Document p2mgQKX5ge42GNaNY3YMRmKbD

I. Derogation Request Page 2 II. Description of the End Use Page 3 Table 1. Selected Aerospace and Defence Products Product Illustrations Description Gore Skyflex Aerospace Materials Gaskets and sealants are used in aircraft structures to seal panels and protect surfaces mechanical forces and harsh environments that can severely damage aircraft structure. They protect against ingress or leak of fluids, minimise corrosion, reduce the impact of abrasion, and fill gaps. The materials make aircraft maintenance faster and simpler because they are lightweight, do not need to be cured, and are flexible to conform to any shape. Cables used in aircraft systems to deliver high quality signals even in demanding conditions2. Gore Aerospace Data and Power Cables Data cables Compact, flexible, and routable cables designed to significantly improve system performance in an aircraft3. Fibre optic and copper high speed data cables transmit MIL-STD-1553, ethernet, CANBus, FibreChannel, IEEE-1394b, MIL-STD-1760, discrete signals, and other protocols to operate critical flight control systems, passenger support system, and mission systems equipment in Civil and Defence Aircrafts. Data cables provide a nervous systemlike network of reliable signal transmission needed to protect soldiers and aircraft with fully functional and finely tuned aircraft Page 4 Gore Microwave / RF Assemblies4 Gore Space Cables and Assemblies. Temperature Capacitors Page 5 survivability equipment and electronic countermeasures. Power cables Used to power generators, operate flight controls, and support mission systems. Mission systems include radar and Aircraft Survivability Equipment such as Missile Warning Systems and Threat Jamming Equipment in Defence applications. Used to transmit and receive analog radio frequency (RF) signals to maintain communications, operate radar, test mission systems, and feed Aircraft Survivability Equipment such as Missile Warning Systems and Threat Jamming Equipment in Aircraft and other Defence equipment. This product category also includes Microwave Cable Assemblies. With respect to modern electronic warfare (EW), defence forces must be able to promptly and accurately detect enemies and take appropriate actions before enemies do. Advanced radar technologies rely on microwave cables to enable this early detection capability. Same properties as Aerospace Data and Power Cables and Microwave / RF Assemblies but designed to survive the harsh radiation, extreme temperatures, and vacuum of space. Capacitors deliver stable voltage and capacitance at elevated temperatures. Key performance characteristics include reliable self-clearing, low dissipation factor, and thermo-mechanical stability. This enables significant design advantages in the Aerospace industry to improve power density in line with the Electrification megatrend to reduce global emissions. Table 2. PFAS used in Aerospace and Defence Products Product Type of PFAS CAS Is this PFAS a PLC GORE SKYFLEX PTFE 9002-84-0 Yes Aerospace Materials PTFE 9002-84-0 Yes GORE Aerospace Data and Power Cables FEP 25067-11-2 Yes PTFE 9002-84-0 Yes Gore Microwave / RF PFA 26655-00-5 Yes Assemblies FEP 25067-11-2 Yes ETFE 25038-71-5 Yes PTFE 9002-84-0 Yes Gore Space Cables and Assemblies ETFE 25038-71-5 Yes PTFE 9002-84-0 Yes Capacitors ETFE 25038-71-5 Yes III. Reference in Restriction Proposal Page 6 Page 7 IV. Need and Justification for a Derogation Page 8 Since the UA has been created, we have also obtained additional information on use of fluoropolymers in capacitors. Page 9 Page 10 Table 3. Comparison of Alternative Materials for Sealant Applications in A&D Page 11 - Page 12 - Page 13 Page 14 Page 15 Page 16 Table 4. Substitution Steps for Developing an Alternative to Fluoromaterials in Aerospace & Defence Applications Steps for substitution What activities does this step entail? Time required for step 1. Identification and development of new material 2. Product development an iterative stage of R&D, (re)formulation and lab testing 3. Qualification and/or Validation - testing and validation with customers and/or external testers 4. Production - implementing the manufacturing plan for the alternative, including a possible pilot phase, regulatory approval, and modifications to the production line. 5. Integration and qualification into end system or vehicle Development and testing of product in-use with end device Identify and develop suitable alternative materials. Product Development from lab discovery to pilot scale. Optimise material for specific application requirements Reliability testing of manufactured components. Supply chain development (new production capabilities and capacity for mass production). Development cycle of new end device Total Unknown Estimate > 20 years 2-3 years 2-5 years 2-5 years 3-7 years Unknown Estimated >29 years - Page 17 - Page 18 Annex I Alternative Assessment Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 o o o o o Page 25 o o o o o o o o o o o o o o o o o Page 26 Capacitors Page 27 Page 28 Page 29 Page 30 Page 31 Annex II Overview of attachments supporting the request - Page 32 Bibliography Page 33