Document k9pK3jqgYxZ5RwMd33866dvkV

Title: Spare parts, wear parts, maintenance and repair To be filled in the text box "general comments" ZVEI e. V., the German Electro and Digital Industry Association, represents an industry with an annual turnover of about 225 bn. Euro and 906 thousand employees in 2022. It is one of the most important industrial associations in Germany and represents the interests of a high-tech sector with a very wide and extremely dynamic product portfolio. Our more than 1,100 member companies employ around 90 per cent of the electro and digital industrys workforce in Germany. Our members include global players, medium-sized and family-owned businesses. Most of the electrical equipment covered by the members of ZVEI have a long lifetime and are by this very well prepared for the sustainable targets under preparation by the EU. For example, electrical equipment for trans- mission and distribution are designed since decades for lifetimes of 40 years and technically, economically and ecologically it is possible in many cases to further extend this lifetime, in some cases with some maintenance or refurbishment. Original design of the installed base and also actual manufactured and installed products are containing PFAS in various areas, based on specific functions and needs verified by type tests. Maintenance and repair require spare parts to bring the product back in a condition to fulfil the technical requirements and performance needed for the task. In the majority of cases, it is required to use the "repair-as- produced-principle", as otherwise the technical performance might change and/or test certificates become invalid, which will revoke the permission of use. An exclusion to use PFAS containing spare parts or wear parts is crucial due to the serious risk of a sudden end-of-life for a wide variety of long-living products, manufacturing equipment and infrastructure after the re- striction's application date. The current restriction proposal prevents the transition towards a circular economy and undermines fundamental sustainability goals, e. g. the "repair-as-produced-principle" constituted in EU product legislation such as Directive 2009/125/EC, which allows products already placed on the Union market to be restored to their original condition without undergoing a conformity assessment again. As an example, the segment of transmission and distribution of electricity is strongly affected. The lifetime of >40 years is practically reached by well planned and executed maintenance. For example, in gas circuit breakers a PTFE nozzle has a very specific and extremely important technical function. There is no replacement material known which can substitute PTFE here. In case this com- ponent needs to be replaced during maintenance or repair because of wear or defect, there is no alternative to the original part. If a new PTFE part cannot be used, the circuit breaker cannot be repaired and is not allowed to be energized again. This will not only take one breaker or bay out of service, but in principle it might need to take a complete substation from the network. The replacement of a switchgear by a new one will take 5 years or more of planning and execution. The small defect will therefore have a long-term disturbance of the network as result. In case more than one of such case happens in the network in close distance (n-1 principle), the consequence would be long term outage of electricity with catastrophic consequences for the society and the industry and will generate dramatic costs. A total blackout for only one hour of a city like Frankfurt/Main will cost about 600 million Euro. Moreover, critical as well, PTFE nozzles are also used in auxiliary circuit breakers in power labs where maintenance applies very often. A ban would lead to loss of testing capabilities in Europe, which will also impact establishment of new PFAS free T&D equipment. Household appliances provide another example: So far, no technically and economically feasible alternatives for tubes with food contact made of fluoropolymers in household appliances like for example coffee machines have been found and even if alternative materials are found within the next couple of years, it is very unlikely that 1:1 alternatives exist. As a consequence, a tube made from a potential alternative material might be heavier, larger, have a larger bending radius etc. than the currently used tubes made of FEP or PFA, which means that they simply would not fit into the appliances that are currently on the market which are designed as compact as possible. Therefore, an exemption for spare parts is urgently needed as otherwise, whole appliances might not be able to be repaired anymore just because simple parts like tubes could not be replaced anymore. For this we ask for the segment of electrical equipment covered by the members of ZVEI (if not in general): Spare parts and wear parts used for the maintenance and repair of products already placed on the market prior to the validity date of the restriction, taking care of any exemption for components or technologies, need to be exempted from the regulation without time limitation until the equipment has reached its practical end of life.