Document qaL0JVOk7gEadagQkkgG61N7E
Response Suggestions for PFAS Proposal
Zhejiang Green New Materials Co., Ltd. (GNM) greets the five countries that have proposed the ECHA and PFAS control draft. Our company has always made unremitting efforts to comply with domestic and international regulations, and continuously conducts strict self review of the compliance of products exported to the European Union. For a long time, we have supported the ambitious attempts of the European Union to reduce the risks caused by toxic and harmful substances, and have taken sincere practical measures to meet the requirements of EU chemical regulations, including REACH. However, we believe that the PFAS (Perfluoroalkyl and Polyfluoroalkyl Substances) restriction proposal proposed by the five European countries is an excessive measure, as it classifies over 10,000 organic fluorine compounds (PFAS) as persistent substances of concern equivalent to already regulated perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA).
GNM is mainly engaged in the research and development, production, and sales of fluorinated special functional materials. The PTFE raw materials used by our company are included in the scope of PFAS substance restrictions. After communicating with our company's clients, they unanimously believe that PTFE has a series of excellent performance, and there are currently no feasible substitutes for the products produced with it. They hope to permanently waive the exemption for the following reasons:
1. Our company's PTFE powder is made by a special process to achieve a particle size of micrometers. It is mainly used in fields such as lubricants, coatings, inks, etc. to improve its high pressure, high temperature, and friction resistance properties. As PTFE is currently
known as the solid material with the smallest friction coefficient =
0.04) can act as a dry lubricant under special circumstances, and there are currently no other materials available to replace it.
2. The PTFE isobaric pipes produced by our company are mainly used for lining chemical pipelines, and their quality fully meets the ASTMF1545 standard. Due to its strong resistance to strong acids and alkalis (with a pH range of 0-14) and high and low temperatures (with a
temperature range of -190 to 260), PTFE is irreplaceable in
pipelines and related products produced using PTFE in the chemical industry.
In summary, our company sincerely supports the PFAS restriction proposal proposed by the European Union. However, the package control measures for fluoropolymers are not conducive to the stability and development of industries such as lubricants, coatings, inks, and chemicals. PTFE products currently do not have feasible alternatives, so our company hopes to permanently exempt PTFE.
Attachment: 1. The table of Common Plastic Friction Factors 2. The table of Common Plastic Corrosion Resistance 3. The table of Common Plastic Temperature Resistance 4. Customer's Opinion Letter
Zhejiang Green New Materials Co., Ltd. August 9, 2023
Attachment
Serial number
1 2 3 4 5 6 7 8 9 10 11 12
Table 1 The table of Common Plastic Friction Factors
Upper sample
Steel
Plastic
Lower sample Plastic
Static friction
Dynamic friction
Static friction
Dynamic friction
coefficient coefficient coefficient coefficient
s
k
s
k
PTFE
0.1
0.05
0.04
0.04
FEP
0.25
0.18
-
-
LDPE
0.27
0.26
0.03
0.33
HDPE
0.18
0.08-0.12
0.12
0.11
POM
0.14
0.13
-
-
PVDF
0.33
0.25
-
-
PC
0.60
0.53
-
-
PET
0.29
0.28
0.27
0.20
PA66
0.37
0.34
0.42
0.35
PCTFE
0.45
0.33
0.43
0.32
PVC
0.45
0.40
0.50
0.40
PVDC
0.68
0.45
0.90
0.52
Table 2 The table of Common Plastic Corrosion Resistance
Serial number
Medium
Concentration/ %
Temperature/
PVC PP PVDF
1
Ammonia
10
80
2
Aqua regia
10
80
3
Benzene
Pure
80
Bleaching
4
20
solution
80
5
Boric acid
Saturation
6
Oxalate
50
Sulfuric
7
98
acid
80
80
80
Sodium
8
13
hypochlorite
40
Sodium
9
70
hydroxide
80
---excellent ---good ---ordinary ---inferior
PTFE
Serial numbe
r 1 2 3 4 5 6 7
Table 3 The table of Common Plastic Temperature Resistance
Plastic name
Density /g/cm3
Temperature resistance/
PVC (Hard) PVC (Soft)
CPVC HDPE LDPE
PP ABS
1.301.58 1.161.35 1.451.65 0.9410.960 0.910.925 0.890.91 1.021.09
-4060 -4060 -4095 -7070 -7060 -35120 -4080
8
PVDF
9
PTFE
10
NR
11
NBR
1.76 2.12.2 0.900.95 0.961.20
-20140 -190260 -5570 -10120