Document ppy2LeEReoxDn5x871n7aEZRw

PlasticsEurope Association of Plastics Manufacturers II Ref. Ares(2020)2057767 - 15/04/2020 European Commission DG ENVI Circular Economy and Green Growth (ENV. B) Mr Kestutis Sadauskas -- Director @ec.europa.eu Cc: @ec.europa.eu gec.europa.eu DG GROW Chemicals & Consumer Industries (Dir. D) Mr Pettinelli - Director Pec.europa.eu Cc: @ec. europa. eu @ec. europa. eu Brussels, 15 April 2020 Reference: Request for postponing the deadlines of ECHA's public consultation on the restriction proposal on undecafluorohexanoic acid (PFHxA), its salts and related substances due to the Covid-19 sanitary crisis Dear Mr Sadauskas, Dear Mr Pettinelli, The Fluoropolymers Group of the trade association PlasticsEurope, as a representative of the seven leading producers of fluoropolymers in Europe, values the opportunity to provide comments to the ongoing public consultation on Germany's restriction proposal on undecafluorohexanoic acid (PFHxA), its salts and related substances (hereafter `PFHxA restriction proposal') that opened on 25 March 2020. This is a priority for us to help ECHA's committees assess PFHxA-related uses, their alternatives or the socio-economic impacts of the restriction proposal on our industry and the society at large. However, in the wake of the major sanitary crisis that Europe and the world are currently facing due to Covid-19, the Fluoropolymers Group is very much concerned about the tight deadlines that have been set to provide comments to the public consultation on the PFHxA restriction proposal. The first deadline of 13 May 2020 is especially very close and may not allow the Fluoropolymers industry to provide the necessary feedback. We are therefore urging ECHA to postpone the deadlines to provide comments to the public consultation on the PFHxA restriction proposal, by at least one month, and in particular due to the following reasons: Some of our staff members, including critical resources for the work on the REACH PFHxA restriction are affected by Covid-19. This concerns staff members in charge of compiling evidence in key areas for ECHA's evaluation such as uses, emissions, toxicology, alternatives, socio-economic impacts. PlasticsEurope AISBL Rue Belliard 40 box 16 1040 Brussels Belgium Phone +32 (0)2 792 30 99 Email @plasticseurope.org www.fluoropolymers.plasticseurope.org Some of our colleagues are on sick leave until further notice. Others work from home, while the closure of schools and day care forces our personnel to combine work with taking care of their children. This considerably complicates the internal process of producing and gathering input to the public consultation, as it requires close coordination between several companies' departments as well as external dialogue with stakeholders in the downstream sectors. We also would like to point out that the global scale of this COVID-19 crisis, including restrictions posed in Asia (e.g. Japan) and North America (e.g. the US), additionally make the above-said efforts very challenging, since the European industry is closely linked with these regions. Stringent contingency measures have been in place in most European countries, including the temporary closure of a number of production sites. This makes the communication with our downstream users and within the supply chain much more difficult. For a number of downstream users, plants shutdowns have led to lay-off for operational reasons until further notice. In this context, communication to downstream users, which is of utmost importance to get precise information on PFHxA-related applications, cannot take place. Finally, Covid-19 is causing delay on the delivery of various studies and reports on risk aspects, alternatives and socio-economic implications. Without such materials being ready for use in due time, our company members are concerned that they will not be able to provide evidence-based input to the public consultation, which is critical, in particular for the assessment of exemption requests. In order to ensure that each company member having interest in the PFHxA restriction proposal can provide sufficient input, we urge ECHA to postpone the deadlines to provide comments to the public consultation on the PFHxA restriction proposal, by at least one month. Our current main concern is on the first deadline of 13 May 2020. This deadline is very difficult to give meaningful comments in the current circumstances and should be at least extended to 13 June 2020. This tentative date should be reconsidered in the light of the future developments associated with Covid-19. The members of the Fluoropolymers Group of PlasticsEurope would like to thank the European Commission for its consideration and remain available to discuss the timetable and its practical imp li cations. We have also sent an identical letter to ECHA Executive Director (Mr B. Hansen). Yours sincerely, PlasticsEurope Fluoropo/ymers Group