Document kmxG1g1pmLLOvVXrJ8jnom6E

FEF the leading association for equipment manufacturers and their servicing divisions, serving the UK retail petroleum market ... Federation Forecourt Equipment Secretaries:- Mr C Dunn-Meynell, 57 Albany Street, London NW14BT Telephone: 020 7935 8532 email: =fef.org.uk Please reply to: Secretariat ECHA -- European Chemicals Agency P.O. Box 400 00121 Helsinki Finland 21 September 2023 Proposed restriction of around 12,800 per- and fluoroalkyl substances (PFAS) under Annex XV of REACH PFAS are widely used by the Forecourt industry in components such as:- Batteries, in separators, binders, gaskets, seals, electrolytes Electrical motors and combustion engines Lubricants, coatings and greases of surfaces, to e.g., reduce friction Plastic parts of EEE as fluoropolymers are the most flame-retardant plastics Seals and gaskets Cables and their sheathing Industrial installations and manufacturing equipment The above list is not exhaustive. Some PFAS are highly dangerous while others are benign. There has been a massive Industry concern. A risk based assessment approach would be preferable in determining any restriction on the use of PFAS. Release of PFAS from equipment could only occur when a component is replaced or when it reaches the end of its life. In such cases, this can be managed to ensure the PFAS is not released into the environment and can be safely disposed of, recovered, recycled or reused. The main impacts on forecourt equipment are anticipated to be bans on Viton (DuPont name for its synthetic rubber and fluoropolymer elastomer, commonly used in O-rings and other molded or extruded products) and PTFE (Polytetrafluoroethylene). However, there are so many PFAS that there will be some that you do not realize are used in components. Alternatives are either more expensive or simply not currently available. Identifying them from your supply chain without specific tests would be difficult and expensive. Our position is that there should be an exemption for essential industry uses, or at the very least a derogation to give time to identify where PFAS is used and to research alternatives. There is a concern that if the bans come into force, chemical companies may not continue to manufacture them due to the risk of future litigation (group actions have already started in the US), so supply, even with a permitted use, may be problematic. In a document from ECHA there is a proposed 13 year derogation for petroleum industries. It is not yet clear what this would cover. There is no such derogation announced for new or synthetic fuels which need to also be included if eh EU targets for carbon reduction are to be achieved. Yours faithfully Mr Crispin Dunn-Meynell General Secretary