Document pBMqaojYyLr6OLpqK0V48yp0d

A Worldwide Vision Connecting People with Technology Amphenol is one of the largest manufacturers of interconnect products in the world. The Company designs, manufactures and markets electrical, electronic and fiber optic connectors, coaxial and flatribbon cable, and interconnect systems. The primary end markets for the Company's products are communications and information processing markets, including cable television, cellular telephone and data communication and information processing systems; aerospace and military electronics; and automotive, rail and other transportation and industrial applications. Regulaon (EC) NO. 1907/2006 (REACH) Proposal for a restricon of Per and Polyfluoroalkyl substances (PFAS) Submied by: Amphenol Spectra-Strip and High Speed Cable Products 720 Sherman Ave. Hamden, CT USA Date: 9/20/2023 Dear Sir or Madam, Amphenol Spectra-Strip is a manufacturer of high speed bulk cable products that are incorporated in Amphenol High Speed Cable Products. The Amphenol High Speed Cable Products are in mulple different applicaons, including data centers, interconnects between electronic equipment. In addion, Spectra-Strip provides high speed bulk cable to other Amphenol divisions for internal equipment applicaons. The type of fluoropolymer used for the conductor insulaon in the high speed cables include FEP and PTFE. These are considered Plascs of Low Concern (PLC) as they sasfy the recognized PLC polymer hazard assessment criteria that includes certain physicochemical properes like high molecular weight, insolubility in water/lipids and thermal, abioc, and bioc stability. OECD (2009) Based on this the fluoropolymers should be exempt from the PFAS restricon. The unique electrical properes of this subclass of PFAS are low dissipaon factor and high heat stability which are properes that facilitate efficient signal transmission, reduced signal loss and heightened data integrity in elevated temperature environments. The fluoropolymers, FEP and PTFE, are suitable for the various high-performance applicaons that include data transfer where higher operang frequencies and higher bandwidth is required. In addion, many of these applicaons experience a high temperature environment that non-fluoropolymers will not properly operate. The proposed restricon would affect this high-speed data transfer, power AI and "green economy" and many of the next generaon of products including arficial intelligence, clean energy, and electric vehicles. There are no material substuons for the fluoropolymer in the high temperature environment. Polyethylene would have close approximaon to the electrical properes but would increase in the size of the product. Increasing the size in this current world of downsizing applicaons is not the opmum product design method. Plus, polyethylene cannot operate in the same high temperature environment that fluoropolymers can operate and therefore cannot be used. This lack of alternatives to the fluoropolymers may result in potentially hazardous, less durable substitutions making the known applications unable to meet the stringent safety standards. In addition, future improvements in infrastructure that require increased speed of electronic signal transfer would be severely affected. The economic impact to Amphenol would be over $120 million and affect 1,000 Amphenol employees. Amphenol Spectra-Strip and Amphenol High Speed Products understand the concerns in regard to the potential long-term effects of certain PFAS substances in the environment. Responsible manufacturing is a strong focus across all of Amphenol. But the fluoropolymers noted in this document are safe when used in their intended methods. Fluoropolymers have unmatched performance; they are inert, are not biodegradable, toxic, or mobile, do not dissolve in or contaminate water or generate microplastics, and cannot enter or accumulate in a person's bloodstream. Based on this information, fluoropolymers should be excluded from the substances of high concern. If they cannot be excluded, an extended derogation period needs to be extended without a formal deadline for the wire and cable fluoropolymer market until it is possible that acceptable substitutes are available. If there are any questions, please do not hesitate to contact one of the undersigned. Respectfully submitted. Albert M. Ermer, Jr. Director of QA, NPI, & Mfg. Technology PH @amphenol-tcs.com Gregory Fitts Senior Application & Design Engineer PH @amphenol-tcs.com