Document mB20BL3NNZK3VQEoRYNBXdB2b

PFAS derogations requests for spare parts and pre-owned products We represent over 45,000 businesses across Europe The voice of digitally transforming industries platform services data analytics software & hardware cybersecurity telecoms semiconductors cloud technology Healthcare Manufacturing Finance Buildings Mobility 41 NATIONAL ASSOCIATIONS 100 COMPANIES 60+ Categories of uses identified in electronics* Application area Coatings Printed circuit boards High voltage/power applications Cables and connectors Components Mechanical applications Displays Batteries Fire prevention Heat transfer Chemical equipment Chemicals Others *Excluding semiconductors, energy, medical, automotive, aerospace Details Capacitors, dielectric films Electret films in microphones, sensors Gaskets, sealing Microphone/speaker vent membrane Piezo in acoustical equipment Rubber parts in image forming process in printers Annex XV report on electronics 1 Apart from proposed 12-year derogation for the semiconductor manufacturing process, no derogations for the electronics sector No computing / communications products will meet 18 months transition period Huge economic impact, business closures 2 No derogation for spare parts of existing products No spare parts can be made available despite the requirement to do so under the EU Ecodesign directive/regulation As is, restriction will lead to premature obsolescence of products on the market 3 No derogation for refurbished or second-hand products / articles already on the market Use and emissions from electronics are less than 1% of the total PFAS use and emission Derogation needed | Spare parts to repair consumer electronic products 7 years derogation needed to avoid premature obsolescence of existing consumer electronic products Impractical to design, qualify & produce PFAS-free spare parts for consumer products manufactured before PFAS restriction Precedents in other REACH substance restrictions REACH restriction 68 on C9-C14 PFCAs (belong to PFAS family) Compliance with other EU legislation EcoDesign regulation mandates spare parts for electronic displays until at least 7 years after placing the last unit on the market Guarantee obligations in proposed Right to Repair Directive Impact of no exemption 77% of EU prefer to repair a consumer product than buy new one 30% of EU have repaired a product within past six months EU consumer electronics repair sector employs 104,000 people and generates 14.5 billion Euros revenues Derogation needed | Spare parts to repair professional B2B products 15 years derogation needed to avoid premature obsolescence of existing professional b2b electronic products Additional considerations apply for equipment with long lifetimes (e.g. telecommunication networks, industrial HVAC, industrial printing,...) lifetimes and contracted maintenance periods usually extends to 10 to 15 years in the product's first application (up to 25 years in some cases) The availability of spare parts is essential to realize the lifetime potential of such products In many cases spare parts for professional users have already been manufactured and are commercially available for customers at short notice, which is often contracted No drop-in replacements (especially for fluoropolymers) PFAS-free spare parts are not drop-in alternatives as dimensional changes from alternative materials generally necessitate product re-design For products that are no longer commercially available it is unrealistic to design PFAS-free spare parts Extended `repair as produced' provisions in EU legislation RoHS Directive Art. 4(4) + 4(5) provide that restrictions do not apply to spare parts for products that were placed on the market before an exemption expired, or spare parts recovered from products placed on the market before restrictions applied Derogation needed | Re-supply of pre-owned products Impractical to expect products manufactured before PFAS restriction to comply Without an exemption, resale of pre-owned products will be banned Functional products would be discarded as waste No additional PFAS emissions (products already on market) Normal practice in EU regulations and directives REACH restrictions 68, 51, 45, 20, 19, 18a, etc Persistent Organic Pollutants (POPs) Regulation All CE Marking directives and regulations Compliance with ESPR Requires products to be easier to refurbish and reuse products Impact of no exemption No EU second-hand car sales (20% of components contain PFAS) Global support from 25 leading industry associations around the world Questions for discussion 7 years derogation for spare parts to repair consumer electronic products What additional information is needed to substantiate this derogation? 15 years derogation for spare parts to repair professional B2B products What additional information is needed to substantiate this derogation? Derogation for re-supply of pre-owned products What additional information is needed to substantiate this derogation? General Has impact of PFAS restriction on circular economy, right to repair and product longevity been considered? How should we estimate the number of companies / people affected? Number of companies that manufacture electronic products? Number of people / companies that use electronic products? #AStrongerDigitalEurope @DIGITALEUROPE linkedin.com/digitaleurope Thank you for your attention and feedback!