Document ozJKOkd6qVoa5aygMegE9N3o

Rheinmetall Waffe Munition GmbH District Silberhuette, Kreisstrasse 2 06493 Harzgerode, Germany ECHA Public consultation on PFAS RHEINMETALL 10.07.2023 Holger Krause Abteilung C3SGG Tel. +49 39484 70225 Fax. -590. rheinmetall.com Public consultation on PFAS Non-confidential The Rheinmetall Weapon and Ammunition GmbH (RWM) is providing this initial response to the public consultation on the proposed EU restriction dossier for PFAS to bring attention to our dependence on PFAS substances, including many fluoropolymers, that are within scope of the current restriction proposal and for which there are no alternatives available today. The RWM is the only producer of large calibre ammunition in Germany and have several other products in the defence sector with a large variety of customer countries. In addition to PFAS-reliant uses for the RWM already identified, there are likely to be further missing uses. These are not visible today given the complexity of supply chains and the limited visibility on PFAS substances many of which are not required to be disclosed in Safety Data Sheets or REACH Article 33 declarations. Accordingly, the defence industry and (other) niche applications being key areas of concern for the RWM have been flagged in the restriction proposal as uses not yet researched in detail. Supply chain enquiries requiring sectoral coordination have been started, but responses may not arrive within existing REACH consultation windows. This challenge is aggravated by the absence of an official list of CAS numbers. For the RWM the proposed Universal PFAS restriction presents significant risks of wide-spread obsolescence for materials and processes and unpredictable side effects. Advisories received so far of planned PFAS-based product withdrawals by manufacturers and consequent specification changes by users show that this restriction proposal is already causing impacts that have to be managed to ensure business continuity for affected applications. It is uncertain today whether and to what extent these first cases can be managed without negatively affecting our activities and product performance. The defence sector is heavily regulated and with many product specific requirements, which need to be given full attention when assessing alternatives and impact of withdrawal. Our sector is reliant on PFAS substances in a wide range of applications due to their unrivalled performance properties, making them the only choice currently available to meet the demands required by many uses in products and processes across the sector. PFAS are essential for the continued operability of products currently in service which may have a service life lasting more than 40 years as well as for the manufacture of new products, spare parts and future technology programmes. Rheinmetall Waffe Munition GmbH Branch Pyrotechnik Silberhuette District Silberhuette, Kreisstrasse 2 06493 Harzgerode, Germany Phone +49 39484 70-0 Fax +49 39484 70-590 Registered Office: Sildheide Luneburg Local Court, C/R no. HRB 201403 Commerzbank AG, Dusseldorf IBAN: DE34 3004 0000 0172 0457 00, BIC: COBADEDD XXX VAT No.: DE 811144119 Chairman of the Supervisory Board: John Joseph Abunassar Management Board: Rene Gansauge (Chairman), Roman Ohne, Matthias Koll www.rheinmetall.com Contact information: Juliane Dannroth Vice President Health, Safety and Environment Email: @rheinmetall.com Holger Krause Team Leader REACH Email: @rheinmetall.com RHEINMETALL