Document o9jGNn91a07B1JDqBBwOgbvNE

DocuSign Envelope ID: CF3C388846819EA6--F097DC1A-4-49ED0DC--BBF6BEC1-DB67CE1359EDEE0D44AD9AB4 Submission by the 3-D Printing Equipment Consortium to the PFAS Consultation The 3DPrinting Equipment Consortium is made up of several (mostly US) manufacturers of 3D Printing (aka additive manufacturing) equipment who are importing such equipment and ancillaries into the European Union to facilitate the growth of this progressive technology within the EU27. Additive Manufacturing presents momentous benefits in terms of product design, localized manufacturing, and efficiency of material use, which are completely in line with the objectives of the European Green Deal and, in particular, the Ecodesign for Sustainable Products Regulation (ESPR). Additionally, these technologies are central to the Fourth Industrial Revolution (Industry 4.0) as represented within the European Union by the Digital Transformation agenda. Specific members of the Consortium have previously submitted comments to both the first and second Calls for Evidence issued by the proponents of the proposed PFAS Restriction. However, disappointingly, it is noted that the comments submitted regarding the critical uses of fluoropolymers within the 3D printing process have not been recognised in the proposal submitted on 13th January 2023 and published in its current form on 23rd March 2023 at the launch of public consultation. It appears that the only items being considered for a potential timelimited derogation currently within the 3D printing/additive manufacturing realm relate to two nonpolymeric PFAS uses: The Consortium therefore believes that use of fluoropolymers specifically in 3D Printing Equipment represents a `missed use' in the context of this current consultation. While the Consortium is not contesting the legitimacy of the requests for the derogations already identified, the lack of reference to any use of polymeric PFAS within 3D printing represents a substantive omission, even though the quantities involved are very limited. The Consortium has identified several current critical uses of fluoropolymers in the 3D printing sector including, but not limited to, glass laminates for various resin reservoir assemblies, gaskets, lubricants, and specialty tubing. The performance of these fluoropolymer components is pivotal to the commercial use of 3D printing technologies for manufacturing of critical medical and dental devices, athletic equipment, components and manufacturing aids in automotive, industrial machinery components, and electrical industry components for major EU companies. As documented in earlier submissions by Consortium members, several alternatives have already been assessed for these applications, but NO viable alternative has yet been identified. Final 2023 Sept 21 DocuSign Envelope ID: F338489A-F9D1-49DD-BFBC-D6C39DED4DA4 The EU market for 3D Printing in 2020 was estimated at 4.23 billion and was anticipated to grow at a CAGR of 14% to 9.28 billion by 20261. The Consortium estimates that the impact of the nonavailability of appropriately functional equipment for Additive Manufacturing could therefore impact the EU-27 economy by in the order of 15-20 billion by 2030 if the Restriction comes into force by 2028, even though the emissions from fluoropolymer use are likely to be infinitesimal in practice. This reflects the fact that virtually all such equipment is dependent on fluoropolymers to some extent. The Consortium members therefore join their voice with the hundreds of companies who have already called for a general derogation for fluoropolymers2. Further information on this statement is available from: Jason Rolland on behalf of the 3D Printing Equipment Consortium t-abtroirkby: sjaSoin, 1OttatA,I. `..= U91- I-91-93223E443 Signature Jason Rolland Mi@carbon3d.com Name SVP , Materials Title Sep 21, 2023 Date Carbon Effiltlitge"y: 11/ /496' (Alitm-sLti Et5W-416FWULA4B... Signature Maxim Lobovsky Name CEO Title Sep 22, 2023 Date d by: EU3461)0b4A-142A Signature )(day zei f Name CEO Title sep 25, 2023 Date 5%10'1146thI Inc Futtop Signature Ric Ful op Name Founder and CEO Title sep 22, 2023 Date foul-gabs W 41" stratasys nth, Desktop Metal 1 https://www.mordorintelligence.com/industry-reports/europe-3d-printing-market 2 https://chemicalwatch.com/826977/hundreds-of-companies-call-for-eu-to-leave-fluoropolymers-out-of-pfas-restriction Final - 2023 Sept 21