Document pB40zN0kzdXx3Mz3nDRzpybxX

9/18/2023 EU^OCUS r_J GROUP BUILDING COMPROMISES FOSTERIMG BREAKTHROUGHS < Chemours PFAS Restriction under REACH: What Way Forward for Fluoropolymers & F-Ga 18 September 2023 Purpose of the Meeting 1. Introduction 2. Annex XV: share our observations 3. Economie impacts: share our assessment in case of a ban of Fluoropolymers & F-Gases altogether on the key sector of the economy 4. Discuss possible way forward EU^OCUSj 1 9/18/2023 Approach of the Five Countries- some concerns "Universal Ban" Annex XVII restriction to apply to ail PFAS (fulfilling OECD dfinition), 18 months of 'transition period' after Entry into Force (EIF). Drogations pesticidal active substances biocidal active substance human and veterinary mdicinal products Dominating "anti-PFAS" narrative is based on old tech"logies based PF0S< PF0A ~ banned SmCe more than 10 years m Europe Ban on manufacture, use and placing on the market As substances on their own As a constituent A mixture An article 1 25 pp tor any PFASs 2 250 ppb for sum of PFASs 2 50 ppm ' for PFASs Time-limited drogations = "delayed ban" applied either 6.5 or 13.5 years later from EiF tentative drogations proposed in square brackets [...] where data is not enough EUrFOCUSj ~ -GS0U[' 3 PFAS Restriction Timeline (2023-2026) TODAY Restriction Dossier Submission } Public Consultation ! Publicjtkm il fcbivjiy) j RACadopts opinion and draft SEAC opinion ECHA Opinion Consultation on draft SEAC opinion | | 1 1 ljlit/ Chctk j Cui/uirii yifwik 13 Jan 2023 22 Mardi 2023-Sep 20 23 Nov 2023 Nov 2023-Jan 2024 Feb-Mar2024 Council/EP Scrutiny (tbc) Entry into force 1 Draft Annex j ! XVII Restriction | adopted (tbc) Q1-Q3 2025 (tbc) Q3 2025 (tbc) Q42025 Early 2026 (tbc) PREPARATORY PHASE ECHA PHASE COMMISSION PHASE SCRUTINY/ENTRY INTO FORCE PHASE STAGE 1: STAGE zil STAGE 3: STAGE 4: STAGE 5: Annex XV Prparation I public | I Con5uitatioj|i Opinion Development Commission Staae Entry into Force & Enforcement CECHA EUROPEAN CHEMICALS AGENCY "REACH Committee" First bans expected as from July 2027 onwards EU'FOCUSj 2 9/18/2023 Some Substances in scope of PFAS Proposai Fluoropolymers (PTFE, PFA, etc) F-Gases (e.g i23^yf and 13360122 isomers) Fluoropolymers are a specialty plastic F-Gases are specialty performance rfrigrants Durable by design and fluids. Fluoropolymers hve thermal, Chemical, F-Gases (i234yf) are circular by design photochemical, hydrolytic, oxidative, and Three main orooerties: coolino. heatina and biological stability and they hve negligible insulation (blowing agents). residual monomer and oligomer content and low Ultra-low global warming potential (GWP) and to no leachables. no Ozone depleting potential (ODP) Fluoropolymers do not pose a significant riskto human health or the environment when used for their intended purposes. EUrFOCUSj GROUP 5 REACH PFAS Annex XV - Our Concerns THE PROPOSAL BY g COUNTRIES IS FLAWED No drogations, only bans (+18 months afterEiF) or l'delayed bans" (+6.5 or+ig.syears afterEiF) Persistency - main criterion for ban ("P-sufficient approach"): No hazard assessment No information on use resulting in missions Norrisk assessment Insufficient analysis of alternatives No causal link between alleged presence of PFAS and actual fluoropolymers usage Wrong premises (e.g. non-fluorinated polymerization aids are `better'forthe environment) Old data (e.g. HFPO-DA missions data from 2013) Alternative RMOs not considered OVERALL: no dmonstration of unacceptable risk & no rcognition that fluoropolymers can be produced responsibly DIRECT IMPACT ON FLUOROPOLYMERS and F-Gases 1. Ail PFAS as per dfinition, unless explicitly derogated, will be banned as from July 2027 2. Most substances will be completely banned after a transition period (if at ail) 3. Fluoropolymers and F-Gases are in scope of restriction proposai. 4. Fluorinated Polymerization aids are banned for the production of PTFE and FKM (Chemours products). 5. Transported isolated intermediates used under strictly controlled conditions are banned (contrary to REACH). OVERALL: indirect ban on high-tech conomie sectors, including green technologies, relying on fluoropolymers. EU^OCUS, GROUP 6 3 9/18/2023 Main Concern of the Five Countries: PERSISTENCY Hazards/Risks (Problem identification L.C.D.: carbon-fluorine bond particularly strong and highly persistent "Alt PFASs are considered to be very persistent, eitheron the basis oftheirown very persistent properties or the very persistent properties oftheir terminal dgradation product (arrowhead)" (p.22) "P-Sufficient approach" Very Persistent "Additional hazardous properties dpend on the spcifie structure of a PFAS": Dfinition Grouping X Long-range transport potential ("LRTP") X Mobility X Accumulation in plants X Bioaccumulation X Ecotoxicity X Endocrine Activity/Endocrine Disruption X Effects on Human Health ____________________ I___________ Referenced "additional hazardous properties" are not applicable to fluoropolymers EU^OCUSj GROUP 7 Fluoropolymers and F-Gases are used across sectors and are key to EU Initiatives and Policies TRANSPORTATION automotive, heavy duty, train, marine, aerospace ENERGY H2E, solar, wind, nudear, Oil 4 Cas CHEMICAL INDUSTRY INDUSTRIAL MACHINERY MEDICAL & PHARMA ELECTRONICS & SEMICON S Ail sectors are connected, one sector cannot exist without the other S Both FPs & F-Gases are key driver of the "Green Deal" (Upstream and Downstream) S Both FPs & F-Gases are substances of necessity rather than choice sustainabie and Smart mobility 8 EU^OCUSj GROUP 4 9/18/2023 Applications in semiconductor manufacturing SEMICON TOOLS ' Valves, Fittings, Tubings Pumps, Filters Lubricants Valve seats Valve sealing Vacuum pump oil Etchant gas Pellicle mask Flow measurement Thermal management Heat transfer fluids T~ to__ >--i - -t t'Ti m aVftjffiri*.^**LujJifJari'B fc^iiin^igai INFRASTRUCTURE : Duct coating Air conditioning Humidity control Fire protrection WAFER TRANSPORT Wafer carrier FOUP sealing CHEMICAL DISTRIBUTION SYSTEM Valves Fittings Heat exchanger/insulation Flow measurement Tubing Chemicals primary Tubing Chemicals secondar containment Water System tubing Pumps Filters Seals Electronic cleaners CHEMICAL PACKAGING Container lining Drums Tanks lining ^ Chemours- Applications in Data Centers Hlectrical/Electronic Systems Tapes, wires and cables Data cables Electrical connectors, insulators Sensors Displays, touch screens Anti-drip, easy clean, non-adhesive additives for computers and other electronic devices Printed Circuit Boards Maintenance Fiber optic end-face cleaners Defluxing and degreasing of servers or server components Fire protection of data centers 10 PFA. PTFE. FEP. HFOS Equipment & Racks Immersion cooling fluid Wire and cable Gaskets and seals Air Conditioning & Cooting Temprature and humidity control Air-cooled cabinets and direct expansion Systems Construction Building Foam Insulation - SPF Unitary HVAC Equipment Foam Insulation ^ Chemours- 9/18/2023 Applications in Medical Medical devices and applications Surgically implantable medical devices such as vascular gratis Surgical mesh Heart patches Cathters Carrier fluid forthe dposition of lubricants on medical devices and cathters Dielectric insulators in defibrillators, pacemakers Diaphragm pumps Membranes for filtering and venting purposes Strile container filters, needle retrieval Systems, Tracheosto, cathter guide v/ire forlaparoscopy, valves, fittings, pimps, tubing and medicine inhaler canister coatings Labware Medicine Packaging Items that need sterilization Metered Dose Inhalers PTFE. FEP. RFA ETFE, HFCs Infrastructure Transport and stationary rfrigration Systems AC, heat pump, & humidity control for: Patient rooms Spcial areas (OR, ICU, etc.) Thermal management for labs and equipment Rfrigration and insulation for Food Services and distribution of vaccines and pharmaceuticals Cleaning of supplmentai oxygen Systems for breathing air Foam insulation for cryognie tanks Thermodynamic sanitary hot water tanks Pire protection Medical imaging & analysis Semiconductor chips O-rings, gaskets, seals Coating for wire & cable Tapes, wires, and cables Bearings and assemblies Degreasing ^ Chemours' 11 Applications in Clean Energy Renewable Energy Production Photovoltaic front sheets protection Photovoltaic back sheets insulation Junction boxes in photovoltaic vents Control centers for offshore wind parks Wind turbine paints and coatings Release film: support production of composite turbine Wades esp. for offshore turbine PTFE bearings Stationary & Mobility Fuel Cells lonomer exchange membranes for PEM fuel cells Gaskets and seals to prevent leaks and environmental releases to reduce carbon dioxide missions into the atmosphre Binder materials in the lectrodes Component of the gas diffusion layers (GDLs) September 13. 2023 12 C hf: mnursC onfui enti aI Energy Storage lonomer exchange membranes for flow batteries Gaskets and seals to prevent leaks and environmental releases to reduce carbon dioxide missions into the atmosphre Binder materials in the lectrodes Hydrogen Production lonomer exchange membranes for PEM water electrolysers Tubing fluid transfer in alkaline water electrolysis hydrogen production Systems Binder materials in the lectrodes Gaskets and seals to prevent leaks and environmental releases to reduce carbon dioxide missions into the atmosphre Chemours' 9/18/2023 Applications in Chemical Production Manufacturing and processing Valves Vessels Reactor vessel and agitator lining Lined pipes and fittings Heal tracing Seals <3askes Pumps nar Ion Exchange membranes Inslmmentation lining Filters Rfrigration machines coolant Bolts/washers Data Wiring Dist/lfati'on cofuimi packaging Lubricants Technical equipment Propellants in degreasers, leak detectors, sealants, paints, drain openers Transport and distribution Container lining Packaging AC cooling Very low temprature rfrigration OHE" iiqB 13 I I B I I I 1 1 I III I IIIII `-o^XJ7 ""cxtc ^ Chemours ELECTRICAL SYSTEMS, WIRES, CABLES, AND SEMICONDUCTORS Semiconductor chips Lambda/02 sensor conduit & grommet Electric mirror lubrication DC motor bearing lubrication Oxygen/NOx Sensor Heated seat wire Diesel pump wire ABS transmission brake sensor wire High tension ignition cable Battery terminal wire Convoluted wire hamess conduit Cable lie wraps Xenon/bi-xenon headlight wire Throttle body injection wire ABS sensor cables Printed Circuit Boards TRANSMISSION & TRANSAXLES Internai shiftseal ring/clutch piston ring Clulch pilot and release bearings Clutch bearing lip seals Dual mass flywheel replacement Auto ORC de-coupler foralternators Driveshaft: CV joint lubrication ENGINE & POWERTRAIN Head cylinder & oil pan gasket Transmission & crankshaft seals Valve stem seals Bearing lubrication Flexible O-ring & piston skirt coating Front engine accessory drive Throttle body bearings & lubrication ETC lubrication Actuator assembly; valve belt tensioner Air intake manifold gaskets Turbochargerhoses EV binder for battery and seals CHASSIS ABS interconnected hose Hydraulic break lines Impulse hose at wheel Brake pad clips, shim and wear indicator Insulating foams and sound dampening Shock stmts/absorber piston seals Dry Lubricant bearing door hinges Axle seals Adhesives NVH busing - lubrication Steering bail bushing incl. lubrication Steering bail joint insert and shaft steering splines Steering assist pump piston rings Cabin comfort and heating 14 FUEL SYSTEMS Fuel line: feed retum, vapor Fuel line quick connector seals Interconnect hoses Fillerneck hose Fuel rail crossover FIORs Fuelsenderseal Connector o-rings Diaphragm pressure regulator Anti-expulsion tank valve Pressure injection bushing EV battery cooling ^ Chemours' V/lS/lQll Applications in the Cold Chain Foam Insulated Transportation Shipping Containers / Railcar/ Trailers - SPF Insolation Walk-in Cooler Panels Reach-in Coolers High-End Residential Refrigerators High-End Commercial Refrigerators Refrigerated Warehouse - SPF Insolation Spa foam Insolation Water heater foam insolation Lining of valves, piping, tobing, filters, seals, gaskets and other standard floid handling components Lining of mixing vessels and tanks Coating on Processing belts Air Conditioning & Rfrigration Rfrigration for food prservation (farm) Indostrial Ice Making (fishing vessels) Refrigerated transport (tmck/trailer) Refrigerated transport (container - rail - ship) Rfrigration for food processing (flash freezing, etc.) (Indostry graphie bullet points excel) Refrigerated Storage (warehoose) (Indostry graphie bollet points excel) Rfrigration at point of sale (grocery, C-store) (Indostry graphie bullet points excel) Rfrigration for food/beverage retail (restaorant, bar) (Indostry graphie bullet points excel) Commercial Ice Making (Industry graphie bullet points excel) Rfrigration - home appliances (Industry graphie bullet points excel) Chemours' 15 AIRFRAME Exterior surface coatings Toilet area galleys Overhead lockers Satellite dishes Aircraft wings covers Heat shrinkable protective covers Air bearings Electronic device trays Control surfaces Intgral skin foams Paint Replacement Film 3D printed and molded parts for repair Packaging Sleeve items that require light transmission Fasteners Fire prvention Systems I I III I IM I FUEL SYSTEMS Fuel lines and hoses Hydraulic Systems Coating for wire & cable Tapes, wires, and cables Containment bags, bladders, and tanks Tank fuel seals and insulations Tank liners Tubing liners Fluid transfer devices ENGINE & SYSTEMS O-rings, gaskets, seals Satellite propulsion Systems Throttle box seals Arming components Engine and exhaust components Battery binders Battery separators Gears, and slides Oxygen Systems (propulsion, SCBA) Degreasing components and landing gear Cabin comfort cooling and heating 16 ELECTRICAL/ELECTRONIC SYSTEMS Tapes, wires, and cables Printed circuit boards Coating for wire & cable Electrical connectors, insulators Flight control Systems Sensors O-rings, gaskets, seals Air bearings Electric harness parts Gears, and slides ^ Chemours- 8 9/18/2023 Applications for Fluoropolymers & F-gases in Defense Machinery PFPE. PTFE. FEP. PFA. ETFE. HFCa. HFOs See trucks and planes Battery binders Pneumatic cylinders Aircraft fuel pump Systems Hydraulic Systems Fuel tank insulations Intgral skin foam seating to increase protection Degreasing of engine components and landing gear Medium and heavy-duty vehicle AC Carrier fluid and lubricant dposition Lubricants IT & Electronics - Ail communication devices, transportation and command centers High Frequency Circuit boards Radar Radome Data Cabling High performing batteries 17 Way Forward - Fluoropolymers Fluoropolymers should get "no timelimited drogation" for manufacturing and use in applications in transportation, medical, electronics, semicon, hydrogen, communication, Chemical and other industrial and professional applications Condition: responsible manufacturing through abatement & mandatory end-of-life management (ALL manufacturers & downstream users) 18 j * fl ^ Chemours Fluoropolymers and polymeric PFPEs: meet OECD criteria of low concern (PLCs), do not dgrad and do not bio-accumulate (high molecular weight) The largest share of fluoropolymers waste shall be thermally treated and mineralised standards for waste management facilities shall be harmonised State-of-the-art abatement technologies can reduce missions of fluorinated organic compounds to a couple of kgs per year. Permits for Dordrecht facility for mission to air and water took abatement measures into account (around 35 kgs in 2021 vs 8 tons in 2013) EU'FOCUSj GROUP tn 9/18/2023 Industry-all EU manufacturers of Fluoropolymers commit to eut missions FPG Responsible Manufacturing Programme for European Manufacturing sites Since the 2021 adoption of the responsible manufacturing principles, ail Fluoropolymer Products Group (FPG) members are engaged in concrte actions related to responsible fluoropolymer manufacturing practices. The undersigned members of the Fluoropolymer Products Group (FPG) hereby commit to an industry Responsible Manufacturing Programme for European Manufacturing sites. The programme is comprised of three pillars: 1. A voluntary commitment to reduce non-polymeric PFAS missions from our fluoropolymer manufacturing; 2. A platform to promote the adoption of commercially available State of the art technologies to minimise non-polymeric PFAS missions in our manufacturing; and 3. A commitment to inform downstream users of fluoropolymers on theirsafe handling and use. 19 Way Forward - F-Gasses Low Global Warming Potential F-Gasses (HFOs) should be derogated for key sectors applications (Heatpumps, Automotive, Blowing agents for insulation) Condition: Mandatory recovery of F-gasses during life, periodic leak-checks, mandatory recovery end of life. Enable recovery of F-gasses in the End of LifeVehicle Directive (mandatory recycling) and Flarmonise leak checks for new vehicles during yearly maintenance control Impose and enforce regular leak checks for beat pumps maintenance EU'FOCUSj 20 IC 9/18/2023 Additional risk management measures The implmentation of the additional risk management measures mentioned above could be facilitated by a voluntary commitment which involves ail actors of the F-gas supply chain, including manufacturers/importers, distributors, downstream users, research institutes and trade associations. Establish a stakeholder platform involving such actors to develop measures such as the set-up of certification Systems in a collaborative and constructive manner together with authorities and regulators. Focus Area I. Automotive sector 21 F-Gas Sustainability Platform I. To provide regulators with an additional option to consider beyond the proposed PFAS restriction, and to avoid potential restriction inflicting high socital cost and damage. II. To increase transparency in the supply chain to further reduce the potential illgal trade of F-gases III. To identify where missions can be reduced from manufacturing to end of life/waste To facilitate the development of innovative measures, always with a view to further reduce the impact on the environment IV. To develop indpendant authentication/certification through third parties (e.g.EU EMAS) Note: Some stakeholders are already ISO 14001:2015 certified, which is complementary to EMAS. V. To develop voluntary initiatives to complment existing or future regulatory measures other than the proposed PFAS restriction VI. To secure a 'One Voice' for the European Commission and other EU decision-makers, through the value-chain VII. To secure reuse, recycling and development of a circular economy VIII. To secure the green deal objectives in their entirety: from rduction of energy consumption to the greening of solutions IX. To provide a neutral support for the entire industry to implement guidelines and proposais developed by the platform, that will be made available to along the supply chain. X. To increase transparency in the supply chain where possible and pertinent through innovative and currently being developed measures such as "Digital twins" or similar ^ EU^OCUSj GROUP Thank you for your attention! EU^OCUSj GROUP 22 11