Document k1YdrK37No9Nyb4Bz7KEn7z0

Kotel ry Proposed PFAS restriction - analysis of impacts on the electronics industry Comment on the Annex XV restriction report TR 19 Ympristkysymykset (working group for Environmental Compliancy and Electronics) 9-18-2023 Contents 1. Introduction and scope ......................................................................................................................... 2 2. Purpose of PFAS .................................................................................................................................... 2 2.1 PFAS in components and finished products ....................................................................................... 3 2.2 PFAS in production equipment ........................................................................................................... 6 2.3 PFAS in production processes ............................................................................................................. 6 3. Analysis of alternatives ......................................................................................................................... 7 4. Socio-economic impact analysis ........................................................................................................... 8 4.1 Direct impacts on companies and European industry ........................................................................ 8 4.2 Impacts on safety ................................................................................................................................ 9 4.3 Impacts on the environment .............................................................................................................. 9 5. Derogations......................................................................................................................................... 11 5.1 Request for derogation ..................................................................................................................... 11 5.2 Other concerns.................................................................................................................................. 12 1. Introduction and scope KOTEL ry (registered association) is the association for cooperation for research and development of electronics in Finland. The purpose of KOTEL is to promote quality, reliability and efficiency of electronic components, equipment, systems and software design, manufacturing, procurement, and maintenance. To achieve these goals, the association strives to combine the know-how of its member companies and organizations and promote overall national and international co-operation. The other means and practical measures for success are training seminars, research and development projects and various working group activities in the areas of electronics reliability, environmental requirements and characterization, environmental and life cycle compliancy, EMC, electronics corrosion, failure and material analyses and thermal management, to name a few. In Europe, KOTEL participates and contributes actively in CEEES, Confederation of European Engineering Societies. KOTEL was founded in 1967 and is based on cooperation and collaboration. The KOTEL network comprises more than 40 companies and institutes (various industries, engineering services and research/educational institutes) operating in Finland, with approximately 100 active members in working groups and projects. We represent approximately half of the jobs in the electronics and electrotechnical industry in Finland and more than half of the industry's export revenue. Working groups and Engineering (Research) projects are the essence of our cooperation & collaboration. Working groups function as forums for active and collaborative information sharing - in the working groups, experts from member companies jointly conduct studies, small projects, benchmarks, workshops etc. (which result working group reports), initiate and organize seminars and provide ideas and concepts for research projects. Experts from our member companies in our working group for Environmental Compliancy and Electronics have drawn up this document. Our Finnish member companies build the core for KOTEL operations. The companies represented by KOTEL manufacture and sell, for example, motor drives and other motorization equipment, industrial robots and automation solutions, power converters and inverters, high-pressure pumps, and sensors and solutions for industrial and environmental measurements. 2. Purpose of PFAS Per- and polyfluoroalkyl substances (PFAS) are found in a variety of substances, mixtures, and articles, including complex objects that are commercial components. These components are incorporated into end products produced by companies, resulting in very complex objects. However, it's important to note that PFAS are not always intentionally added or used as such in these products. In this chapter, we are talking about intentionally-added PFAS which bring critical qualities to components, products and processes. PFAS are employed in both electrical and mechanical components due to their advantageous characteristics. Their durability, ability to withstand high temperatures, hydrophobic nature, resistance to various chemicals, permeability, and excellent sliding properties make them ideal for numerous applications. Industrial electronic components incorporate a broad range of PFAS materials, particularly fluoropolymers. These mechanical products often function under high pressures and across a wide temperature range. Typically, these components are part of systems that include operating fluids such as refrigerants, oil, or water. These systems need to be airtight for environmental reasons (like preventing leaks), safety, and energy efficiency. Insulators also contain large amounts of PFAS to prevent electrical breakdown. PFAS have largely replaced ceramic insulators because they achieve the same effect with much smaller quantities. Fluoropolymers, in general, are exceptional materials that ensure low friction and tightness due to their strength and chemical durability, making them critical design components. Replacing them is not as simple as a `drop-in' approach; it would necessitate a significant conceptual redesign with an uncertain outcome. 2.1 PFAS in components and finished products According to an analysis of our member companies' part databases, PFAS are found in several different types of parts. These include but are not limited to the following: Wires, cables and insulation thereof Connectors and gable glands Electrical components (capacitors, thermistors, resistors, attenuators etc.) Filters, membranes and vents O-rings, gaskets, bonded seal rings and plugs (sealing) Tubing, tube fittings and valves Insulation or protective sheets and films Machined parts and coatings Lubricants Sleeve bearings Below are some examples that illustrate the importance and critical role of PFAS in the previously mentioned part types. Breathing vents are plugs equipped with a permeable membrane that protect enclosed equipment from humidity and other environmental conditions. If these vents didn't possess both hydrophobic and permeable properties, water or water vapor could infiltrate the enclosure and condense within the equipment. This could lead to corrosion, compromised reliability, and potential electrical safety hazards. Often, these vents are deemed safety critical items in approval tests. The PTFE membrane used in these vents is challenging, if not impossible, to replace. Membrane or porous filters, often composed of polytetrafluoroethylene (PTFE), are utilized to regulate the gas flow through the probe of a measurement instrument. These filters facilitate the passage of gases to the internal sensor while excluding water and particulate matter. Absence of such a filter could result in water ingress to the probe, leading to inaccurate and unreliable measurements, and prolonged sensor recovery times. Utilization of a filter with inferior properties could slow down the flow rate, adversely affecting the measurement precision and response time. Furthermore, it could lower the maximum operational temperature of the probe, thereby eliminating its applicability in certain hightemperature applications that rely on these measurements. PTFE cannot be directly substituted in these types of filters. If alternative materials were used, both the temperature specifications and hydrophobic properties would be compromised. Specifically, metal filters would alter the humidity conditions within the system. The hydrophobicity of filters is achieved through the porosity of the material, a characteristic that is easily implemented with PTFE from a manufacturing technology perspective. In contrast, metal filters, due to their different physical and chemical properties, may not maintain the same level of hydrophobicity. This could potentially lead to moisture accumulation and subsequent issues within the system. Therefore, finding a suitable replacement for PTFE in these applications presents a significant challenge. High-performance seals and gaskets are utilized in demanding industrial gas and liquid measurements. These include determining liquid concentration in the process industry, insulating power transformers, controlling biogas quality and process, and managing bio-decontamination processes, among others. Only compounds of PFAS can withstand the intense heat and chemical stresses present in these harsh environments. Cables frequently employ PTFE insulation due to its superior dielectric properties, which significantly influence the cable's attenuation characteristics, particularly in sensitive measurements. Furthermore, PTFE is the only viable option for high-temperature applications or for complying with the fire safety standards of certain countries, such as those pertaining to plenum cabling. PFAS are utilized as flame retardants in polycarbonate components (e.g., plastic covers). While a substitute material exists, its machinability is different, necessitating the renewal of injection molding tools. This constitutes a massive undertaking, encompassing evaluations, secondary manufacturing, approvals, and more. An 18-month timeframe for replacing this material is critically insufficient for such a task. Safety is a paramount concern in the design and operation of products, particularly those that handle high-temperature liquids or gases. Unintended leakage of these substances into the surroundings can pose significant hazards. To mitigate these risks, reliable guide gaskets and seals are essential. These components ensure the tightness and dimensional stability of the system, thereby preventing any potential leaks. Energy efficiency is another critical factor in product design. It is closely tied to the properties of wear resistance and low friction. In systems such as valves, especially pressure regulators, friction can lead to increased hysteresis, which in turn results in decreased regulation performance. Therefore, maintaining low friction is crucial for energy-efficient operation. The majority of valves incorporate guides and coated O-rings to achieve this balance between safety and efficiency. Finally, here is a list of some identified PFAS compounds in our member companies' parts and processes, for information. Out of these, PTFE is clearly the most prevalent and critical. It should be noted that we have performed the scans based on the OECD and EPA PFAS lists and therefore, some crucial substances in the scope of the current restriction proposal may not be included. Available data is limited because so far, PFAS have not been of concern in current regulations, save the few already restricted exceptions. Compound Name 1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene and 1,1,2,2tetrafluoroethene 2-(Difluoromethoxymethyl)-1,1,1,2,3,3,3-heptafluoro-propane 4,4'- [2,2,2-trifluoro-1- (trifluoromethyl)ethylidene]diphenol Benzyltriphenylphosphonium, salt with 4,4'-[2,2,2-trifluoro-1(trifluoromethyl)ethylidene]bis[phenol] (1:1) Bis(4-chlorophenyl) sulphone Bisphenol AF Butane, 1,1,1,2,2,3,3,4,4-nonafluoro-4-methoxy Fluorine Phosphonium, triphenyl(phenylmethyl)-, salt with 1,1,2,2,3,3,4,4,4-nonafluoro-N-methyl-1butanesulfonamide (1:1) Poly(ethylene-co-tetrafluoroethylene) (ETFE) Polytetrafluoroethylene (Teflon) Poly(tetrafluoroethylene-co-perfluoro(propylvinyl ether) Poly (tetrafluoroethylene-co-vinylidene fluoride-co-propylene) Siloxanes and Silicones, Me 3,3,3-trifluoropropyl Tetrafluoroethylene-hexafluoropropene copolymer Vinylidene fluoride-hexafluoropropylene polymer 2-Propenoic Acid, 2-[Methyl[(Nonafluorobutyl)Sulfonyl]Amino]Ethyl Ester, Telomer With Methyloxirane Polymer With Oxirane Di-2-Propenoate and Methyloxirane Polymer With Oxirane Mono-Propenoate 1-Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1,2,2-tetrafluoroethene Propane, 1,1,1,2,2,3,3-heptafluoro-3-[(1,2,2-trifluoroethenyl)oxy]-, polymer with 1,1,2,2-tetra 1-Hexene, 3,3,4,4,5,5,6,6,6-nonafluoro-, polymer with ethene and 1,1,2,2-tetrafluoroethene Ethene, 1,1,2,2-tetrafluoro-, homopolymer CAS Number 25190-89-0 163702-08-7 181531-28-2 75768-65-9 80-07-9 1478-61-1 163702-07-6 7782-41-4 332350-93-3 25038-71-5 9002-84-0 26655-00-5 54675-89-7 63148-56-1 25067-11-2 9011-17-0 1017237-783 25067-11-2 26655-00-5 68258-85-5 9002-84-0 It should be noted that components contained in electronics are not expected to spontaneously release PFAS in the environment. The end-of-life phase of industrial electronics is generally controlled and does not constitute an emission source on a grand scale. Furthermore, there is no direct contact from the PFAS-containing components with users, and even if there were, the components have been specifically chosen for their stability and chemical inertia, which means they hold their form for years and decades without releases or emissions. 2.2 PFAS in production equipment In addition to being incorporated into products manufactured and sold by our member companies, PFAS-containing parts are used in production equipment. This is another critical area where the proposed PFAS ban would have significant impacts on companies' ability to manufacture, product quality, costs, and profitability. Types of parts containing PFAS in manufacturing and process equipment are, for example, cables, Orings, seals and gaskets, probes, many critical filters, valves, chemical lines/piping, Teflon pumps, chambers, jigs, wafer cassettes, and chemistry benches. Additionally, PFAS are present in lubricating oils for vacuum pumps used in demanding conditions, such as equipment containing process gases. Especially resistance to chemicals and high heat tolerance are required properties for certain parts used in production equipment. These parts have very long lifetimes, often years or decades, or as long as they are mechanically intact. They are somewhat more expensive than pure plastic parts. Even if there were alternatives to PFAS-containing parts for these types of equipment, this would most likely require re-designs of the machinery on the manufacturers' part and lead to complete equipment system updates for end-users such as our member companies. The costs of these equipment are anywhere between tens and hundreds of thousands of euros, with associated testing, validating and process changes increasing the bill with at least the same sum. It would make sense that the next generation of equipment could be made PFAS-free, if possible, but this should happen in the natural course of equipment updates. At the very least, availability of spare parts for production equipment should be ensured. 2.3 PFAS in production processes PFAS are critical in certain manufacturing processes as process gases, liquids and lubricants. Their identified alternatives are often other PFAS or already restricted or more heavily regulated. We present a few examples of such cases below. Tetrafluoromethane (R14, CF4) is commonly used in clean room processes in the semiconductor industry. It is an unparalleled gas for dry etching in wafer fabrication. It has many other process uses, and while substitute gases may exist for dry etching (such as reactive ion etching), they are very laborious and time consuming to test and approve for production and not guaranteed to work in current manufacturing ecosystems. Other potential alternative processes are very unorthodox and unlikely to work properly. Banning CF4 could lead to many issues in the semiconductor industry, e.g., high costs for R&D and manufacturing, loss of mature technology, quality and yield constraints, and loss of competitiveness within the EU, just to name some. Certain F-gases are used in cold sprays. While not an essential component for products, cold sprays are used in e.g. finding faults in printed circuit boards and in cooling components quickly in order to do testing. It is very important to be able to change the temperature of electronic components fast and locally when studying and developing new electronic components. All identified alternatives for cold sprays seem to contain a type of a tetrafluoropropene or tetrafluoroethane compound. The restriction proposal's definition of PFAS includes Hydrofluoroolefins (HFOs), which are used as refrigerants. HFOs have already been identified as alternative substances for refrigerants in response to the bans imposed by the F-Gas Regulation and the Montreal Protocol. These alternatives are considered environmentally friendly due to their low global warming potential (GWP) compared to certain more harmful fluorinated gases. However, the proposed PFAS restriction also advocates for the elimination of HFOs. Given that HFOs are already regulated by both the F-Gas Regulation and the Montreal Protocol, it's important to avoid redundant regulation to ensure the availability of alternative refrigerants. Therefore, it's crucial to clarify how this proposal intersects with other regulations related to substances that fall under the proposed PFAS definition, such as the forthcoming revised F-Gas Regulation. 3. Analysis of alternatives The presence of PFAS in these chemicals and components necessitates that suppliers offer PFAS-free alternatives. However, this transition is not straightforward. It requires a period for redesign, verification, and ensuring the proper function of the end products. A sudden ban on more than 10,000 components for all companies at the same time could disrupt the supply chain. Even if there were PFASfree alternatives available, the market might not be able to deliver them promptly due to the sudden increase in demand. Substitution potential for many of the identified PFAS compounds is unknown. It is already clear that materials such as fluoropolymers and fluoroelastomers are the best available technologies for demanding conditions and long life cycles, as demonstrated in the previous chapters through the unique combination of properties that PFAS possess. While there may be alternative materials that could theoretically replace these parts, they are likely to lead to loss of quality, performance and durability in the final products. This is not a sustainable development direction and it undermines decades of product development across critical industries, in addition to possibly putting lives at risk. In any case, all new parts - such as cables, pipes, sealings, filters etc. - have to be tested and validated for use. Conditions such as temperature, humidity, pressure and safety matters have to be tested. Even if there were viable PFAS-free alternatives, replacing the whole PFAS-containing component base would take an immense amount of work in first identifying the alternatives, testing them in product runs, validating them in actual operating conditions and with actual customers, and possibly repeating the cycle if the results were subpar - and all of this for each subassembly and each product. In some cases, also expensive and time-consuming 3rd party approval tests and certifications (e.g. IEC/UL safety approvals, FAA/NWS configuration management control) would be necessary. Mapping potential alternative components, testing them, validating them in complete products or entire systems and approval testing and/or certification for the finished products easily takes more than 10 years in advanced industries. It is likely that products without PFAS are going to be completely new products, as they may have to be designed from scratch, not only their electronic components. 4. Socio-economic impact analysis The proposed ban on PFAS, with its broad scope and potential impacts on component availability, manufacturing, and product quality, would have far-reaching effects. These effects would extend beyond our member companies and their direct customers, impacting societies worldwide in numerous and potentially unpredictable ways. Some of the anticipated impacts are detailed below. 4.1 Direct impacts on companies and European industry Our position, based on the prevalence and criticality of PFAS compounds in both finished products and production processes, is that the proposed PFAS ban would significantly impact our member companies' production and R&D costs, availability of parts, product quality, profitability, and ability to manufacture. The proposed ban would likely eventually lead to business shutdowns. This would jeopardize tens of thousands of jobs in the EU, counting from our member companies' employee base alone. Not only would the current offering be under threat should the proposed ban come into force, but product development would halt for years in the meantime as companies would have to focus all their efforts on redesigning current products. Innovation for societally important objectives such as carbon neutrality would be impeded. 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. Efforts and investments put into modern technologies to stay on top of the technology race in the recent decades should not be ignored. It is clear that if the business enablers of European industry are blocked, manufacturing will concentrate in countries with less stringent regulations, such as in Asia, where environmental and worker protection are similarly at a lower level. Investors' interest in investing in European industry will naturally cease. All the talk about European security of supply and decreasing reliance on China during the Covid crisis and component shortage will have meant little. Type tests are mandatory for most markets, including EU and any material change with impact on the test result, requires that type tests need to be repeated. As these tests are very time consuming and some specific tests are extremely expensive, the tests have to be done after all(!) PFAS replacements have been completed, to avoid repeated testing of the same product. It is easy to see that such changes for entire product bases would paralyze European manufacturing for years if expected to be performed all of a sudden for all products across all applications and industries. Our member companies operate in a diverse range of industries that are vital to society. These include Power & Renewables, which provide sustainable energy solutions; Chemicals, which contribute to a wide array of products and processes; Oil & Gas, which remain key energy sources; Metals, Pulp & Paper, and Cement, which are fundamental to construction and manufacturing; Mining & Minerals, which supply essential raw materials; Food & Beverage, which ensure the availability of consumables; Water & Wastewater, which manage our most crucial resource; Marine, which supports transportation and trade; and Rubber and Plastics, which find applications in countless products. Further, the measurement industry supports the following societal functions: life science industries; early severe weather detection; safe and efficient airport operations; vaccine and medicament development; chip manufacturing; energy saving in data center cooling and ventilation optimization, as well as in heating or drying processes optimization; ensuring quality and safety of electric vehicle lithium ion battery manufacturing; biogas production; carbon capture; meteorological and climate monitoring; enhancing weather forecasting; reference level meteorological measurements and road safety infrastructure; advancing renewable energy sources, e.g. optimizing wind farms; ensuring a reliable electricity supply globally; improving product quality and yield in various industries utilizing liquid measurements; reducing carbon emissions in cargo shipping; optimizing food production; and monitoring air quality. Each of these industries plays a significant role in maintaining the functioning and development of societies across the globe. The proposed PFAS restriction in its current scope is a massive threat to these functions and industries. 4.2 Impacts on safety The utilization of PFAS substances in components such as power modules, capacitors, LCL filters, conformal coating PCBAs (Printed Circuit Boards Assembly), cables, batteries, semiconductors, chips, and charging resistors is crucial for the functionality of products. These components are particularly vital in safety-related areas where resistance to elevated temperatures, pressure, abrasion, and other extreme conditions are required. Semiconductor parts, cables, and coatings play a pivotal role in ensuring the reliability and performance of industrial electronic and electrotechnical products. This is especially true in heavy industry applications where a sudden malfunction could lead to catastrophic consequences. For instance, in nuclear plants, a malfunction could result in a nuclear meltdown, leading to significant environmental damage and potential loss of life. In marine applications, equipment failure could compromise navigation or communication systems, posing serious risks to crew safety and cargo. In oil refineries, a malfunction could lead to a fire or explosion, causing extensive property damage and posing a significant hazard to workers. Therefore, the reliability of these components, ensured by the use of PFAS, is of utmost importance in these and many other industries. The performance of these products is critical to the processes or industries that rely on them. While some of these components may contain PFAS, they are typically supplied individually or as advanced solutions for integration into final machine applications. This means there is no direct exposure to the users or environment. While PFAS polymers are currently the only comparable alternative for complying with official safety regulations applicable to the industry, our member companies are actively seeking replacements for identified essential uses of PFAS. The concept of essential use 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. 4.3 Impacts on the environment PFAS play a pivotal role in measuring and optimizing processes, thereby enabling the green transition and influencing product lifecycles. The unique properties of PFAS, detailed in previous chapters, allow for precise measurements and process optimizations. For instance, in the manufacturing sector, PFAS-based components can withstand harsh conditions, ensuring accurate measurements and efficient processes even under extreme temperatures or pressures. In the context of the green transition, PFAS-containing products contribute significantly to energy efficiency. Their heat resistance and insulating properties are utilized in various energy systems to minimize energy loss, thereby promoting sustainability. PFAS-containing products are also used to measure the processes in manufacturing and process industries. For example, our member companies' products are used to seal, safeguard and measure processes so that energy use can be optimized. If the quality of these functions and measurements declined due to components with less optimal properties, energy efficiency would decrease, leading to unnecessarily high energy use and therefore "waste", as well as higher greenhouse gas emissions, unless renewable energy sources were used. It should however be noted that the proposed ban would affect the upscaling of renewable energy production as well. 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. Measuring environmental aspects such as climate change, air quality, renewable energy production potential, the weather and severe weather phenomena, would be significantly hindered should products containing PFAS be banned. Needless to say, this could compromise not only the health and safety of people and societies, but also our global progress towards carbon-neutrality and slowing down global warming. Moreover, their durability extends the lifecycle of products they are used in, reducing the need for frequent replacements and thus minimizing waste. For instance, seals made from inferior materials may not perform as well or last as long as those made from higher-quality substances. Shorter product lifecycles can also result from using materials with lower durability or resistance to wear and tear. Products made from such materials may not withstand the rigors of use over time, leading to a need for more frequent replacements or even entire system redesigns. In addition, per- and polyfluoroalkyl substances (PFAS) play a significant role in the circular economy due to their widespread use in various components and products. The circular economy model aims to reduce waste and continually reuse resources, which often involves the recycling and repurposing of existing materials and products. PFAS, due to their unique properties such as durability, heat resistance, and chemical stability, are integral to many products, making them a key part of this cycle. However, the presence of PFAS in so many components also presents a challenge for the circular economy. If PFAS were to be banned, it would disrupt this cycle significantly. Given that a vast number of current components and products contain PFAS substances, a ban would mean that these items could no longer be reused, recycled, or repurposed as they currently are and as efforts and investments are made to further facilitate this. This would not only lead to an increase in waste but also pose a significant challenge for manufacturers who would need to find suitable alternatives for PFAS. Moreover, the transition to PFAS-free alternatives is not straightforward for reused, repurposed, and recycled products and components either. It requires time for redesigning products, trying to find PFAS- free alternatives from the second-life market (currently an impossible task), verifying their performance, and ensuring their proper function. A sudden ban on PFAS would also disrupt the second-life supply chains and create a significant demand for alternatives that the market might not be able to meet promptly. However, it's important to note that while PFAS have these benefits, we recognize that they are also persistent in the environment and can pose potential health risks. Therefore, managing their use in a way that harnesses their advantages while mitigating their environmental impact is crucial. This involves careful lifecycle management of PFAS-containing products, from design and manufacturing to use and end-of-life disposal or recycling. This is something that professional companies take into account in their processes, and Finland as a location for manufacturing and operating has advanced lifecycle service possibilities, including rigorous end-of-life handling. We call for careful consideration and planning to ensure a smooth transition towards more sustainable alternatives without disrupting advances in the green transition and the principles of the circular economy. 5. Derogations We believe that the criticality of our member companies' products and solutions to society, highlighted in the previous chapters, merits separate consideration in preparing far-reaching restrictions such as the proposed PFAS ban. Industrial B2B and B2G companies operate in a very different world compared to the B2C industry, with business clients setting their own requirements, public tenders often containing very strict safety, environmental, and quality requirements, and with applications that are often critical for the customer and either directly or indirectly affecting the health and safety of populations and the environment. Therefore, we would like to request an additional derogation to the proposed restriction and raise certain concerns. 5.1 Request for derogation Due to the wide and complex impacts of the proposed ban on our member companies' products and other similar products and technologies, as outlined in this document, the industrial electronics industry needs more time to prepare for a wide PFAS phase-out. Ideally, this would span over decades, focusing on the most harmful PFAS compounds and/or incorporating different product or component categories in batches, to allow for incremental substitution of these chemicals. A total ban in 1.5 years after entry into force is simply impossible for companies to prepare for and implement without closing down completely. Therefore, we request the following derogation, should the decisionmakers otherwise adopt the proposal in its current form: By way of derogation, paragraphs 1 and 2 shall not apply to industrial electronics in B2B and B2G applications until 13.5 years after EiF The derogations should be reviewed prior to the sunset date to verify that the derogation period is still sufficient for a smooth transition to PFAS-free products and technologies. The speed of product and process development all along the supply chain will determine this, and it is impossible to set a deadline carved in stone. There are growing concerns about the concept of right-to-repair and risk of sudden obsolence of products. Ensuring the ability to provide spare parts is crucial in meeting the requirements of the European Green Deal and transitioning towards the circular economy. Therefore, in addition, we request an unlimited derogation for spare parts: By way of derogation, paragraphs 1 and 2 shall not apply to spare parts manufactured and supplied for products and systems sold until 2050 5.2 Other concerns It should be noted that if derogations are granted for finished PFAS-containing components for a very specific (limited) industry, availability of these parts may become an issue if component manufacturers no longer have a business case for producing their components due to a dwindled market. It is also possible that the manufacturing of such components itself would not be covered by a derogation. This is a risk that regulators should take into account in decision-making. At present, there are very few known alternatives suitable for our PFAS applications. Replacing PFAS in our products would necessitate a comprehensive redesign of thousands of parts, requiring close collaboration with our complex, international supply chains. This is a highly time-consuming and iterative process that involves multiple rounds of testing, re-qualification, and often, recertification of the new designs. The proposed derogation periods, ranging from 5.5 to 13.5 years, do not provide sufficient time for industries to undertake proper redesigns. Given the trial-and-error nature of the redesign phase, we strongly advocate for granting derogations for fluoropolymers and fluoroelastomers with a minimum validity of 13.5 years.