Document nNavkB6k03gVm1roEz6R85V78
Ref. Ares(2016)1692687 - 11/04/2016
From:
@mmm.com]
Sent: Friday, April 08, 2016 5:48 PM
To:
(GROW)
Cc:
;
(ENV);
(GROW);
(GROW)
Subject: PFOA Proposal: Reliable Analytical Measurement
(ENV);
Dear
,
Following the PFOA stakeholder meeting organized by the Commission in March, I am coming back to you with our comments (attached) on the challenges we foresee with the implementation of the new proposed restriction limit (25 ppb), and subsequently the need for the 36 months transition timeframe as proposed by SEAC.
As mentioned during the stakeholder meeting, 3M is currently working on developing the improved analytical methodology to determine compliance with the proposed PFOA standard for fluoropolymers and related matrices.
We would be happy to meet with you and your colleagues to further discuss our work on the validated methodology, which might as well be relevant for you in light of the enforcement process. Please let us know when would be the best time for you to meet.
Thank you. Kind Regards,
Public Policy & Government Affairs, Europe
3M Europe, Hermeslaan 7 | 1831 Diegem (Brussels) Belgium
Office: +32.2
| Mobile: +32
@mmm.com | www.3M.com
From
@ec.europa.eu [
@ec.europa.eu]
Sent: Friday 3 July 2015 12:17
To:
@mmm.com>
Cc:
@mmm.com>;
@mmm.com>;
@ec.europa.eu;
@ec.europa.eu;
@ec.europa.eu;
@ec.europa.eu
Subject: [EXTERNAL] RE: PFOA proposal: request for a meeting with 3M
Dear
,
Thank you for your email regarding the proposal for a restriction of perfluorooctanoic acid (PFOA), in which you express concerns about the enforceability and practicality of the proposed threshold limit and the impact for several of your business units.
I can assure you that we are fully aware of the concerns about the threshold limit as numerous comments to this regard have been received in the public consultation which ended on 17 June 2015. The comments received in the public consultation can be found on the website of the European Chemicals Agency (ECHA) here: http://www.echa.europa.eu/web/guest/restrictions-under-consideration/-/substancerev/1908/term The Commission will keep under close scrutiny that the Committee for Risk Assessment and the Committee for Social-Economic Analysis of ECHA will give due consideration to these comments when drafting their opinion on the proposal for restriction.
With regard to your request for a meeting I would like to invite you to inform me and in DG Environment in writing, of any elements that are currently
missing in the comments received in the public consultation and which in your view would be essential for drafting the decision on the amendment of Annex XVII. We can then assess better whether a meeting will be necessary for obtaining further clarifications.
Kind regards,
-------------------------------------------------------------
European Commission
DG for Internal Market, Industry, Entrepreneurship and SMEs
Unit D.1 - REACH
Tel.: +32-2-
e-mail:
@ec.europa.eu
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From:
@mmm.com]
Sent: Wednesday, July 01, 2015 5:53 PM
To:
(GROW)
Cc:
;
Subject: PFOA proposal: request for a meeting with 3M
Dear
,
I am writing to you on behalf of 3M as we would greatly appreciate the opportunity to meet with you for an exchange of views on the joint German and Norwegian proposal for a restriction of Perfluorooctanoic acid (PFOA), PFOA salts and PFOA-related substances.
3M is a global technology company with a diversified portfolio of innovative solutions in transportation, security, healthcare, energy, water, and communications. As you may be aware, 3M has a somewhat unique perspective of this dossier as we had moved away from the manufacture of PFOA several years ago, today our business units are actively involved in the development of high quality alternatives and some of our businesses are also downstream users for this chemistry. Therefore, while we are slightly removed from the debate on the Restriction it will potentially have significant impact for several of our business units, indeed we already receive questions and concerns from our own customers.
In this context, we would very much like to meet with you to discuss the proposed Restriction, the process and to seek your advice moving forward. We are keen to meet with you, our EU REACH expert and a representative of our business units, to share our concerns, experience and perspective. For example
the challenges around the enforceability and practicality of the extremely low threshold limit (2 parts per billion) proposed.
We are also seeking a meeting with
and would be happy to
meet jointly should that be more convenient for you.
I hope you would be amenable to a meeting with us, I will be contacting your office in the coming days to discuss your potential availability.
Kind regards,
Public Policy & Government Affairs, Europe
3M Europe, Hermeslaan 7 | 1831 Diegem (Brussels) Belgium
Office: +32.2.
| Mobile: +32.
@mmm.com | www.3M.com
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