Document o2wrv3Gzga3bj0azeqy9xBr3

Meeting with stakeholders on PFAS restriction dossier Short report to be shared with PFAS restriction group and the relevant stakeholder Date: 24 June 2021 Place: Online (90 minutes) Reporting Member State: o NO Participants (names and organization): o Chemours: Murli Sukhwani, Valentina Mauri, Maryan Walter, Jeffrey Sowder, Joachim Gerstel, Cor G. Verhart, Alisha Bellezza Loic Chereau Pietro Sonza Samer Saab @chemours.com @chemours.com @chemours.com @chemours.com @chemours.com @chemours.com o Alber&Geiger: Evi Moutsipai, @albergeiger.com Albi Alla, Walbergeiger.com Guustaf Borchardt, @albergeiger.com o Swedish Chemicals Agency: Jenny Ivarsson, @kemi.se o RIVM, the Netherlands: Martijn Beekman, @rivm.nl o Danish Environmental Protection Agency: Elisabeth Paludan, E@MST.DK (Toke Winther could not participate as planned) o Danish Ministry of Environment: Mikkel Aaman Sorensen, @rnirri.dk o Norwegian Environment Agency (NEA): Alice Gaustad, Anne Line Filtvedt, Audun Heggelund, Role of stakeholder/company: o Chemours is a major USbased company within the Fgas sector (and fluoropolymers). The company produces low GWP refrigerants, foam blowing agents and more, see presentation from Chemours from the meeting. o Alber & Geiger is a political lobbying powerhouse which represents their clients' interests on the highest EU levels and has been engaged by Chemours on the Fgases. Specific PFAS substance (if applicable): o Fgases, and the Opteon product line. Specific subject (if applicable): o Alber & Geiger contacted the Norwegian Environment Agency on behalf of Chemours with a request for a meeting to discuss the following: The future of fluorinated products (Fgases), broadly known for their uses as refrigerants, and their interplay with the ongoing EU per and polyfluoroalkyl substances (PFAS) restriction. Through Opteon, a brand of Fgases, Chemours is offering extremely low Global Warming Potential (GWP) solutions in refrigeration, air conditioning and heatpump applications (RACHP). Some Fgases ultimately degrade, partly or completely, to trifluoroacetic acid (TFA). The PFAS restriction has introduced FGases under its scope. FGases should, however, not fall under the PFAS restriction, as they do not pose significant environmental risks. They are in closed systems and recovered at the end of life, whereas they are not meant for release in the environment. Moreover, double regulation should be avoided. The existing EU FGas Regulation (No 517/2014) and MAC Directive (2006/40/EC) secure the safety of the substances' intended use throughout their entire lifecycle, while foreseeing a robust recovery mechanism. Stakeholder invited to provide the information presented in call for evidence or public consultation? Yes. Agenda Agenda item Introduction Chemours overview Alternative regulatory management options for Fgases Criticality of Fgases in a broad range of applications Illustration on key applications Wrapup content Background, objectives, participants Who are we, what we make Currently under assessment by dossier submitters and cannot be discussed in detail. However, Chemours may provide input. Overview of applications Overview of key properties of Fgases (vs. alternatives) Illustrate application requirements and technology tradeoffs Key messages Report o The participants had been introduced by email to the whole meeting group before the meeting, see above. o NEA thanked Chemours for getting in contact with the dossier submitters on the Fgases and the PFAS restriction and highlighted that the willingness to share information on the specific applications is appreciated. Stakeholder information is key to have a solid basis for the assessments and the development of a knowledgebased restriction proposal. NEA further explained that a key point with addressing the whole PFAS class is to avoid regrettable substitution that may arise if PFAS are regulated substancebysubstance or in small subgroups. In the PFAS restriction group Norway together with Denmark have taken responsibility for the assessment of the application of Fgases. o Chemours presented an overview of their company, including their European activities. Chemours has activities in six countries in Europe. Main products in Europe include fluoropolymers and Fgases, the latter being the topic for the meeting. o A policy perspective on the Fgases was introduced by Chemours with the main message being that low GWP HFOs facilitate decarbonization by enabling improvements in energy efficiency that meet the longterm needs of all relevant applications. It was pointed out that the current revision of the Fgas regulation is an opportunity to address any unaddressed issues with F gases. o The presentation continued with a discussion of criticality of Fgases in a broad range of applications, and it was underlined by Chemours that Fgases enable the EU green and digital transition. o The presentation then proceeded into more detailed illustrations of four specific applications: commercial refrigeration, heat pumps, mobile air conditioning (MAC) and foam blowing agents. o The Chemours presentation concluded with a wrapup and some key messages: o Fgases are key to achieving the European Green Deal's objectives. Restricting Fgases in a way that generates regulatory overlap and uncertainty could slow down decarbonization of key sectors and hinder innovation. o Safety and Total Cost of Ownership (TCO) are critical considerations associated to flexibility in the choice of the refrigerant. o Fgas regulation revision & MAC Directive are key tools to manage circular economy challenges on Fgases. o Chemours underlined that they look forward to further cooperation with the dossier submitting authorities and kindly offered assistance from their experts in any assessment under the PFAS restriction proposal. o Further details may be found in Chemours' presentation which was shared after the meeting. o NEA explained that the next step is a 2nd Call for Evidence that will be launched in July wherein we are seeking to quality check our current information and assessment. In this call for evidence a summary of the different applications will be published together with some specific questions. We are happy to receive information from Chemours either in the 2nd Call for Evidence, or as a separate action. o Furthermore, NEA pointed out that one of the particular challenges with Fgases is to find balanced and justified assessments of for which applications fluorinefree alternatives may be introduced, and for which applications there are no alternatives, or when we can expect that alternatives are ready or on what conditions they may be introduced. o To the Chemours presentation the authorities asked about leakage management in mobile air conditioning, and about TFA formation from some Fgases, with reference to a study showing elevated concentrations of TFA in groundwater in Denmark. The study may be found on the below links (in Danish only, but it should be possible to translate): https://mst.dk/service/nyheder/nyhedsarkiv/2021/jan/nytstoffundetigrundvandet/ https://mim.dk/nyheder/2021/jan/mangeforekomsteraftfaopdagetigrundvandet/