Document nkpz90reBbQMa8vjBX197K4X8

Application for derogations from PFAS REACH restriction for chemicals as refrigerants Refrigerants are chemicals, which are called as fluorocarbons, including CFCs, HCFCs, HFCs and HFOs. Due to ozone depletion, global warming and climate protection, Montreal Protocol, Kyoto Protocol, and Kigali Amendment have taken effect and carried out. Therefore, this PFAS REACH restriction does not need to cover these chemicals again. These chemicals are used in gas status. HFCs, for example, includes: HFC-134a, Chemical name 1,1,1,2-tetrafluoroethane, CAS No. 811-97-2, having the formula CF3CH2F. HFC-125, Chemical name 1,1,1,2,2-pentafluoroethane, CAS No. 354-33-6, having the formula CF3CHF2. HFC-143a, Chemical name 1,1,1-trifluoroethane, CAS No. 420-46-2, having the formula CF3CH3. HFOs, for example, includes: HFO-1234yf, Chemical name 2,3,3,3-tetrafluoropropene, CAS No. 754-12-1, having the formula CF3CF=CH2. HFO-1234ze, Chemical name 1,3,3,3-tetrafluoropropene, CAS No.29118-25-0, having the forlula CF3CH=CHF. HCFO-1233zd, Chemical name 1-Chloro-3,3,3-trifluoropropene, CAS No. 460-71-9, having the formula CF3CH=CClH. These compounds can form trifluoroacetic acid (TFA) via atmospheric degradation pathways. For example, HCFC-123 forms CF3CClO and further forms TFA, HFC-134a forms CF3CFO and further forms TFA, HFO-1234yf forms CF3CFO and further forms TFA, and HCFO-1233zd(E) forms CF3CHO and further forms TFA. Please refer to Figs 10 and 11 in the attached article by S. Madronich and etc. published in June 2023. In a word, fluorinated gaseous chemicals can enter into the atmosphere and breakdown into intermediates and further form TFA. For details, please refer to Figs 10 and 11 in the attached article. TFA does not accumulate in animal bodies, which shows a little risk. TFA is an acid when formed in the atmosphere but on reaching the surface (soil or water) it forms salts with alkali metals (e.g., sodium, potassium, calcium, etc.). Because of its lack of reactivity, TFA salts are persistent in the environment and estimates of half-life are uncertain but could be in the range of centuries or millennia. This persistence is not a major concern because it does not react with biomolecules. TFA and its salts are easily excreted by animals and do not bioaccumulate in food chains. Salts of TFA have low toxicity to animals and plants and there are very wide margins between current/projected exposures and toxicity values. Therefore, TFA does not accumulate in animal bodies, which shows a little risk. Please refer to Section 3.8 in the attached article. Based on the comprehensive study in the attached article, we apply for the derogations from PFAS REACH restriction for the chemicals as refrigerants. Attachment: S. Madronich and etc., Changes in tropospheric air quality related to the protection of stratospheric ozone in a changing climate, Photochemical & Photobiological Sciences, Published online: 13 June, 2023.