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PFAS in Aerospace Executive Summary The following executive summary is taken from a full report produced by Risk & Policy Analysts Ltd (RPA) for DuPont Speciality Products USA, LLC relating to the use of PFAS within the aerospace sector. In March of 2023, five Member States published a draft restriction dossier recommending the implementation of an EU REACH restriction relating to the manufacture, use and placing on the market of all substances meeting the OECD definition of per- and polyfluoroalkyl substances (PFAS). A socioeconomic assessment was conducted to provide information on the societal and economic value of the manufacturing and use of polymeric PFAS (fluoropolymers and perfluoroelastomers) containing articles in engines for aviation. The outcome of the socioeconomic assessment and other evidence will be utilized to inform the need for a derogation in the PFAS Restriction for the use of PFAS, fluoropolymers and perfluoroelastomers in aviation. The inherent physical properties of fluoropolymers and perfluoroelastomers are critical articles in aviation because of their ability to meet key performance criteria which are required for safety and efficient operation under harsh conditions. These critical criteria include operating under wide fluctuations in temperature, reducing the wear in moving parts by reducing friction, supporting lightweighting for fuel efficiency and increased payloads, operation of critical safety equipment, while also imparting resistance to radiation and prevention of hazardous conditions from leaks of aviation fluids. More specifically, these key attributes are necessary for safe and proper functioning of aircraft engines and fuel, landing, communications, navigation, and actuation systems. Although the use of PFAS in aviation is complex and extensive, the specific focus of this socioeconomic assessment includes an evaluation of the societal benefits and economic value of Vespel products used in aerospace which include a polyimide compounded with polytetrafluoroethylene (PTFE) and Vespel products that contain PTFE fibres, fluorinated polyimide resins (6FTA/ 6FDA), and Kalrez, a perfluoroelastomer (also known as FFKM) as it relates to their critical contributions to the aerospace industry. The socioeconomic assessment estimated that a restriction on fluoropolymers and perfluoroelastomers such as Vespel and Kalrez would likely result in a severe disruption of the EU aerospace sector and adjacent sectors that rely on air transport, with total losses over the period June 2026 to 2030 estimated at over 550 billion. Via consultation with aircraft manufacturers, it has been estimated that around 400,000-500,000 PFAS-containing components are likely to be present in a smaller short-haul commercial aircraft, whilst in larger aircraft the number of PFAS-containing components will likely be in excess of 1 million. These wider aviation uses are highlighted in section 4. Due to this widespread use of Vespel parts and shapes throughout an aircraft, a PFAS restriction would impact multiple manufacturing chains and raise numerous issues for sourcing alternatives (See Section 7). Moreover, the consultation data and findings indicate that the societal benefit, economic value and avoidance of unintended consequences of alternatives outweighs the negative human health or environmental impacts of their use in aviation. The manufacture of Vespel parts and shapes (within and outside of Europe) and Kalrez perfluoroelastomer parts (only outside of Europe) occur in industrial settings where the use and waste management practices are tightly controlled to prevent or minimize exposure to human health or the environment. In total it is estimated the combined DuPont emissions and machine shop emissions to waste is 3.5 kg PTFE per year via manufacture. When used in aviation, Vespel and Kalrez products are used only where performance criteria are required and where the extension of the useful lifetime and safe operations of aircraft is critical. These examples of polymeric PFAS used in aviation are not PFAS in Aerospace SEA (Public version) RPA & ARCHE Consulting | i single use components as their physical properties allow extended use and minimization of maintenance or failure over the lifetime of the aircraft. It is also important to note that the restriction would also apply to import of Vespel and Kalrez OEM (original equipment manufacturer) replacement parts needed for repair of existing aircraft components which may be present in an aircraft with a 25 to 50-year lifespan. The absence of a derogation in the restriction proposal will impact new aircraft as well as the ability to maintain and repair aircraft already in the various stages of service in Europe. The findings indicate that societal benefits and the economic value that Vespel products which use fluoropolymers and the perfluoroelastomer Kalrez (also referred to as FFKM) contribute to aviation outweigh the risk to human health and the environment. It is important to note that fluoropolymers used in Vespel products and FFKM belong to the class of high molecular weight fluoropolymers/perfluoroelastomers that are distinct from non-polymeric PFAS substances, whereby they have different physicochemical, toxicological, and environmental profiles compared to other PFAS of concern. PTFE, the 6FTA/ 6FDA fluorinated resins, and FFKM are not bioavailable and are therefore not bio-accumulative. Although they are classified as persistent, they are not classified as bio-accumulative, nor are they classified as toxic. Therefore, they fail to meet the criteria for classification as PBT. In aerospace engines, Vespel products are used for light-weighting while also providing the added benefit of reducing the mechanical wear between moving components and the potential for failure. Examples of this include the use of Vespel wear strips between the fan blade and the rotating core, or as bushings in the compressor on the ends of variable stator vanes. Kalrez which is a perfluoroelastomer (FFKM) is used in final form as oil seals (O-rings) in aviation. These Orings are used in the engine oil system of aircraft where sealing between components is subject to extreme temperatures and corrosive and hazardous aircraft fluids. Vespel and Kalrez as articles do release minor emissions during use (estimated at between 175-225 kg PFAS per year emitted globally) and are either incinerated or landfilled at end of life. Based on the properties of PTFE, it is not expected that any leaching would occur should aircraft components containing PTFE be landfilled. If incinerated, the fate of PTFE and FFKM will depend on the temperature and process of the incinerator used. Studies conducted on various fluorinated polymers including PTFE, suggest that these fluoropolymers can be fully mineralized under best available technique incineration conditions. Therefore, end of life disposal practices of these products is unlikely to contribute significant PFAS in the environment. In addition to the socio-economic analysis, this report also includes an analysis of alternatives (AoA) in which the current availability and feasibility of potential alternatives was assessed. In this analysis, alternatives were assessed in comparison against Vespel and Kalrez based on their technical feasibility, economic feasibility, commercial availability, their hazard profile, and the potential for unintended consequences of substitution. For Vespel, the alternatives evaluated were bronze, isostatic Vespel (which is Vespel without PTFE) and other thermoplastics such as PEEK and PAI. Bronze and thermoplastics were both identified as not technically feasible due to a higher co-efficient of friction, the need to redesign other engine parts (bronze), the weight increase (bronze) and an inability to operate within the required temperature range (thermoplastics). Whilst isostatic Vespel would be able to meet only some technical criteria in some applications, this alternative would not meet the criteria in harsh conditions such as high temperature are needed. For alternatives to Kalrez, the alternatives identified were fluoroelastomer (FKM), Hydrogenated Nitrile Butadiene Rubber (HNBR) and Silicone (VMQ). All three alternatives were found to not be technically feasible based on inadequate performance over the needed range of temperature and/or PFAS in Aerospace SEA (Public version) RPA & ARCHE Consulting | ii chemical resistivity. As FFKM offers the highest performance of currently known chemistries, any use of Kalrez indicates end uses where only the best performing product can be used. As such, no presently identified potential alternatives can replace Kalrez in the relevant applications. In addition to the technical, economic and hazard criteria it should also be noted that in the aerospace sector the introduction of new or alternative materials is a complex and time-consuming process. For example, Vespel products are used on nearly all civil airline jets (Boeing 777, 737 and 787, Airbus A320 and A220 series) and turboprops in service, as well as military jets and helicopters. To introduce design and engineering changes in aircraft, an alternative will need to be identified, certified, qualified, validated and commercialized which can take over 30 years to complete. These processes take a long time because of the stringent testing requirements to determine airworthiness and safety. A failure in testing at any stage in this process results in the need to return to earlier stages. The derogations proposed in the restriction dossier have a time limit of 13.5 years, however, based on the aircraft lifecycles and qualification periods, this will not be enough time to implement an alternative into the aerospace sector, even if feasible alternatives were to be identified. This thorough assessment supported with evidence submitted by aircraft manufacturers suggests that it is highly unlikely that alternatives to Vespel and Kalrez currently exist or can be discovered within the proposed derogations. Because Vespel and Kalrez parts are essential in the safe and efficient operation of aircraft, the lack of a derogation to further explore alternatives would significantly disrupt aviation in Europe. This disruption would have a ripple effect to adjacent supply chain who rely on aviation as a key component of supporting the critical functioning of society by movement of people and transport of goods. The disruption throughout supply chains from June 2026 (year of restriction transition period end) to 2030 is estimated to exceed 550 billion. Abradable seals Abradable seals Figure 0-1: Vespelcomponents used within aircraft engine manufacturing Source: DuPont consultation PFAS in Aerospace SEA (Public version) RPA & ARCHE Consulting | iii Risk & Policy Analysts Limited Suite C, 2nd floor, The Atrium, St Georges Street Norwich, Norfolk, NR3 1AB, United Kingdom Tel: +44 1603 558442 E-mail: post@rpaltd.co.uk Website: www.rpaltd.co.uk If printed by RPA, this report is published on 100% recycled paper PFAS in Aerospace SEA (Public version) RPA & ARCHE Consulting | 4