Document jg98YRjDqYeLp532bmvBqp35N

ROBECCHI Lavorazioni Plastiche IIP UNI EN ISO 9001:2015 CERT N.245 Date: 09 September 2021 ROBECCHI ARTICOLI TECNICI S.r.I. - Via Tribolina, 25 24064 GRUMELLO DEL MONTE (BG) - ITALY Reg. Impr. di BG - C. F. e P. IVA: 00843220161 capitale sociale 90.000 i. v. Tel. (+39) 035-8324 ) 035-833391 www.robecchi.com robecchi.com Kind attention: Mr. Martijn Beekman - Netherlands Dr. Mandy Lokaj - Germany Mrs. Jenny lvarsson - Sweden Mr. Toke Winther - Denmark Mr. Audun Heggelund - Norway Mr. Mark Blainey - ECHA Chem iligibund.de Jenny. b11kemi.se tnvvinrlmct rik (miljodir.no mark.blainey@echa.europa.eu Through: fluorseals S.p.A - Via Tribolina, 20/22 - 24064 Grumello del Monte (BG) - Italy The members of fluorseals S.p.A mainly focus on processing of Fluoropolymers, part manufacturing and its applications, the involvement of downstream users in PFAS process. Subject: PFAS restriction proposal & request for exemption of FLUOROPOLYMERS Reference: PFAS - Registry of restriction intentions until outcome (Rol) dated 156 July 2021 Dear Sir/Madam, With regards to Registry of Intention (Rol) filed by 4 EU Member States (Germany, the Netherlands, Sweden, and Denmark) & Norway for the restriction of PFAS, we, a member of fluoropolymer downstream user industry, hereby, would like to share some salient facts related to the importance of fluoropolymers, critical functionalities, performance and benefits of its applications to society, while acknowledging concerns regarding PFAS emissions related to the use of fluoropolymers and their end of life. Registry of Intention for PFAS restriction was announced by ECHA on 15th July 2021, to prepare a restriction proposal for PFAS. Fluoropolymers are also included in the scope. The restriction proposal is intended to be submitted to ECHA by 15th July 2022 Fluoropolymers are a distinct subset of PFAS and are inherently safe, non-mobile, non-bio accumulative and non-toxic. Fluoropolymers are different from other PFAS as they do not share the toxicological and environmental profiles associated with PFAS of concern. Fluoropolymers have unique set of physicochemical properties, they meet OECD polymer of low concern criteria, and are considered to have insignificant environmental and human health impact. Fluoropolymers ensure safety, reliability, durability and critical performance in numerous technologies, industrial processes and everyday applications that are important for human health, safety, and the environment. With a unique combination of functionalities, fluoropolymers are irreplaceable across many key sectors/applications. Alternatives to fluoropolymers, if exist, escalate safety risks, carbon footprint, technology regression, and do not match the advanced performance of fluoropolymers. Most importantly, restriction on fluoropolymers will make EU industry lose its technological superiority over other economies and could put Europe's climate and energy goals at risk. Overall, fluoropolymers contribute heavily to Europe's socio-economic status and are critical for the betterment of the society.