Document v6o21dM96Op450o9gYKde8w0R

EUROPEAN COMMISSION ( J Ref. Ares(2020)5105884 - 29/09/2020 DIRECTORATE-GENERAL FOR INTERNAL MARKET, INDUSTRY, ENTREPRENEURSHIP AND SMES Chemicals and Consumer Industries REACH Brussels, GROW.D.1/ VIRTUAL MEETING WITH THE 3M COMPANY ON THE CHEMICAL STRATEGY FOR SUSTAINABILITY AND A BROAD RESTRICTION ON PFAS AS ANNOUNCED BY FIVE EUROPEAN STATES 24 SEPTEMBER 2020 (9:30-10:30) Participants: 3M : , and DG GROW : Mr. Carlo Pettinelli (Director) , (D2) and (D1). 3M asked for a Webex meeting to exchange views on EU Regulatory actions on PFAS (perfluoro alkylated substances) in the context of the future publication of the Chemicals Strategy for Sustainability as well as a broad restriction on PFAS: an Annex XV restriction dossier that five Member States are preparing (NL, DE, DK, SE and NO). 3M introduced its activities in four business areas (safety and industrial, transportation and electronics, health care and consumer). 3M produces PFAS as well as articles containing PFAS in two factories in EU, one in Belgium and one in Germany. 3M expressed concerns on the planned broad restriction announced by five Member States on PFAS on all non-essential uses. 3M has commented in the call for evidence for this restriction. They mentioned that a blanket restriction on all PFAS, based on persistency, would undermine innovation to produce durable and high performing materials that support societal sustainability goals. They claimed that restricting PFAS as one group of 4700 substances with different chemical structures and physicochemical properties is not scientifically appropriate. They also added that a blanket restriction on PFAS based on persistency would impact many sectors and have tremendous negative effects on innovation, investments and jobs in Europe. According to 3M; the majority of PFAS uses today are in applications with high societal value, which are important to the functioning of our modern life and the implementation of the Green Deal agenda. They suggested that instead of a blanket restriction, PFAS of concern could be better regulated under REACH when grouped according to their similar chemical structures, eg. an "arrowhead" approach (assessing and regulating simultaneously large group of chemicals that can be degraded in the environment to a representative PFAS- the arrowhead PFAS). They also claimed that fluoropolymers should be excluded from the broad restriction, as they do not degrade into the environment. Finally, they considered that essentiality is a subjective criterion, which should not be part of risk assessment. Something non-essential today could be beneficial and essential in a future use. The Commission mentioned that there is a high societal demand, supported also by the European Parliament and the MSs to act on PFAS and to promote substitution, where possible. The Commission is currently working on the Chemicals Strategy for Sustainability, which will also include a PFAS Action Plan. This work involves all relevant DGs acting as a team. At the same time, some Member States announced a restriction proposal for all uses of PFAS except the non-essential uses. The concept of essential uses requires further discussion but will play a role in future. The restriction work is still at an early stage and at this stage in the hands of the Member States. 1 2