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PlasticsEurope Fluoropolymers Product Group CALL FOR EVIDENCE SUPPORTING AN ANALYSIS OF RESTRICTION OPTIONS FOR PFAS Fluoropolymers Product Group PlasticsEurope 13 November 2020 2970612 a ih he \ aA aN The Fluoropolymers Product Group BD0) Why fluoropolymers are critical to EU competitiveness and innovation ? Fluoropolymers are Different to Other PFAS 09 Grouping Based on Established Criteria 2970612 The Fluoropolymers Product Group The Fluoropolymers Product Group represents Europe's leading fluoropolymer producers and experts. As the voice of the industry across Europe, it advocates for a balanced regulatory environment based on scientific facts to ensure that European industries remain competitive and sustainable. Part of PlasticsEurope, the group's members are 3M, AGC, Arkema, Chemours, Daikin Chemicals, W. L. Gore & Associates and Solvay. PlasticsEurope Fluoropolymers Product Group _ 2970612 Fluoropolymers Why fluoropolymers are critical to EU competitiveness and innovation Fluoropolymers are used in a wide range of applications and processes. For example: - They are core components of high-voltage interrupters in wind turbines and used for electrical insulation in photovoltaic panels. + In transportation, they contribute to engine efficiency and emission control. Electric vehicles are enabled by high performance insulators: fluoropolymers in lithium batteries and hydrogen fuel cells. + In electronics, fluoropolymers are critical to the semiconductor manufacturing process (photolithography). + Medical applications: Fluoropolymers enable excellent performance and long lifetimes in medical equipment such as surgically implantable medical devices (vascular grafts, heart patches) and catheters. PlasticsEurope Association of Plastics Manafecty Fluoropolymers Product Group 2970612 PFAS have many different properties SIMILARITIES 1 fully fluorinated carbon or CF2-CF2-CFo2- or... PlasticsEurope of Association Plastics Manafecty Fluoropolymers Product Group GASES LIQUIDS SOLIDS DIFFERENCES Stability eee] seconds thousands of years Toxicity BU = lov 4--P high Mobility rm Insoluble/ Non-volatile J Highly mobile Size eee] MW less than MW multi- 1,000 Daltons gp million Daltons 2970612 PFAS: Are they all the Same? C-H COMPOUNDS A big universe of very different substances } NX '\ SOLID Polythylene H(CH2CHz)xH LIQUID Ethyl Alcohol CH3CH20OH GAS Propane CH3CH2CH3 vv We would never group them together and say "they are the same", because they are NOT the same PlasticsEurope Fluoropolymers Product Group C-F COMPOUNDS FLUOROCARBONS -- Also a big universe of very different substances ) 6:2 Fluorotelomer Alcohol 1] . = Solio Flucropel/me; H(CH2CHa),H LIQUID A Fluorotelomer Cs6F1133CH22CH220H ono A Refrigerant CFs3 CH22F vv We should not group them together, because they are not "the same" 2970612 Fluoropolymers Fluoropolymers are polymers with fluorine atoms directly attached to their carbon backbone. They are virtually chemically inert, non-wetting, non-stick, and highly resistant to temperature, fire & weather. They ensure safety, reliability and performance in numerous technologies, industrial processes & everyday applications and help contribute to the achievement of UN SDGs and the EU Green Deal. PlasticsEurope Fluoropolymers Product Group 2970612 Fluoropolymers are Different to Other PFAS Per- and polyfluoroalkyl substances (PFAS) are a huge and diverse group of chemical compounds consisting of approximately 4,700 individual substances. |i Despite their chemical structure fluoropolymers are different to other PFAS and have specific toxicological and environmental profiles. They are high molecular weight polymers with unique physicochemical properties that constitute a distinct class within PFAS. Fluoropolymers that meet the OECD Polymer of Low Concern criteria are non-toxic, bio-compatible, non-soluble and immobile molecules and they are deemed to have insignificant environmental and human health impacts. PlasticsEurope Assuciation of Plastics Monufacty Fluoropolymers Product Group 2970612 PFAS Terminology and Classification dolOPEN ACCESS: Att orG/1u 0.100 2/ieam.258 GROUP luusy PER- AND POLY-FLUOROALKYL SUBSTANCES (PFAS) CATEGORY .cass NON-POLYMERS POLYMERS PlasticsEurope Assuciation of Plastics Manufecty Fluoropolymers Product Group 2970612 Grouping Based on Established Criteria Grouping for regulatory purposes may be a cost and time efficient way forward. However, it could wrongly treat all PFAS collectively without prior scientific examination of their differentiation. It is not scientifically justified to classify inert solids, salts, liquids and gases in a single class, where properties like vapour pressure, environmental partitioning, hydrophobicity/lipophilicity, aqueous solubility and hazard itself, as well as surface and material properties vary greatly. Grouping based on well established criteria such as long-chain vs short-chains, polymeric vs. non-polymeric substances is necessary for regulatory measures to be scientifically sound. PlasticsEurope Fluoropolymers Product Group 2970612 Contact Us [@agcce.com at AGC Chemicals Europe PlasticsEurope [Dplasticseurope.org PlasticsEurope PlasticsEurope Fluoropolymers Product Group 2970612