inventories for C4-C14 perfluoroalkyl carboxylic acid (PFCA) homologues from 1951 to 2030 part I: production and emissions from quantifiable sources', Environmental international vol 60 pp242-248 8 RAC and SEAC, 2020, `Opinion on the Annex XV dossier proposing restrictions on intentionally added microplastics', Revision 5 - 10 December 2020. 8 3.3 Production sites No exact information is given on the number of production sites. However, little information is given on the production of PTFE: Based on the production and use of PTFE, associated PFOA emissions are calculated at 2% w.w based on the work by Wang et al (2014) from 1990 - 2015, at which time the PFOA stewardship program phased-out the use of PFOA amongst the largest eight global producers. As the PFOA stewardship program did not cover all PTFE production globally, and Wang et al (2014) highlight new producers after 2015, it is assumed that PFOA may still be released from imported PTFE. Historically PFOA has been used as a processing aid in the manufacture of some types of PTFE, with much of the PTFE production taking place outside of the EU (Wang et al, 2014). 4. Emissions product manufacturing and product use 4.1 General Within this section and the coming sections (emissions product manufacturing and emissions product use) the PFAS species are divided into two majour groupings: Polymeric fluorochemical substances Non-polymeric fluorochemical substances Polymeric fluorochemical substances The polymeric fluorochemical substances are further categorized in four major groupings: PTFE (polytetrafluoroethylene) EFTE (ethylene tetrafluoroethylene) PVDF (polyvinylidene fluoride) Other fluorpolymer substances This categorisation has been used as the first three substances make-up 97% of the reported total usage of fluoropolymers in the construction sector while the latter covers 3% of the usage. Non-polymeric fluorochemical substances For the non-polymeric substances, the picture is more complex with a wide range of substances identified as potentially being in use covering fluorotelomer alcohols, acrylates, methacrylates, alkanes, amines, and silanes. The dominant species (based on frequency of respondents reporting its use) was perfluoro-1-butanesulfonyl fluoride (PBSF) and PBSF-related substances, which has applications, primarily as a surfactant and levelling agent for paints, but has also been identified as used in adhesives and sealants (tapes).The lack of granularity for market data on specific named nonpolymeric fluorochemical substances, means that in this section and coming section they are grouped together and simply referred to as non-polymeric PFAS. 4.2 Emissions baseline year The estimated emissions to air, water and land of different PFAS-species are given for articles, processing aids and commercial construction mixtures in Table 4, Table 5 and Table 6, respectively. 9 Note that emissions to the environmental compartments splitted by product manufacturing and product use are not given in the report and are therefore shown combined. Information on the assumptions made and corresponding justifications for these are given further on in this document (Table 8 and Table 10). Table 4. Overview of estimated yearly EEA emissions for 2020 (baseline) by receiving environment for articles. This table includes product manufacturing and use. Group PTFE (granular) EFTE PVDF All other fluoropolymer substances All nonpolymeric PFAS substances Quantity in use in EU (tonnes) 3,895 2,360 525 250 3,700 Emissions to air (tonnes) 96 50 12 6 94 Emissions to water (tonnes) 58 35 8 4 55 Emissions to land (tonnes) 152 84 20 10 147 Total Emissions 306 169 40 20 296 Table 5. Overview of estimated yearly EEA emissions for 2020 (baseline) by receiving environment for processing aids. This table includes product manufacturing and use. Group All nonpolymeric PFAS substances Quantity in use in EU (tonnes) 3,700 Emissions to air (tonnes) 4.0 Emissions to water (tonnes) 0.0 Emissions to land (tonnes) 1.0 Total Emissions 5.0 Table 6. Overview of estimated yearly EEA emissions for 2020 (baseline) by receiving environment for commercial construction mixtures. This table includes product manufacturing and use. Group PTFE (granular) EFTE PVDF All other fluoropolymer substances All nonpolymeric PFAS substances Quantity in use in EU (tonnes) 205 120 25 10 3,500 Emissions to air (tonnes) 15 9 2 1.0 256 Emissions to water (tonnes) 7.5 4.5 1 0.5 129 Emissions to land (tonnes) 7.5 4.5 1 0.5 129 Total Emissions 30 18 4 2.0 514 4.3 Emission estimates time-series In Table 7 the estimated emission of each PFAS-group for the period 1990-2050 is given per receiving environmental compartment. No information was available to allocate the releases to the different life stages of the construction products. 10 Table 7. Yearly emissions in the EU by vector (tonnes) including projections for BAU (Business as Usual). Group Vector PTFE (Granular) PTFE (Micropowder) EFTE PVDF Other fluoro-polymers PFOA (as by-product of PTFE (all types) (in kg) PFHxA (as by-product of EFTE) (in kg) Non-polymeric PFAS Air Land Water Air Land Water Air Land Water Air Land Water Air Land Water Air Land Water Air Land Water Air Land Water 1990 38 60 23 0 0 0 19 29 13 6 8 4 5 8 3 760 1,200 460 7.2 11 4 203 160 106 2000 42 67 26 0 0 0 24 36 16 7 10 4 6 8 3 830 1,320 500 9 13 5 275 211 140 2010 57 91 35 5.5 2.8 2.8 29 44 20 8 12 5 7 9 4 1,260 1,870 750 11 17 7 317 250 166 2020 (baseline) 96 152 58 15 7.5 7.5 59 89 40 14 21 9 7 11 5 0.1 0.2 0.07 22 32 13 350 277 184 2030 156 247 94 0.6 0.3 0.3 109 166 75 23 34 15 9 13 5 0.1 0.3 0.09 0 0 0 387 305 203 Group 199 316 121 0.7 0.3 0.3 140 213 96 29 43 19 12 17 7 0.2 0.3 0.1 0 0 0 427 337 224 Vector 220 349 133 0.7 0.4 0.4 154 235 106 32 48 20 13 19 7 0.2 0.3 0.1 0 0 0 472 373 248 4.4 Overview of the emissions In Figure 1 and Figure 2 an overview can be found of the yearly material flows for polymeric PFAS and non-polymeric PFAS, respectively. The emissions are given for the different stages in the life cycle of construction products. 11 Figure 1. Overview of yearly EEA material flow for all polymeric PFAS used in construction products. Figure 2. Overview of yearly EEA material flow for all non-polymeric PFAS used in construction products. 12 4.5 Emissions product manufacturing For construction products three major categories were identified to subdivide the emissions of different PFAS-species. These will be used to categorize the emissions during product manufacturing and product use. The categories are as follows: Articles Processing aids Commercial construction mixtures In Table 8 the assumptions used to calcalute the emissions during product manufacturing are given. Aditionally, the justifications for these assumptions are given. In Table 9 the emissions are presented. Table 8. Key assumptions and justifications for calculation of emissions during product manufacturing. Component Formulation (Type 1) covering the production of articles containing or made from fluoropolymer and non-polymeric PFAS Formulation (Type 1) covering the production of articles containing or made from fluoropolymer and non-polymeric PFAS Value Quantities of PFAS (by group) used. PTFE (granular) = 3,750 tpa EFTEs = 1,940 tpa PVDF = 475 tpa Other fluoropolymer substances = 250 tpa Non-polymeric PFAS = 3,700 tpa For fluoropolymer and non-polymeric PFAS emission factors based on Environmental Release Category (ERC) no.12A: Air = 2.5% Wastewater= 2.5% Soil = 2.5% Assumption and Justification Assumption: The market data pro-vides usage rates for different PFAS groupings as a range. In each case the upper limit of the range has been used. Justification: Assumes a worst case scenario and utilises the maximum amount of PFAS for each grouping. Assumption: Data on emissions dur-ing formulation of articles is very scarce. Feedback from stakeholder under the CfE commented that dust minimisation and capture is used as a standard practice to control emis-sions and prevent worker exposure. In lieu of better data ERC no.12A has been used covering: `Processing of articles at industrial with low release'. Formulation (Type 2) covering the production of commercial construction mixtures containing or made from fluoropolymer and non-polymeric PFAS Based on total use - PTFE (micropowder) = 200 tpa EFTE = 100 tpa PVDF = 25 tpa Other fluoropolymer substances = 10 tpa Non-polymeric PFAS = 3500 tpa Justification: Estimates for releases is very limited, feedback from industry asserts that emissions are very low and efforts are made to capture and control any dust or vapours generat-ed. The selected ERC default emis-sion factor best represents this set of activities. Assumption: Glge et al (2020) com-ments that 95% of paints and surface coatings are nonpolymeric, assum-ing the remaining 5% are fluoropoly-mers. The extrapolated values from Glge et al (2020) (3,700 tonnes per annum) have been used to apportion between polymeric and non-polymeric. The polymeric substances have then been further disaggregated based on the ratios between PTFE and the other major fluoropolymers. Justification: Extrapolation of key references and data provided through the CfE has been used to estimate quantities in use, due to a lack of good quality market data. 13 Component Formulation (Type 2) covering the production of commercial construction mixtures containing or made from fluoropolymer and non-polymeric PFAS Processing aids (Formulation Type 3) Value Use ERC emission scenario no.2 for `formulation into a mixture' 2.5% w.w to air 2% w.w to wastewater and 0.01% w.w to soil. Assume use quantity: 3,700 tonnes of non-polymeric PFAS. Assumption and Justification Assumption: Data on emissions dur-ing formulation of mixtures (including blending and elevated temperatures) is very limited. In lieu of presentative data ERC emission factors have been used as standard defaults to help guide the estimates. Justification: Formulation of mixtures spans a wider set of applications from paints, adhesives sealants and com-mercial mixtures used to treat articles. It is likely that emissions will vary on a process by process basis, but as a high level approach, the use of ERC default emission factors is justified. Assumptions: Very little available data to guide on the use of non-polymeric PFAS in production of articles (Gluge et al (2020) identifies a broadly even split between polymer and non-polymer). In lieu of better data assume that half of all non-polymeric PFAS is used as processing aids in the pro-duction of articles. Processing aids (Formulation Type 3) Use ERC emission scenario no.6b for `use of reactive processing aid at industrial site (no inclusion into or onto article' 0.1% w.w to air 5% w.w to wastewater and 0.03% w.w to soil. Justification: There is limited detail on this topic, however, the high majority of feedback for the use of non-polymeric PFAS in the CfE relates to the use as processing aids in the production of other articles. In some cases, these substances are used with fluoropolymers such as PTFE and in other cases with non-fluorinated pol-ymers such as poly propylene. Assumption: As with the other stages there is very limited emission moni-toring data. However, feedback from one stakeholder identifies the use of processing aids in the production of construction products where the pro-cessing aid is captured within closed systems and re-used. Justification: based on the feedback from industry stakeholders the emis-sions to air in particular look broadly in line with feedback provided. The estimates for wastewater may be an overestimate and should be consid-ered a conservative worstcase. Table 9. Overview of estimated yearly EEA emissions for 2020 (baseline) during product manufacturing (= formulation) for articles, processing aids and commercial construction mixtures. Group Articles PTFE (granular) 188 EFTE 97 PVDF 23.9 All other fluoropolymer 12.4 substances All non-polymeric PFAS 185 substances 1: n.a. not applicable Processing aids (use in manufacturing) n.a1 n.a n.a n.a Commercial construction mixtures 5 3 0.6 0.39 5.0 88 14 4.6 Emissions product use In Table 10 the assumptions used to calcalute the emissions during product use are given. Aditionally, the justifications for these assumptions are given. In Table 11 the emissions are presented. Table 10. Key assumptions and justifications for calculation of emissions during product use. Component Application Proportional splits for articles and commercial construction mixtures. Application assumes emission factors for commercial construction mixtures outdoors. Value Assume in lieu of better data a 50:50 split between outdoor and indoor applications for both articles and commercial construction mixtures. Use ERC emission scenario no. 9b for `widespread use of functional fluid (outdoor)' 5% w.w to air Assumption and Justification Assumption: No data available to help guide. Have assumed an even split to remain neutral. Justification: see above. Assumption: The application of mixtures may cover a very wide range of activities with varying potential for release to air, land, and water. In lieu of more data have assumed the most appropriate ERC default factors. Application assumes emission factors for commercial construction mixtures indoors. 5% w.w to water and 5% w.w to soil. Use ERC emission scenario no. 9a for `widespread use of functional fluid (indoors)' 5% w.w to air Justification: Given the likely wide variation in specific activities these ERC factors represent the best estimate. Assumption: The application of mix-tures may cover a very wide range of activities with varying potential for release to air, and wastewater. In lieu of more data have assumed the most appropriate ERC default factors. In-use phase, outdoor applications. Emission factors. In-use phase, indoor applications. Emission factors. 5% w.w to wastewater and Emissions to soil not applicable. Use ERC emission scenario no. 10a for `widespread use of articles with low release (outdoors)' 0.05% w.w to air 3.2% w.w to water and 3.2% to soil Use ERC emission scenario no.11a for `widespread use of articles with low release (indoors)' 0.05% w.w to air 0.05% w.w to wastewater and Justification: Given the likely wide variation in specific activities these ERC factors represent the best esti-mate. Assumption: Both fluoropolymers and non-polymeric PFAS substances are known to be hard wearing and highly stable to forms of degradation. During the use phase outdoors the primary pathways for emission will be weath-ering and abrasion from physical /mechanical activities. However, emissions could be expected to be low overall warranting the ERC 10a emission factors. Justification: The level of weathering and emissions is likely to vary de-pending on specific PFAS substance, application, and climate. In lieu of specific data the default values pro-vide a high-level estimate. Assumption: As with outdoor applications, the hardwearing nature of fluoropolymers and non-polymeric PFAS should mean low emissions overall. Primary processes for indoor environments will be contamination of dust through contact with treated surfaces and abrasion through physical /mechanical forces. Waste Emissions to soil not applicable. Assume quantities to reach wastewater treatment plants based on preceding steps. Assume all articles made from or containing PFAS not emitted during earlier life-cycle stages enter waste. It is possible that surfaces covered with PFAS based coatings enter the waste cycle (e.g., during repair or demolition), however, the majority of coatings are likely to remain in place with new coats painted on top of old. Therefore, without the necessary data to calculate how much of the coating enters waste it is assumed surface coatings do not enter the waste stage. Justification: see same justification for outdoor environments. Assumption: This final stage builds upon the preceding steps to quantify materials entering waste. No further estimates are provided for emissions during the waste cycle. Justification. Assumed waste pro-cesses based on the logical flow of material 15 Table 11. Overview of estimated yearly EEA emissions for 2020 (baseline) during use of articles and commercial construction mixtures. For processing aids no emissions are expected. Group PTFE (Granular) EFTE PVDF All other fluoropolymer substances All nonpolymeric PFAS substances Articles In-use (outdoors) All vectors (tonnes) 117 71 16 7.5 In-use (indoors) All vectors (tonnes) 1 1 0.1 0.1 Commercial construction mixtures Application All In-use In-use (indoors) vectors (outdoors) All All vectors (tonnes) vectors (tonnes) (tonnes) 19.96 5 0.04 11.97 3 0.03 2.69 0.7 0.01 1.25 0.35 0.01 110 1 334 91.25 0.75 5. Exposure (workers, consumers) Below information is given on the potential exposure of workers and consumers to PFAS. 5.1 Workers 16 companies provided data in the CfE or the targeted consultation (all in confidential attachments to the CfE or in confidential input to the consultation protected under nondisclosure agreements that allow only use in aggregated figures) on the number of workers employed in the production and handling of well over 100 different PFAS-based construction products. The sum of these workers for all products of the 16 companies amounts to approximately 12,000 workers (rounded to closest 1,000). The construction sector as a whole employs some 18 million people in the EU.9 Considering the uncertainty of the estimate of the overall market for PFAS in construction products and given that many of the stakeholders who provided their number of workers did not specify the related tonnage of PFAS in construction products, extrapolation to the whole market has not been deemed appropriate based on the available data. The construction sector as a whole employs some 18 million people in the EU. Given the diverse uses of PFAS in construction products, it stands to reason that the share of construction workers that handle PFAS-based products at least occasionally is not insignificant. Articles: exposure during production of articles could occur through inhalation of vapours or generation of dusts from mechanical manipulation of materials. Feedback from industry stated that many product plants would make use of abatement equipment to manage both vapours and dust (how many plants and which abatement equipment was not further specified). Processing aids: the feedback from industry was that these processes are largely automated and use closed systems to capture and re-use PFAS as far as possible. It is possible to envisage there will be some atmospheric releases and worker exposure, particularly during maintenance windows, but overall exposure could be expected to be low. 9 https://ec.europa.eu/growth/sectors/construction_en 16  Paints and surface coatings: it can be expected that PFAS will be introduced to mixtures additively during blending and mixing. These processes are more likely to be at elevated temperature, with generation of vapours. Industry feedback was keen to highlight that fluoropolymers such as PTFE, EFTE and PVDF are highly stable with low vapour pressure, but note that also non-polymeric PFAS are used in paints and coatings. The highest worker exposure will likely occur during the application phase of paints and coatings (and potentially adhesives). PFAS based mixtures can be added as coatings/impregnation by spraying, rolling, or brushing onto finished articles, this may occur both indoors and/or outdoors. 5.2 Consumers Most construction products are not generally used by consumers. Uses that are more likely for consumers include DIY (Do-It-Yourself) sealant and adhesive products, DIY durable water repellent (DWR) impregnation and aftermarket floor protection (and potentially paint), however it was not possible to estimate the number of consumers using these products. It is possible that PFAS-based mixtures are to be used within DIY adhesives and sealants, but likely within small quantities. The greater potential for release and exposure may occur where articles are abraided during use (i.e., moving parts) or where maintenance involves cutting (fluoropolymers (such as PTFE, EFTE, and PVDF) are largely stable from degradation, while non-polymeric PFAS may be bound within the matrix of the article). Even for paints and coatings containing PFAS the major risk of exposure comes during application. There is a potential for release into drinking water for any applications involving liners, sealants, or coatings for water pipes. A significant share of all consumers will likely come into contact with buildings that have been constructed using PFAS-based construction products. However, if undisturbed and not subject to direct weathering or washing, the potential release is likely low. Even for paints and coatings containing PFAS the major risk of exposure comes during application, which given the specialist nature of PFAS containing paints is more likely to affect professional workers. The emission estimates for indoor use of paints and coatings are relatively low (4 tonnes per annum from the 3,848 tonnes of PFAS (both polymeric and non-polymeric con-sumed in paints and coatings across the EEA). 5.3 Indirect exposure of humans via the environment Providing further comment on the potential human exposure to PFAS via the environment from uses in construction products (including paints and coatings) is extremely challenging. It is possible for major construction projects this could include outdoor uses on sites near water or agricultural land. The estimated wastewater emissions from the formulation stage have a high potential to end up in sewage sludge, which is applied to agricultural land in some (but not all) EEA states. This would likely give rise to the potential for contamination of food. 17 6. General discussion on emissions and exposure Existing legal requirements: No specific information is given on existing legal requirements. Effectivenes of operational conditions and risk management measures: No information is given on this subject. 7. Alternatives Very limited data was provided on alternatives for the construction products (both articles and surface coatings) through the CfE. The dossier from POPRC (The Persistent Organic Pollutants Review Committee)10 has been used alongside the Annex XV dossier for PFHxS and PFHxA and a brief literature search to supplement the CfE responses further. The alternatives for PFAS in articles, and paint and coatings are given in Table 12 and Table 13, respectively. 10 Draft report on the assessment of alternatives to PFOS, its salts and PFOSF (UNEP/POPS/POPRC.14/INF/8) 18 Table 12. Alternatives for construction products - articles. Subuse/ Function Thermal insulation applications PFAS n.s.1 Processing aids in the production of construction products n.s./ confi-dential Non PFAS alternative? Options such as: Polyisocyanurate Phenolic thermal product Confidential Architecturial fabrics Fluoropolymers Cotton and other natural fibres Polyamid (nylon) Polyester Fiberglass Aramid (Kevlar, Twaron) Carbon fibres Fluoropolymer tube Fluoro- lining polymers Polypropylene 1: n.s. not specified Silicone PVC Co-extrusions (two different materials are extruded as the inner and outer layers) Advantage / disadvantage n.s. High technical feasibility Specific applications may require different solutions Each has trade-offs in performance Either lack of chemical stability and flame retardancy or (see column `costs') Low technical performance Feasible for light-duty applications High strength, stifness and tenacity Low weight Not dimensionally stable when wet Poor UV resistance Stretches considerably Good tensile strength and elasticity Mechanical properties degrade with UV light Subject to ageing Can be coated with PVC to provide UV protection High tensile strength (although decreasing when wet) Long lifetime Brittle Low elastic strain Can be coated with silicone to enhance properties (not further specified) High strength (except compressie strength) Low weight Good abrasion/chemical/thermal resistance Can degrade from UV exposure Can be coated with PVC or silicone to provide UV protection Used (usable) for high-tech products Low expansion coefficient Non-combustible Chemical resistance approaches fluoropolymer Comparable low surface friction, corossion resistance, dielectric strength and low weight For all substitute materials the possibilities depend on the performance requirements of the specific application Temperature resistance Chemical resistance Costs n.s. Not economically feasible or (see column `advantage/ disadvantage') n.s. Less costly 19 Table 13. Alternatives for construction products - paints and coatings. Subuse/Function Paints and coatings PFAS Polymeric and nonpolymeric PFAS1 Polymeric and nonpolymeric PFAS1 Non PFAS alternative Polyurethane Polyester powder Wax emulsions Silicones/silanes/polysiloxanes Hydrocarbon polymer technologies Hydrocarbon and silicone-based surfactants Advantage / disadvantage Technical feasibility and availability not provided Do not provide the same performance in terms of reducing surface tension, oil and dirt repellency. It is necessary to use higher concentrations within the paint mixture compared to fluorosurfactants Superhydrophobic coatings PFOS2 PFHxS n.s. Wood primer and inks PFOS2 Rust protection systems, marine paints, resins, printing inks and coatings in electrical applications 1: n.s. not specified PFOS2 Short chain, polyether-modified siloxanes Low molecular weight polyether-modified siloxanes Siloxane multi-functional surfactants Alkoxylates (silicone and solvent-free) Fatty alcohol polyglycol ether sulphate (sometimes together with a sulfosuccinate) Polymeric matrix (the binder) added to hydrophobic nanoparticles (the filler) Sulfosuccinates (e.g. sodium salt of di-(2ethylhexyl) sulfosuccinate Propylated napthalenes Propylated biphenyls Reduces static surface tension Almost universal aids for difficult to wet and contaminated substrates in diverse areas of application including on capillary substrates such as wood Ability to customize properties such as compatibility, low foam and anti-cratering effects via polyether modification and siloxane chain length. Reduces the surface tension in waterborne systems more strongly than hydrocarbonbased surfactants or higher molecular weight polyether siloxanes Anti-cratering properties Can be used to improve wetting of wood substrates Can be used in spray paints Provides optimum atomization during application without affecting the slip characteristics of the dried finish Combination of reduction in surface tension and defoaming properties Imparting good recoat properties Reduce dynamic surface tension which is particularly advantageous for printing inks (potentially less relevant in the context of construction products) Foam inhibiting and degassing in waterborne coatings and printing inks Can be used to act as a deaerator and to wet pigments and promote flow n.s. Can be used to address the challenge of optimising mechanical durability, as the rough asperities required for maintaining super-hydrophobicity otherwise tend to be easily removed by abrasion This technology still appears to be in development Its performance is not specifically compared to that of PFAS coatings Dissolved in ethanol and water already used as alternative Di-(2-ethylhexyl) sulfosuccinate can also be used as an alternative mixed with silicone polymers, ethanol and water Can be used as water repelling agents Costs n.s. n.s. n.s. n.s. n.s. 20 2: Note that PFOS and its derivatives is listed in Annex I part A of the POP-regulation, https://eur-lex.europa.eu/legalcontent/EN/TXT/HTML/?uri=CELEX:02019R1021-20210315 8. Economic impacts in case of a full PFAS ban Below the economic, environmental, social and other impacts of a full PFAS ban are described based on the Call for Evidence and targeted stakeholder consultation. 8.1 Economic impacts Many stakeholders did not provide cost estimates for substitution but instead suggested that no alternatives were available and/or that reformulation was not possible in their view. Some highlighted that a lack of alternatives that can provide a similar combination of properties would potentially require significant changes to applications in the construction sector, but further detail on the affected products and associated costs could not be provided. No specific input was received to provide a separate estimate for technical and organisational costs for developing and implementing alternatives In many cases, PFAS are used in construction products to improve durability and reduce maintenance/cleaning. If this functionality is lost/reduced, this would lead to higher maintenance costs, as well as costs and waste associated with more frequent replacement. It appears likely that a restriction on the use of PFAS in construction products would lead to a significant loss of business for certain suppliers and therefore potential closures of particularly effected businesses. However, no information was available to quantify the loss of business. A potential loss of competitiveness of the European construction product industry. Substitution costs and time required for identification of alternatives, reformulation, obtaining market qualifications could not be quantified at this stage but could be substantial. 8.2 Environmental impacts Substition of processing aids will not match its performance in terms of being "circular economy ready", durability, environmental footprint per quantity installed and disposed of, cost effectiveness and vapour permeability, according to a producer. Performance benefits will be lost, such as energy savings due to translucency, durability, fire resistance, reduced structural building materials due to light weight, UV resistance, and novel architectural designs. 8.3 Social impacts Stakeholder input was received from some suppliers of construction products dependent on PFAS, employing some 1,000 people in sum, of which at least a share if expected to be lost. It was also suggested that job losses "in the thousands" could occur in the wider construction industry, although no further detail was provided as to how and why this employment would be lost. Note that generally speaking, a share of any employment losses would likely be temporary, but sufficient information was not available to judge the time of the employment losses and any potential salary implications. 8.4 Other impacts Potential health and safety implications in the applications seals/bearings and pipe linings. 21  One producer indicated that fundamental research is required to find alternatives for processing aids that deliver the required performance and are subject to lower environmental concerns than PFAS. 9. Uncertainties The uncertainties of the presented information are given here per section. 9.1 Substances uses and applications Some substances identified in literature have not been identified by stakeholders (and viceversa), so there is some uncertainty about whether these are (still) used in the EEA in reality. There are probably further PFAS substances used that have not been identified. This could be the case particularly for substances (and their uses) that are considered commercially sensitive and strictly confidential. Relatively little specific information on degradation products has been received and a comprehensive literature review on potential degradation of each of the identified substances used has not been performed. 9.2 Manufacturing (market data + market price) Market data The market data gathered via the CfE is incomplete and structured in a fashion that makes analysis very challenging. As an example, two key issues can be highlighted: Respondents have provided data identifying which PFAS are in use, and further data on specific named products including working concentrations for PFAS. However, it is possible for the same product to be used across multiple specific activities and even across major sectors (e.g., the same product may be used in construction and mining). Total quantities manufactured and imported has been provided by some respondents but as a headline number without disaggregation by use. This means it is not possible to apportion tonnages to uses even at the parent level. Many respondents have provided data as ranges and in some cases these ranges are very broad (e.g., "<1,000 tonnes" = 1 - 999 tonnes). Standard approaches can be applied to help us calculate quantities, but with many respondents using large ranges the estimates would be very uncertain. Market data from the CfE and the targeted stakeholder consultation likely does not cover all relevant users, and sufficient information to extrapolate from the stakeholders that provided information (e.g., their market share) to the whole EEA market was not available. The market data from stakeholder consultation may also include some double counting (when different supply chain stages report tonnages for the same products), although this is likely less severe than the previous caveat. For construction products, sufficient data was not available to provide a breakdown of tonnages of PFAS used by sub-use or application. A further uncertainty is associated with the definition of a 'lubricant use'. PFAS can be used for providing smooth and frictionless surfaces. Whether such applications shall be seen as lubricant use or coating/sealing use will impact the figures of PFAS in both lubricants and construction. Number of production sites 22 No specific information was given on the number of production sites. However, some information was presented on the number of workers of the 16 companies which provided data in the CfE or the targeted consultation (12,000 workers). This number is uncertain and should therefore be considered only a rough indication of the number of magnitude of workers involved with the products of those 16 companies. Tonnages REACH database It should be noted that official statistics on production and trade (e.g., Eurostat Prodcom or Comext data) are not sufficiently detailed to identify PFAS-based construction products. As polymers are exempt from registration under REACH, and a lot of PFAS-based construction products are based on polymeric PFAS, tonnage bands from ECHA's database of registered substances are also not useful in this case. Additionally, the CfE identifies approximately 20 non-polymeric PFAS substances in use, but with no tonnage data provided. This makes further analysis challenging. SPIN database There are certain limitations in using data from the SPIN database to estimate tonnages of PFAS used: The database is based on data from the Product Registries of Norway, Sweden, Denmark and Finland and there are certain limitations to what needs to be notified11 which means that not all construction products (containing PFAS) will be notified. In addition, confidential information may not be included in the market figures derived from the SPIN database. Tonnage estimates from the SPIN database are extrapolated from the participating countries to the EEA as a whole, based on the assumption that PFAS use in construction products per capita is the same across the EEA. Information from stakeholder consultation There are certain limitations and uncertainties related to the provided information by the stakeholders on manufacturing and import of PFAS: The data provided through the CfE and supplemented by further stakeholder input likely does not cover all relevant users. The data gathered via the CfE is incomplete and structured in a fashion that makes analysis very challenging. Respondents have provided data identifying which PFAS are in use, and further data on specific named products including working concentrations for PFAS. However, it is possible for the same product to be used across multiple specific activities and even across major sectors (e.g. the same product may be used in construction and mining). Total quantities manufactured and imported has been provided by some respondents but as a headline number without disaggregation by use. This means it is not possible to apportion tonnages to uses even at the parent level. The figures may include some double counting (when different supply chain stages report tonnages for the same products). Many respondents have provided data as ranges and in some cases these ranges are very broad (e.g. "<1,000 tonnes" = 1 - 999 tonnes). Where data has been provided as ranges, the upper bounds have been used to quantify a `worst case' scenario, but with many respondents using large ranges the estimates are very uncertain. 11 For instance, Part 3 of the Executive Order setting out the notification duties for the Danish Product Registry (https://at.dk/en/regulations/executive-orders/special-duties-suppliers-1794/). 23  In general, no specific information on import and export of PFAS-based construction products was identified. 9.3 Emissions The approach uses a basic source-flow model, which involves some degree of simplification and generalisation of the life-cycles of the different products. A very large number of substances have been identified as being in use or potentially in use (with varying quality of data available on each), so the approach taken has not tried to develop estimates on a substance-by-substance basis, but grouped the main substances used and types of uses (based on emission-relevant considerations such as way of application of PFAS to product, indoor/outdoor use, professional/consumer use, etc.). Specific data on releases was not available for all substances, products and life-cycle stages. Assumptions based on expert judgement and Environmental Release Category (ERC) emission scenarios have been used to fill the gaps. In addition, the uncertainties around market data (see above) cascade into the emission estimates. Therefore, the estimates included in this section should be treated as indicative orders of magnitude and not definitive estimates to the nearest tonne. 9.4 Exposure to workers and consumers Similar uncertainties as for the market data (see above) apply to the use of information from the CfE on workers associated with PFAS-based construction products. In addition, downstream user sectors and applications are very wide-ranging and diverse. Any estimates provided should therefore be considered only a rough indication of the number of magnitude of workers/users involved. 9.5 Alternatives For alternatives to PFAS in construction products, very limited data was provided from stakeholder consultation, and the input received regarding alternatives stems exclusively from industry. Literature on potential alternatives has been identified for some of the main applications but is not comprehensive. 9.6 Economic impacts in case of a full PFAS ban Information on the main types of costs was patchy covering only some of the many applications of PFAS in construction products. Hence, it is not clear whether they apply to PFAS-based construction products in general, although it seems likely that the general conclusions outlined above are probably similarly applicable across most applications All stakeholder responses received related to economic impacts came from industry and so the results reflect exclusively an industry position. One major source for uncertainty is whether current assets could be used or if they would need to be replaced (which could cost in the order of hundreds of millions of Euros). 24