Document vyJgLGqXkB6J6E0Ed5aRXDam

PFAS restriction ACEA COMMENTS ON THE ANNEX XV DOSSIER OF THE UNIVERSAL PFAS RESTRICTION PROPOSAL September 2023 Second submission ACEA - European Automobile Manufacturers' Association 1 WHO WE REPRESENT ABOUT ACEA The European Automobile Manufacturers' Association is a professional association uniting 14 major mobility actors on the European market. 13.0 million Europeans work in the auto industry (directly and indirectly), accounting for 7% of all EU jobs. 11.5% of EU manufacturing jobs - some 3.4 million - are in the automotive sector. Motor vehicles are responsible for 374.6 billion of tax revenue for governments across key European markets. The automobile industry generates a trade surplus of 79.5 billion for the European Union The turnover generated by the auto industry represents almost 8% of the EU's GDP Investing 58.8 billion in R&D per year, automotive is Europe's largest private contributor to innovation, accounting for 32% of the EU total. Today, ACEA would like to extend the first submission to the public consultation on the universal PFAS restriction proposal that was submitted on May 24th. 2 CONTENT I. INTRODUCTION AND CONTEXT.............................................................................................................4 II. PROPOSAL FOR ALTERNATIVE APPROACH ON PFAS DEROGATIONS AND EXEMPTIONS ..................... 5 III. MOBILE AIR CONDITIONING............................................................................................................. 10 IV. PRODUCTION OF VEHICLES .............................................................................................................. 11 1. Machinery and equipment are long-term capital goods........................................................... 11 2. Use of PFAS in machinery and equipment ................................................................................ 11 3. Use of PFAS as process chemicals in production ....................................................................... 11 4. Summary ................................................................................................................................... 12 ANNEXES................................................................................................................................................ 12 I. USES OF PFAS IN H2 TANK STORAGE SYSTEM ........................................................................... 13 II. ELECTRONICS IN AUTOMOTIVE INDUSTRY ............................................................................... 14 III. LUBRICANTS.............................................................................................................................. 48 IV. NON-EXHAUSTIVE LIST OF APPLICATIONS OF FLUOROPOLYMERS AND FLUOROELASTOMERS50 V. NON-EXHAUSTIVE LIST OF PFAS USED IN LACQUERS AND IMPACTED PARTS .......................... 51 VI. NON-EXHAUSTIVE LIST OF PFAS USED IN TEXTILES.................................................................. 52 3 I. INTRODUCTION AND CONTEXT The PFAS REACH restriction is expected to have a major impact on the automotive industry. This document is the second response of ACEA to the public consultation and on the revised Annex XV dossier published on 22 March 2023. PFAS are mainly used in the automotive industry for their unique properties: - High stability - Resistance to high temperatures and high pressures - Electrical insulation - Resistance to aggressive chemicals - Resistance to friction - Surfactants properties As of today, the restriction proposal includes fluoropolymers and fluoroelastomers, which are fundamental to our industry. F-gases, also included in the restriction proposal, are also widely used as refrigerants and for testing methods. As mentioned in our first contribution to the consultation (comment ID 4276) ACEA fully shares the desire to reduce the uses if PFAS in our industry. The current proposal by the dossier submitter is not appropriate as it would have critical impact on automotive industry; mainly the impossibility to produce, approve and place on the market vehicles, as well as strongly negate the possibility to shift to better and greener technologies and electromobility. This submission is an addition to the first ACEA document submitted on the 24th of May 2023. We wish to explicit our position and give to the ECHA committees our proposal for relevant risk option management on PFAS. We also wish to give further details on the impact of the restriction proposal on the automotive industry, especially on the following subjects: - Textiles in the automotive industry, as displayed in the answer to the ECHA online questionnaire - see online questionnaire. - PFAS in air conditioning as an addition to our first submission. - PFAS used in the production process of vehicles, part IV of this document, and in the production equipment. - PFAS used in H2 technology in automotive industry, as annex I of this document. - Electronics in the automotive industry, which can be found as the annex II in this document. - Lubricants in the automotive industry, also to be found as the annex IV in this document. - PFAS used in paints, lacquers, and coatings, as the annex VI of this document. 4 II. PROPOSAL FOR ALTERNATIVE APPROACH ON PFAS DEROGATIONS AND EXEMPTIONS We believe a reduced scope excluding non-hazardous PFAS such as fluoropolymers and fluoroelastomers would be beneficial. Some PFAS have proven to be non-mobile, non-bioaccumulative and non-toxic in their use phase. Furthermore, recycling obligations at the end of life are already applicable for some of their uses (for instance, as stipulated in the new Batteries Regulation). A reduced scope would be beneficial to both ACEA, ECHA and national authorities, as many of the substances currently considered by the restriction proposal pose no threat to human health or the environment. Excluding substances from the scope would prove to facilitate the process of reviewing the data sent during the public consultation, as well as making the enforcement easier afterward. As such, we would like to propose an exclusion of the fluoropolymers and fluoroelastomers of the scope of the proposal: - Concerning the manufacturing phase, the risks of PFAS emissions to the environment can be controlled with alternative Risk Management Options. - Concerning the use phase, they are considered non-toxic, non-bioaccumulative, non-mobile and as such, are classed as polymers of low concern by OECD. - Concerning the end-of-life phase, incineration of fluoropolymers does not contribute to environmental PFAS emissions and is a safe method of disposal. Several other industrial associations have supported similar request in their submission to the public consultation, highlighting a growing concern across the industry. ACEA also knows that changing the scope of the proposed restriction may be complex at this state of the process. Should the fluoropolymers and fluoroelastomers stay I the scope of the derogation, ACEA would request specific derogation concerning fluoropolymers and fluoroelastomers. Currently, most fluoropolymers and fluoroelastomers uses fall under the proposed derogation 6.o about the safety of vehicles and passengers. As stated below and in our first submission, ACEA fully support the inclusion of this proposed derogation in the final text of the Annex XV dossier. However, some applications are reported to provide durability or to comply other regulations (example: emissions), which are non-safety related. As such, we would like to request a 6,5-year derogation for fluoropolymers and fluoroelastomers in such cases, with a review clause performed by the Commission to assess the state of the available alternatives. If fluoropolymers and fluoroelastomers are not excluded from the scope of the restriction proposal, we would need to have several new derogations to be able to transition and maintain a relevant industry. As of today, and considering the data we gathered on the uses of PFAS in the automotive industry, we identified the following derogations to be needed for our industry: Original Annex XV report text Amendment Derogations with no time limitations 5 No Derogation The following potential exemption are marked for reconsideration after the Annex XV report consultation: 6.o. [applications affecting the proper functioning related to the safety of transport vehicles, and affecting the safety of operators, passengers, or goods until 13.5 years after EiF]. 6.o. applications affecting the proper functioning or safety of transport vehicles, or affecting the safety of operators, passengers, or goods. This exemption shall apply perpetually but maybe reviewed and reassessed by the Commission no later than 13.5 years after EiF. No derogation The following potential derogations are marked for reconsideration after the Annex XV report consultation: Use of PFAS in semiconductor Package. This exemption shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF. 5.ee [The semiconductor manufacturing process until 13.5 year after EiF] No derogation The following potential derogations are marked for reconsideration after the Annex XV report consultation: 5.ee The semiconductor manufacturing process. This exemption shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF. 5.ee [The semiconductor manufacturing process until 13.5 year after EiF] 5.s lubricants where the use takes place under harsh conditions, or the use is needed for safe functioning and safety of equipment until 13.5 years after EIF 5.s Lubricants (oils & greases) where the use takes place under harsh conditions, or the use is needed for safe functioning or for or compliance to regulations (emissions, safety). This exemption shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF. No derogation 6.xx Low and high voltage Electrical and electronic components and control units (including functional coatings, PCB reinforcement, PTFE membranes, passive components, all sensors, connectors, polyswitches and cables, displays). This exemption shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF. No derogation By way of derogation, paragraphs 1 and 2 shall not apply to: 6 Vehicles already on the market and - Spare parts to repair these vehicles - Aged batteries for repurpose - Maintenance of machinery - PEM membrane for electrolysers - machinery for tire production These exemptions shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF Derogation effective until 13,5 years after EiF No derogation 6.xx Rechargeable batteries cells until 13,5 years after EIF for automotive vehicles. For the following uses: fluoropolymers (often PVDF and PTFE) used as binder for cathode or anode, Separator membrane including coatings, Sealings in cell, edge coating on electrodes and Electrolyte. This exemption shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF. 6.e proton-exchange membrane (PEM) fuel cells until 6.5 years after EiF; 6.e proton-exchange membrane (PEM), anode and cathode, gas diffusion layer, seals, humidifier membrane, Hydrogen sensor in fuel cells and electrolysers. This exemption shall apply perpetually but may be reviewed and reassessed by the Commission no later than 13,5 years after EiF. No derogation 5.xx Control cable lines, coatings for sliding elements (bearing, bushings, guides) and coating of tubes until 13,5 years after EIF. No derogation The following potential exemption are marked for reconsideration after the Annex XV report consultation: 5.xx Sealing applications until 13,5 years after EIF. 5.v Hard chrome plating until 13,5 years after EIF. 5.v [hard chrome plating until 6.5 years after EiF] The following potential exemption are marked for reconsideration after the Annex XV report consultation: 5.u [textiles for the use in engine bays for noise and vibration insulation used in the automotive industry until 13.5 years after EiF] 5.u textiles used in engine bays for ignition protection and noise and vibration insulation in automotive means of transport and non-road mobile machinery (NRMM) until 13,5 years after EIF. 7 No derogation 5.xx Flame retardant additives until 13,5 years after EiF. Derogations effective until 6,5 years after EiF No derogation 5.xx Body applications until 6,5 years after EIF. 5.e textiles for the use in filtration and separation media used in high performance air and liquid applications in industrial or professional settings that require a combination of water and oil repellence until 6.5 years after EiF. 5.e filtration and separation media used in air and liquid applications in industrial or professional settings that require a combination of water and oil repellence until 6.5 years after EiF. Specific Derogation No derogation 5.xx Components of combustion engine systems in harsh conditions (high temperature, contact with Hydrocarbons) Examples: lines and hoses, sealing systems (static and dynamic) membranes (valves, sensors) until ICE ban, and for ICE and hybrid applications exported after. No derogation Any vehicles applications of fluoropolymers and fluoroelastomers not fulfilling any other derogations until 6,5 years after EiF Only partial derogation 5.p Refrigerants in mobile air conditioning-systems Refrigerants used in mobile air conditioning in combustion engine vehicles with mechanical systems until: compressors until 6.5 years after EiF. - 7 years after EiF for new vehicle types for passenger cars. - 17 years after EiF for new registrations for passenger cars. - 10 years after EiF for new vehicle types for heavy-duty vehicles. - 22 years after EiF for new registration for heavy-duty vehicles. No derogation Unlimited derogation for systems in combustion engine vehicles with mechanical compressors. "Request for distinction between vehicle New Type (NT*) and vehicle All Type (AT*) [in case of derogation lower than 13.5 years after Entry In Force: +10 years between AT and NT (*) according to (EU) 2018/858 type approval" 8 Considering the great number of uses of PFAS in the automotive industry, and in other industries, the research and qualification of alternatives will take an amount of time which is impossible to assess considering the current information. As such, we proposed to add review clauses to several derogation proposals when needed, as seen in the table above. The review clause has already been acted for several restriction dossier, and it will enable the Commission to assess the state of the qualification of alternatives. This means that when required, extended derogation period could be granted to industrials if no PFAS-free substitutes have been found and proved to be efficient enough and commercially viable. 9 III. MOBILE AIR CONDITIONING In our first submission from May 2023, we pointed out that the PFAS ban on refrigerants as proposed has an impact on European vehicle production. As any vehicle must fulfil conformity of production when leaving the manufacturing plant any EU located vehicle plant has to produce vehicles with fully functional refrigerant systems. Therefore, manufacturers must consider PFAS free refrigerant in EU plants also for markets outside the EU, which we believe has been overlooked by the dossier submitters. Consequently, the restriction proposal would also indirectly affect non-EU market, where other refrigerants might be beneficial to meet customer expectations. As a conservative estimate, R744 air conditioning systems would increase the production cost per vehicle by around 300 (Report Summary F-gas use-July 2021) compared to the similar vehicle produced outside the EU with R1234yf Systems. This would mean a 1,7 billion Euro increases per year for the vehicle manufacturers in the EU and loss of competitiveness on worldwide market. This is expected to influence decisions to produce them outside the EU - with impact on employment. Overall, there are 3.5 million jobs on direct and indirect vehicle manufacturing in the EU today. Aftersales costs for dealers and workshops are significantly affected not only in the EU but also in target countries for vehicles "made in EU" - e.g., for servicing machines, workshop preparation, staff training. Besides this direct effect for European vehicle production, we expect an impact and possible shortage of supplier capacities in Europe to meet this steep ramp up of supply parts. 10 IV. PRODUCTION OF VEHICLES 1. Machinery and equipment are long-term capital goods. Production facilities in the automotive industry are a very durable investment good that is handled very professionally over the entire life cycle of several decades. A regulation that makes no distinction between new plants and existing plants endangers the continued operation of existing machines and plants. In some cases, this includes systems that have been in use for decades - and whose planned service life is far from being reached. Regulation must therefore make a distinction between new systems and old systems; whereby old systems also include regular maintenance and repairs with the corresponding spare parts. Likewise, the affected chemicals needed can only be replaced if there are substitutes. Individual components in these complex systems often cannot be replaced without a significant intervention in functionality, especially when elementary properties are changed. This would be expected in the event of a ban on PFAS in industrial components without replacement. It is necessary to ensure that spare parts for these plants are available throughout the entire operating cycle in consistent quality with consistent properties to safeguard the investments made and not jeopardize competitiveness. A premature replacement of machines and systems jeopardizes investments made and must not be sought from the point of view of sustainability. Likewise, the usual further use must be possible until the end of the technical service life of used machines. 2. Use of PFAS in machinery and equipment. PFAS are used as part of machine components in numerous applications. These include, for example, seals, valves, diaphragms, insulators, cables, semiconductors, and coatings. Spare parts containing PFAS are also necessary for the long-term operation of the machines and systems, as long as no equivalent alternatives are available. For purpose tailored and efficient implementation, the time horizon of capital goods must be considered. Even a derogation period of 13.5 years is often far too short. Accordingly, a much longer exception must apply to components and process equipment of capital goods for existing plants and their maintenance and spare parts. Currently, the use of PFAS in existing machines and systems is not fully known due to a previously nonexistent PFAS declaration obligation throughout the supply chain. To efficiently assess impact and substitutes, such a declaration obligation would be required. It however needs to be understood that there is time required for the supply chain to comply with such "new" obligation. 3. Use of PFAS as process chemicals in production PFAS used in the process chemicals may not be fully declared in the safety data sheet as most of them are not classified as hazardous and there are no legal obligations to disclose the full 11 composition of mixtures in the safety data sheet. Considering the thresholds proposed in the Annex XV, we support an extended PFAS reporting obligation for the suppliers to make sure we would be able to comply with the restriction proposal. Process chemicals include lubricants and release agents, heat transfer fluids, test gases, electroplating additives, adhesives, cleaning agents, solvents, and auxiliary materials in the painting process. An obligation to declare PFAS in the safety data sheets of these excipients is also a prerequisite for being able to estimate which industrial machines, plants and processes would be affected. For some applications, there are currently no suitable alternatives, which would lead to significant production restrictions, if banned. Essential coating processes for example are currently not feasible without PFAS. A possible ban on PFAS in all areas of application of the production plants would have to be preceded by a precise declaration obligation to be able to subsequently develop the possible substitutes or process changes. A ban on fluoropolymers, which are classified as polymers of low concern, must be exempted. 4. Summary In summary our demands are: a phase-out roadmap for polymeric and non-polymeric PFAS with risks to humans and the environment and substitution options, a review process for polymeric and non-polymeric PFAS with risks to humans and the environment and a lack of substitution options, a general exemption for fluoropolymers due to their low risk (OECD classification "polymers of low concern"), a general exemption for spare parts based on the "repair as produced" principle, an obligation to declare PFAS, a differentiation of the possible prohibitions according to the use and substitutability of the PFAS components of machine components and process chemicals, the openness to innovation to enable the use of polymers of low concern (PLC) in new technologies and applications that are not yet known, and Research funding for the replacement of essential use PFAS in production, recycling, and waste treatment. 12 ANNEXES alma 13 DRIVING NOBILITY FOR EUROPE I. USES OF PFAS IN H2 TANK STORAGE SYSTEM Identification Product / Technology Short description of product Affected components / PFAS mixtures Hydrogen tank storage systems O-ring sealing in the tank Back-up sealing in the tank O-ring sealing in the valve Gasket in the valve Back-up ring sealing in the valve Anti-wear ring sealing in the valve Rotula bearing Lubricant grease Gasket for cryogenic valve Fluometal bearing for shaft guidance Tank liner-boss Tank liner-boss Valve Valve Valve Valve Rotula (neck mounting) Valve-boss mounting Valve Valve O-ring sealing in vacuum plug Fluometal bearing for sliding suspension Vacuum plug Bracket FVMQ PTFE FKM PTFE PTFE PTFE PTFE PTFE PTFE PTFE FKM PTFE CAS number Low friction 9002-84-0 X 25190-89-0 9002-84-0 X 9002-84-0 X 9002-84-0 X 9002-84-0 X 9002-84-0 X 9002-84-0 X 9002-84-0 X 25190-89-0 9002-84-0 X Function of PFAS in the material Heat resistance / Temperature retention Chemical / fuel stability Durability Pressure equalization (membrane) X X X X X X X Others X X Sealing X Sealing + Vacuum compatibility 14 II. ELECTRONICS IN AUTOMOTIVE INDUSTRY SUMMARY Non-polymeric PFAS monomers are used during the semiconductor manufacturing. Polymeric PFAS are contained in many electrical and electronic components. The dossier submitters have identified "Transport" and "Electronics and semiconductors" as independent main applications (sectors). But, in fact, there are many connections between these two sectors. This was visible during the semiconductor shortage which led to global production stop by many OEMs in 2021 and 2022. The dossier submitters did not propose a derogation for PFAS in electronics. Therefore, we propose to add a derogation for electrical and electronic components for 13.5 years. In the case of semiconductor manufacturing there is a time-unlimited derogation required due to lack of alternatives and complexity of the production processes. AUTOMOTIVE USES Lots of electrical and electronic component are used in automotive parts and vehicles. Many of these components are found on printed circuit board (PCBs): Semiconductors, e.g., ICs, ASICs, Controllers, MEMS sensors Capacitors Inductors and Magnetics Other sensors 15  PFAS are also found in: PCBs as such, e.g., in high-frequency PCBs, Connectors, Wires and cables, Switches and Fuses. [6] The dossier submitters have classified the uses in such a way to distinguish between electronics and transport. However, we would like to emphasize that there are many interlinkages between sector (main application) "Electronics and semiconductors" and "Transport". 16 FUNCTIONAL USES - SEMICONDUCTORS - PFAS IN PRODUCTION PROCESS PFAS are used in semiconductor manufacturing process and advanced packaging. ESIA elaborated on the PFAS use in the semiconductor manufacturing process. PFAS are used in three major manufacturing steps: Photolithography Wet chemistries (additional sub-use) Plasma Etch / Wafer Clean (additional sub-use) 17 [2] -46 vs; _ ally IL% , 0 Figure 10-1 ASML Latest Extreme Ultraviolet Photolithography Exposure Tool.79 aces 18 DRIVING NOBILITY FOR EUROPE Here is an assessment of Alternatives for Photoacid generators (PAGs) used in photolithography manufacturing step. [2] There are no PFAS-free alternatives available for PAGs that fulfils all the required performances. The global semiconductors industry supply chain is complex, and as seen on the following figure, extend to several countries around the globes through dozens of companies. Regulating and monitoring the substances used in the process is especially complex. 19 [3] 20 bray USHIO JEOL - Canon --- Nikon Nuflare - -- SMIT _ ULVAC Kokusai .'", ..lokyo Electron " Screen Ebara Rigaku "` SAMCO Hitachi Lasertec Accretech.---ShirrEtsu -,-.---- ..--- ,--',.... ISR -5,-'--, ---'.--- TOK ---,,,-- *---. .., Fujifilm < .--' _IX Nippon -- -------- Fujimi -- .,,,,. Hitachi Chem --> Sumitomo < SE WI ES ' , Gigatane I AP Systems -.41IIIIMIeNhi..-__.%,,"Sg &r e.,,4: `iki \ Charm Engineering eirt` ,, KOSES '1 - Uniti t ElI V -'4'kf- - Hermes-Epitek - Grand Plastic Nantit Kulick &Soffa Oa' - ASTI Naura Hwatsing Accotest - ASM Pacific ASM Pacific Assembly, Test, & Packaging ASM ASML Besi Mycronic Evatech Camtek Heidelberg SUSS MicroTec Bruker Zeiss - Vistec -- Hesse -- , Grohmann Merck / EMD .,,- BASF Linde Henkel -- Entegris Air Products --- DuPonotr Aa - -- Honeywell Elec. Mat. \ Amkor \\ Quik-Pak Nanonex Applied Materials ,i.\\ LAM Research Mattson Tech \, Vecco Axcelis Nissin Ion Plasma Therm Keithley Thermo Fisher --_ . Keysight Tech --- - KLA COHU Teradyne Micro Control -- National Instruments ifiimfTa1;is1aSuf;:ir:aeDnau4eTmesncetdsha:rl-i -.:-.5::::::;;;;" 7// / Hitachi /,`, i ,- NOK "' ,' i '' ":,,.. Iblden d' ,` --__.- Shinko ,,, TOWA TESEC ___- DISCO - Advantcst - - FasfordTech Note 1: Blue text represents examples of direct semiconductor equipment suppliers. Note 2: Green text represents examples of direct semiconductor material suppliers. Note 3: Flags represent the suppliers' headquarters and do not represent the global extent of the suppliers' operations. Note 4: The facility infrastructure supply chain is not represented in the figure above but has its own unique and complex supply chain. Note 5: Connectors may not represent all supply pathways but rather are representative. Figure 4: The semiconductor global supply chain in 2019: example tier-1 MIRE and material suppliers (The Centerfor Security and Emerging Technology 2019). acea DRIVING MOBILITY FOR EUROPE FUNCTIONAL USES IN MANUFACTURING PROCESS - MEMS SENSORS [5] Alternatives: C3F8, C4F8 (and CF4): Exemplary use cases: used for MEMS Reactive Ion Etching (RIE) and Deep Reactive Ion Etching (DRIE) in order to passivate the silicon surface. Required characteristics: Achievable aspect ratio (defined as the total depth etched divided by the total elapsed time). Alternatives: Not known at all. A sufficient aspect ratio is only known to be commercially achievable with fluorinated process gases. Fluoropolymers are also used in MEMS sensor, such as PFPE: - Exemplary use cases: glue for attaching sensitive MEMS to pressure ports. - Required characteristics: unique combination of wide application temperature range, resistance to chemicals and mechanical properties (stability) - Alternatives: Substitution only partially possible by glass solders with lead (Pb) content. Also, the substance lead (Pb) is affected by several regulations (RoHS, ELV, REACH) and should be avoided as PFAS-replacement for environmental reasons. [5] 21 FUNCTIONAL USES - PFAS IN ADVANCED PACKAGING PFAS are also essential for advanced packaging in finished Semiconductors, which is the state-of-the-art technique. [2] 22 A semiconductor package encloses one or more semiconductor devices or integrated circuits protecting the device from the environment. The package connects the semiconductor to the printed circuit board (PCB), dissipates heat and provides protection from the surrounding environment particularly from moisture, shock/vibration, dust, etc. Assembled packages go through multiple package types, to form three dimensional integrated circuits. Older technologies still use subsequent thermal and chemical steps to produce, therefore thermal and chemical stability in the assembled package are important. For a few older die attach adhesive applications alternatives can be expected in the very near future (1+ year). However, for most adhesives and encapsulants it is expected to take from 10 to more than 13 years to find and implement alternatives. However, for most package related uses of adhesives, in MEMS and Thermal Interface Materials System (TIMS), die overcoats, encapsulants and underfills, die passivation and substrate polymer there are no viable alternatives to the PFAS being used. For some of these technologies, alternatives have been sought for 18 years without success. For these uses it is likely that alternatives will take more than 20 years to find viable alternative chemistries or technologies and 6 years to implement. [2] 23 FUNCTIONAL USES - PASSIVE ELECTRONIC COMPONENTS Passive Electronic Components are components such as Capacitors, Resistors, Inductors (Coils, Chokes), Transformers (Magnetics), Resistors, Substrates & Interconnects, Energy and High Frequency Components [5] : Passive Electronic Components are used to give specific functions to electronic systems. Together with active components, they make it possible for any electronic device to function. Passive Electronic Components are usually mounted on Printed Circuit Boards (PCBs), either mounted directly on the surface (SMD technology) or fixed with leads (wires) using through-hole-technology. PFAS are essential for the functionality of Capacitors, Inductors and Sensors Mainly used polymeric PFAS in products: fluoropolymers, fluoroelastomers, perfluoropolyether Uses and functionality of polymeric PFAS in Passive Electronic Components: Encapsulations and protective coatings to guarantee reliable usage in harsh environments. Electret foil (Electret with permanent electrical dipole) for microphones. Wire insulation, tubes, shrink tubes and membranes to provide electrical insulation and environmental resistance. Sealing material (O-rings, grommets, glues, ...) and lubricants to prevent penetration of liquids and gases. Fluoroelastomer used as adhesive and passivation gel. Hydrophobic coatings. 24 FUNCTIONAL USES - COATING OF ELECTRONIC COMPONENTS Intended use in electrical and electronic equipment {IEEE) [Derogations for EEE should be set at this level.] Non-exhaustive examples of uses Reasons .why PEASs are un-replaceable Functions of EEL requiring:the use of PEAS Functions &IEEE requiring the use of PFAS (Link to Column 6 of List B (Annex 4)i Functional coatings* r_. "Functional coating" is a c:ciatirg applied to an article in order to give it the required functions, as iilustrated in the right cell :.En). 'Functional :coating' inciudes, but riot limited to, "conformal coatfiiisr," used to protect ,;E,,Iectricii-ic materials. In our response, v*ie use the term 'functional coating" because the required functions. are not 'only to protect the objeicts.) [4] Electronic circuit I:ioards, semiconductors, small electroric components ite_g. capacitors., resistors, coils, diodes, transistors., switches, connectors and their electrical junction points), casing; motors., voice coils, parts to protect optical features (e.g. liquid) crystal panels, touch panels,. optical .sensors, LED, Toslink, opticail fibers, lenses for electronic cameras, projection lenses, polarizers), printing process (Toner/ink adhesion prevention, tonerideveloping carrier thernsel',,,es), oil barrier, fan, arid so 07_ Fluorine compourds are the :only coating materials that can simultaneously provide and express multiple fu7ctions required for the proper functioning of electrical and electronic equipment i various environments, such as low refractive index, low dielectric constant and low dielectric loss tangent, electrical insulation, oil repellency, water repe I le-ncy, heat resistance, chemical resistance, weather resistance, rnoldl release and optical 'protection (i.e. for optical sensors, lenses and soon). in addition to the above, toner/development carriers are also rectLirec to be fluidity, charging ciaracteristics, and durability. 1.0ptical function 2_High speed communication and transmissibn LI17 ction 4.51iding functic 7 in mechanica section 6.Safety arid safety functions 7.Functional stir:ace Camera, Lighting, rylonitor/Panel,, Optical cable,l Smartphone,, PC, Antenna, Base :stations. motor, Printer, Industrial equipment, Cable, Medical equipment, Electric appliance, Industrial control equipment, Cooking appliance, Touch par el,, All the EEE in Rol-IS categories I-- 11vvoul d need this function_ acea 25 DRIVING MOBILITY FOR EUROPE  Conformal Coating [9] C6 SFP coatings are used to provide liquid and moisture protection of electronic components. The coatings are described as conformal coatings as they "conform" to the topography of a component or circuit to protect it from the environment and insure reliable performance. Anti-Solder coating [9] Another use of C6 SFPs is anti-solder coating. In soldering of an electronic part, flux is always used to activate the bonding surface, which is included in a solder cream. If this flux penetrates the parts, it potentially causes contact malfunction or other imperfections. By using SC SFPs, penetration of the flux can be prevented without disturbing activation. It is also used in wet chemical processes to facilitate the wetting/coating of difficult to treat surfaces for cleaning, coating, or anti-foaming purposes. They are also used in the manufacture of conductive seals and to help orientation of liquid crystals in liquid-crystal display. Except for anti-flux migration coating, there are non-fluorinated alternatives for protective coating (acrylic type, silicon type, PU type, polyolefin type). However, these substances present several disadvantages: flammability, slower drying time, thermal instability, and excessive film thickness. The nature of the coatings for electrical and electronic equipment, which is dependent on electric currents and electromagnetic fields and custom-made equipment for the generation, transfer, and measurement of such currents and fields to perform adequately, necessitates the use of C6 SFPs. Therefore, we suggest including the following derogation, in line with the SEAC opinion on the PFHxA restriction proposal: 26 FUNCTIONAL USES - CAPACITORS [5] FUNCTIONAL USES IN MANUFACTURING PROCESS - CAPACITORS [5] Alternatives to PFPE: 27  Exemplary use cases: process aid in the manufacturing of film capacitors to define unmetallized area. Required characteristics: unique combination of electrical parameter and heat resistance. Alternatives: Not known. FUNCTIONAL USES - INDUCTORS AND MAGNETICS (CHOKES, COILS, TRANSFORMERS) [5] Alternatives to PTFE, FEP, ETFE, PVDF or PFA: Exemplary use cases: electrical insulation on electronic components (cable sheath, shrink tubes, etc.) Required characteristics: unique combination of heat resistance, electrical insulation, resistance to chemicals and mechanical properties (abrasion, flexibility, ...), Alternatives: PVC or PP are already in use as wire insulation for low temperature applications, but they cannot be used if high operating temperatures (>105C) are required. Polymers like PEEK or Polyimide are suitable for high operating temperature but have different mechanical and/or electrical properties compared with fluorinated polymers. 28  Evaluation of Alternatives for the coating of cables and wires: [4] Supplier is producing transformers, choke coils, inductors. PFAS are contained in the winding wire of transformers in the coating / insulation around the wire. Supplier is claiming PFAS alternatives for this application to be ready by 2024. Supplier is saying that the derogations proposed in the current Restriction Dossier are sufficient to cover their needs of PFAS, since they plan on having an alternative before that. Using a PFAS-free alternative will not have an impact on waste and energy. The PFAS restriction will not impact research and development activities and timeframes. [12] 29 FUNCTIONAL USES - RESISTORS Intended use in electrical and electronic equipment (EEE} [Derogations for EEE should be set at this level.] Non-exhaustive examples of uses Reasons why PFASs are un-replaceable Functions of EEE requiring the use of PFAS Functions of EEE requiring the use of PFAS (Link to Column G of List B (Annex 4)) Functional coatings* (*. "Functional coating" is a coating applied to an article in order to give it the required functions, as illustrated in the right cell (En). "Functional coating" includes, but not limited to, "conformal coating" used to protect electronic materials. In our response, we use the term "functional coating" because the required functions are not only to protect the objects.) Electronic circuit boards, semiconductors, small electronic components (e.g. capacitors, resistors, coils, diodes, transistors, switches, connectors and their electrical junction points), casing, motors, voice coils, parts to protect optical features (e.g. liquid crystal panels, touch panels, optical sensors, LED, Toslinls optical fibers, lenses for electronic cameras, projection lenses, polarizers), printing process (Toner/ink adhesion prevention, tonerldevelopi ng carrier themselves); oi l barrier, fan, and so on. Fluorine compounds are the only coating materials that can simultaneously provide and express multiple functions required for the proper functioning of electrical and electronic equipment in various environments, such as low refractive index, low dielectric constant and low dielectric loss tangent, electrical insulation, oil repellency, water repel lency, heat resistance, chemical resistance, weather resistance, mold release and optical protection (i.e. for optical sensors, lenses and so on). In addition to the above, toner/development carriers are also required to be fluidity, charging characteristics, and durability. [4] 1.0ptical function 2.High speed communication and transmission function 4.Sliding function in mechanical section 6.Safety and safety functions 7.Functional surface Camera, Lighting, Monitor/Panel,, Optical cable, Srnartphone,, PC, Antenna, Base stations Motor, Printer, Industrial equipment, Cable, Medical equipment, Electric appliance, Industrial control equipment, Cooking appliance, Touch panel, All the EEE in Rol-IS categories 1- 11 would need this function, acea 30 DRIVING MOBILITY FOR EUROPE FUNCTIONAL USES - FUSES Polyswitches, also called polyfuses or multifuses, use thermoplastic materials in the organic polymer matrix that gives the fuse its functionality. Currently, PVDF is in use as a thermoplastic PFAS. Changing to a different polymer changes the functionality of the fuse: heating and expansion characteristics are different, causing the device to trip at a different current and to reset differently when cooling down. Alternative materials exist, e.g., thermoplastic PE (Polyethylene), but will need time for full changeover in the portfolio. A minimum of 5 years derogation / 6.5 years transition period is necessary for full changeover. [12] FUNCTIONAL USES - PCB PFAS fluoropolymers are used as a fiber-reinforced fluoropolymer layer in Printed Circuit Boards (PCBs), examples include, PTFE and PFA, for the following benefits: Stable dielectric constant Heat resistance Chemical resistance Non-stick and low frictional properties Water and oil repellent Low dissipation factor, i.e. reduced signal loss They can be used in Rigid, Flexible and Hybrid PCBs. Other materials exist such as traditional FR-4 laminate material (glass-reinforced epoxy), but they show several disadvantages: Signal loss is higher. No stable impedance achievable: not possible for circuits require stable impedance (e.g., HF) Dielectric constant changes too strongly with temperature for applications that involve a wide range of temperatures. Absorbs moisture. Not suitable for applications where a high dielectric constant is necessary, e.g., Radios, antennas, filter circuits, power amplifiers, high-speed digital PCBs. for such requirements, PTFE-based laminates are the material of choice. All other laminate materials show disadvantages in at least one crucial requirement. PFAS are also used in high frequency PCBs: It should be emphasized that specific PFASs (PTFE, PFA, FEP) are also the key material constituting the dielectric layer of the PCB itself. The PTFE and PFA are the key enabling constituents of the performance required of such PCBs for mission-critical applications due to their unique combination of properties: 1. Highly ablative, without charring. 31 2. Low modulus allowing them to be formed around surfaces. 3. Low dielectric constant and low dissipation factor enabling superior electrical performance. 4. Stable at temperatures above 130C, enabling stable performance during temperature excursions. 5. Inherently flame retardant. In Table 1 and 2. PFAS-free alternatives are assessed. Fluoropolymers are the only material that delivers all the required key properties: High frequency range (<= 77 GHz) maximum operating temperature (MOT) > 130C Flame retardancy Formable Time: require significant investment in both time (a minimum of 5 years to invent a replacement, with an additional 5-10 years required to scale to commercial levels and demonstrate reliability Costs: In addition to time, this is a minimum of 7-digit Euro required investment per application to develop such alternative, and a minimum of 6-digit Euro per customer, per application, to qualify such an alternative, if in fact, the alternative can be qualified at all. [7] Use Case by JEITA: There are printed circuit boards where low dielectric constant, heat resistance and flame resistance are required, and fluorinated materials are suitable and actually used for this application. No nonfluorinated material exists that can satisfy these three properties simultaneously. There are nonfluorinated materials that have each of these properties, but they cannot be mixed to make an article that satisfies all three at the same time. Even if they could be mixed, the material mixed would not satisfy heat resistance, as the lowest property of the three substances would appear with regard to thermal properties. The same applies to transparency, low refractive index, low dielectric constant, weather resistance and chemical resistance. [4] 32 FUNCTIONAL USES - SENSORS Types of Sensors and uses of PFAS for Sensors [4], [5]: Coating of Sensors for insulation and for protection against the environment: Use case on next slide (ZVEI) Piezoelectric Material providing the essential function of Piezoelectric components such as Sensors (e.g. Pressure sensors, Acoustic elements): Use case on following slides (JEITA) Glue for attaching MEMS to pressure ports: Use case in semiconductor section (ZVEI) Semiconductor manufacturing process for MEMS sensors: Use case in semiconductor section (ZVEI) Semiconductor packaging process for MEMS sensors: Use case in semiconductor section (RINA study) Alternatives to fluoropolymers and perfluorpolyethers in coatings : Exemplary use cases: coating/encapsulation of sensors in harsh environments Required characteristics: unique combination of heat resistance up to 260C, resistance to chemicals, resistance to moisture and wetness (hydrophobic properties), mechanical properties (stability), dielectric strength at high temperature. It is very likely that alternatives do not exist at all (based on experience from extensive R&D efforts). [5] 33 FUNCTIONAL USES - PIEZOELECTRIC ELEMENTS, E.G. PRESSURE SENSORS [4] 34 FUNCTIONAL USES - PVDF IN PRESSURE SENSORS Intended use in electrical and electronic equipment (EEE) [Derogations for EEE should be set at this level.] Non-exhaustive examples of uses Reasons why PFASs are un-replaceable Piezoelectric elements Piezoelectric elements pressure sensitive films, speakers, microphones, piezo pickups for acoustic guitar PVDF and its copolymers with unique dielectric and piezoelectric properties, which are also excellent in durability, electrical insulation property, and heat resistance are used in piezoelectric elements used in EEE and its components. Therefore, it is impossible to substitute to the Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT. Functions of EEE requiring the use of PFAS Functions of EEE requiring the use of PFAS (Link to Column 6 of List B (Annex 4)) 3.Piezoelectric function Touch panel, Speaker, Various sensor Other products in RoHS categories 1- 11would need this function if they use touch panels or sounds for example. [4] acea 35 DRIVING MOBILITY FOR EUROPE FUNCTIONAL USES - CONNECTORS Connectors are parts or devices used for electrically connecting or disconnecting circuits etc. They can connect and disconnect by hands or with simple tools without requiring special tools or processes such as soldering. We interrogated several suppliers of such components to assess the impact of the PFAS restriction proposal on their activities. [12] Supplier 1: We are not aware of a single replacement insulation material that does not belong to the PFAS group (Insulators with r = 2,05 dielectric constant), because the characteristic impedance is depending on the value of the dielectric constant. PTFE (CAS Nr 9002-84-0) is also used as insulating material by coaxial connectors and very rarely Fluorosilicon rubber (FVQM) (CAS Nr: 63148-56-1) as sealing gasket The insulators are used for assembling the connector. There are alternatives but will need longer time and higher capacity for redesign. The biggest problem is capacity because in all the cases where PFAS material are used (almost in every case PTFE), there is a redesign necessary. The design departments have no capacity to handle all the requested changes: Redesign to reach PFAS free will generate more waste because of bigger components (connectors, cables etc.). Design will need to be larger in size to still achieve the desired characteristic. Moreover, bigger components could have a big impact in the redesign of the final vehicles. Since PEEK, SPS, PBT and LCP have a higher dielectric constant than PTFE, the connectors, cables etc. will need to be larger in size to still achieve the desired characteristic impedance of the transmission channel. Larger connectors do mean heavier connectors, which in turn means more waste of resources, and more weight that vehicles will have to carry around. Thus, the result of the switch away from PTFE will inevitably lead to a higher carbon footprint. Possible future bans on other plastic material would also impact the research for alternatives. It is not feasible, will have significant price increases by low and medium quantities, a larger carbon footprint and more waste. According to Supplier 1 - the only solution is to use PTFE in connector (and cable industry) without limitations. Supplier 2: No derogation for connectors will have a very big impact: loss of business as there are no alternative with the right functionality known. Supplier 3: Supplier is not aware of any alternatives. A PFAS-free alternative will imply more waste and more energy consumption. The research and development activities will be impacted, innovation will be hindered and will require longer timeframes. Supplier 4: This supplier claims to use alternatives for PTFE in the future. But: no one-size-fits-all solution as with PTFE. Instead, every application will have to be substituted with a specific material, depending on the requirements. 36 Depending on the substitution material, will result in larger or heavier connectors, more costly materials, materials that are more difficult to process. This requires R&D effort and redesign downstream of the supply chain which means increased costs. Time estimate: o 3 years for a complete portfolio change only from supplier side. 37 FUNCTIONAL USES - SWITCHES Intended use in electrical and electronic equipment (EEE) [Derogations for EEE should be set at this level.] Non-exhaustive examples of uses Reasons why PFASs are un-replaceable Sliding elements in mechanical section Plain bearings Conductive plain bearings Sliding parts of various electric components (motors, connectors, switches, etc.) Sliding parts of various mechanical components (bearings, gears, winder, etc.) Fixing and photoconductive components, etc., in printing equipment Fluoropolymers with multiple functions such as excellent selflubrication (low coefficient of friction), electrical insulation property, chemical resistance, releasability, heat resistance and flame retardancy are used in sliding elements in mechanical section of EEE and its components to function normally in various environments. The Non-PFAS alternatives mentioned in the ANNEX XV RESTRICTION REPORT cannot be used as they exibit the worst performance. In addition, some components are required to maintain their indispensable sliding characteristics over a long period of time under severe conditions such as high temperature, high pressure, high voltage, and high friction. Fluoropolymers are the only materials that resist such severe conditions, and substituting other materials is impracticable. Functional coatings* (*. "Functional coating" is a coating applied to an article in order to give it the required functions, as illustrated in the right cell (En). "Functional coating" includes, but not limited to, "conformal coating" used to protect electronic materials. In our response, we use the term "functional coating" because the required functions are not only to protect the objects.) Electronic circuit boards, semiconductors, small electronic components (e.g. capacitors, resistors, coils, diodes, transistors, switches, connectors and their electrical junction points), casing, motors, voice coils, parts to protect optical features (e.g. liquid crystal panels, touch panels, optical sensors, LED, Toslink, optical fibers, lenses for electronic cameras, projection lenses, polarizers), printing process (Toner/ink adhesion prevention, toner/developing carrier themselves), oil barrier, fan, and so on. Fluorine compounds are the only coating materials that can simultaneously provide and express multiple functions required for the proper functioning of electrical and electronic equipment in various environments, such as low refractive index, low dielectric constant and low dielectric loss tangent, electrical insulation, oil repellency, water repellency, heat resistance, chemical resistance, weather resistance, mold release and optical protection (i.e. for optical sensors, lenses and so on). In addition to the above, toner/development carriers are also required to be fluidity, charging characteristics, and durability. [4] Functions of EEE requiring the use of PFAS 4.Sliding function in mechanical section Functions of EEE requiring the use of PFAS (Link to Column G of List B (Annex 4)) Motor, Printer, Industrial equipment, Camera All the EEE in RoHS categories 1-11would need this function. 1.Optica I function 2.High speed communication and transmission function 4.Sliding function in mechanical section 6.Safety and safety functions 7.Functional surface Camera, Lighting, Monitor/Panel, Optical cable, Smartphone, PC, Antenna, Base stations Motor, Printer, Industrial equipment, Cable, Medical equipment, Electric appliance, Industrial control equipment, Cooking appliance, Touch panel, All the EEE in RoHS categories 1- 11would need this function. acea 38 DRIVING MOBILITY FOR EUROPE Examples of switches I the automotives industry are Hazard switches, power seat switches, power window switches, sliding door switches, etc. PTFE is used as a structural material for various switches and has waterproof and dustproof functions for the contact area and moderate flexibility functions to transmit the ON/OFF feeling to the fingertip when the button is pressed. It also satisfies the reflow resistance required for the component materials during mounting. The following table shows specific characteristics for PTFE compared to other materials. Each of these properties is found to be superior to the other materials: There are no alternatives to PTFE sheets and PTFE-based adhesive tapes that have the flexibility suitable for switches and the necessary functions of water repellency, stain resistance, and reflow resistance. There is no evidence that new materials with these properties will be developed in the future. [14] 39 FUNCTIONAL USES - CABLES Evaluation of alternatives by JEITA [4] Wires and cables are mainly insulated with fluoropolymer materials. There characteristics are : Resistance to high temperature Chemical inertness Excellent ageing Tenacity Excellent dielectric properties Negligible humidity absorption Good resistance to atmospheric exposure The production process used differs according to the materials: PTFE presented in the form of powder is worked using a discontinuous extrusion process. PTFE tapes use a continuous taping process. ETFE and FEP are thermoplastic materials in the form of granules and use a continuous extrusion process. 40  For the polyimide insulated wires, AXON uses POLYIMIDE tapes with a FEP for heat sealing. These tapes are worked using a continuous taping process. A FEP or PTFE lacquer is added for coloration. AXON also offers equipment wires with POLYIMIDE and PTFE tapes. These products are mainly used for applications where the risk of arc tracking must be avoided. [13] It is not possible to achieve similar performances with others existing materials due to physical reasons. 41 Next are summarized for each potential raw material alternative, what are the limitations justifying why the material cannot be used as material. [13] The potential alternatives to Fluoropolymers are not alternative, as their performances and technical characteristics are not at the level of Fluoropolymers. Conclusion Fluoropolymers must be distinguished from other PFAS. This is particularly true because fluoropolymers have very different toxicological profiles from other PFAS substances. According to OECD criteria, they are considered "Polymers of low concern (PLC)", "Fluoropolymers are non-toxic, not bioavailable, non-water soluble and non-mobile molecules and are deemed as such to have no significant environmental and human health impacts". They are used in a large number of applications, some of which bring considerable benefits to society, up to meeting the ambitions of the European Union in terms of climate, energy, health, and Industry. 42  Currently, there is no alternative material that can replace fluoropolymers. And there is nothing to suggest that it could be otherwise in the short, medium or long term. Therefore, Axon Cable is requesting the Fluoropolymers not to be included in the Restriction proposal. FUNCTIONAL USES - SMALL BATTERIES Use Case "small batteries" means batteries used in Automotive, that are not EV Batteries, and not starter batteries, such as: Battery in E-Call system Battery in Tire pressure sensor Battery in Key Etc Both rechargeable and non-rechargeable (primary) cells use PFAS for several key functionalities within the battery Example for Use in primary (non-rechargeable) Lithium cells: PTFE is used as the binder material for the positive electrode in Lithium primary batteries to provide three main functions: 1. Mechanical cohesion between the positive electrode particles to enable electrode integrity during cell assembly and throughout the lifecycle of the battery storage and use, 2. Lubricant to allow the electrode particles to slide over each other during electrode formation (compression) giving uniform electrode density that is important to consistent battery performance and longevity, 3. Lower water absorption during mixing (PTFE is a hydrophobic material) and more complete drying during electrode baking - low moisture content is critical in Lithium chemistry PFAS Emissions [8], [12]: During battery manufacturing: on empty bags and equipment used on manufacturing process. During battery use : under normal and reasonably foreseeable conditions of use, no end-user of this battery will be exposed to any chemical substances. No PFAS emissions are foreseen during battery use. During battery recycling : no unintended and uncontrolled PFAS emissions are foreseen during battery recycling. 43 FUNCTIONAL USES - OPTICAL ELEMENTS, E.G. LCD PANELS Functional use of Fluoropolymers and Fluorinated polyimides in elements with optical function (LCD panels, manufacturing process of LCD panels, transparent circuit boards). [4] 44 Functions and properties required for EEE Optical function Display function(Liquid crystal display / LCD) [4] Characteristic of parts and materials to achieve their functions and properties of EEE No interference of light transmission (Transparency) Low voltage drive and fast response (Low anisotropic refractive index and low viscosity) Performance requirements for materials (PFAS) Low refractive index, High transmissivity + Water and oil repellency, Flexibility, Flame retardancy Low anisotropic refractive index, Low viscosity, Low voltage drive + Heat resistance, Durability (e.g.) Specific parts or components that accomplish the functions or characteristic of EEE Optical fiber, Optical Lens, LED, Monitor/Panel, Fiberglass, Optical adhesive, Protective coating material, Anti-reflective material, etc. Liquid crystal panel (W, various monitor), etc. acea 45 DRIVING MOBILITY FOR EUROPE SUPPLIER INFORMATION ON PFAS IN LCD PANELS What are liquid crystals? Substances with a PFAs moiety have properties between liquids and solid crystals. Liquid crystal may flow like a liquid, but its molecules may be oriented in a crystal-like way. Properties: Very low water solubility/vapor pressure. No surface-activity feature. Electronegativity of Fluorine leads to electrical dipole of molecule. Due to very specific properties all substitution efforts not successful. Why do Liquid Crystal Displays Need PFAS? The rod-shaped LC molecules need a dipole moment to orient in the electric field direction. Fluorine atoms are a mandatory part of LC molecules for this purpose. Transmittance of an IPS/FFS-LCD-pixel (IPS/FFS: In Plane Switching/Fringe Field Switching) is increasing with increasing voltage - reason is the changed LC orientation depending on the applied voltage. Need for FFS LCDs on Automotive applications: In comparison to other LC technologies FFS features a combination of: higher light transmittance which results in energy saving particularly on high brightness applications. improved safety thanks to readability under various viewing conditions to meet different driver and co-driver and backseat passenger requirements. good switching behavior under various operating temperatures. To assure readability even under bright sunlight automotive displays must be capable of high brightness over the lifetime of the car. In general, device lifetime of LC-displays is unprecedented. Alternative technologies might suffer from demanding environmental conditions such as high brightness at high temperatures which could lead to a replacement before EOL of an automobile. FEEDBACK FROM SUPPLIERS The suppliers are not aware of PFAS-free alternative viable materials - not the right functionality, not available on the market or too high development cost. The supplier is testing alternative material IC/PCBA/Photoresistance/LC for application in their panel product, but they see higher defect rate and worse display effect. Using PFAS-free alternative will result in more waste (worse display effect, higher defect rate, etc.) and longer development timeframes. 46 For the time being, PFAS-free components will greatly affect product performance such as the advection of photoresist will decrease, leading to a decrease in the display effect of the screen. And the anti-static effect of POL will deteriorate, which will cause higher defect rate of our screen, etc. If no derogations were to be granted, all the jobs in the EU would be lost at the supplier's company.[12] EMISSIONS ELECTRONIC COMPONENTS During manufacturing of electronic components PFAS are handled with care and in accordance with applicable regulations regarding hazardous chemicals, occupational health and safety as well as emissions to the environment. Closed systems, extraction and separation plants are commonplace. During use of electronic components No reasonably foreseeable emission of PFAS into the environment during use. During electronics recycling PFAS containing articles in electrical and electronic equipment are collected and dealt with in accordance with applicable regulations, e.g. Waste Framework Directive (WFD) 2008/98/EC, ELV Directive 2000/53/EC and WEEE Directive 2012/19/EU. If the components cannot be repaired or directly reused, they are sent for material or thermal recycling. (a recent study by Conversio has shown that at its end-of-life approximately 85% of all fluoropolymers end up in waste-to-energy recovery incinerators). In these processes, the polymeric PFAS contained in our articles are either broken down into their original components or mineralized so that the PFAS properties are lost. Latest studies confirm that fluoropolymers at their end of life when incinerated under representative European municipal incinerators conditions do not generate any measurable levels of PFAS emissions and therefore pose no risk to human health and the environment. [5] FUNCTIONAL COATINGS OF ELECTRONIC COMPONENTS As coatings for the electronic devices need to be applied in clean room-type working conditions, the emissions during applications are effectively zero. End of life of the components coated with these coatings are covered by the proper treatment defined in the Waste from Electrical and Electronic Equipment (WEEE) and the separate collection defined in the Directive of the Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS). This ensure that emissions at end of life are effectively zero.[9] 47 SEMICONDUCTOR PACKAGING, INCL. MEMS, ASICS There should be no release of PFAS during normal use of consumer or other end products, for those that include PFAS containing semiconductors. The concentrations of PFAS in assembly, testing, and packaging (ATPS) chemistries are low (parts per billion range) and any releases are anticipated to be minimal and only at the end of the product's useful life, during electronics recycling or disposal. Some of the electronic reclamation processes are thermal and may cause a break-down of PFAS, but this would require further investigation.[2] ANALYTICAL METHODS FOR DETECTING AND IDENTIFYING PFAS There are currently no available analytical methods capable of measuring the total speciated PFAS concentration in products. The methods mentioned in Annex E are either : 1. targeted methods or 2. provide results for fluorine, which do not translate in PFAS concentrations. I. Targeted methods: o Are available for limited number of PFAS only, and not all commercially available (lab scale only). o are not all validated and certified, especially the TOPA technique mentioned in the Restriction Dossier. o Make use of expensive or very expensive equipment . II. Total fluorine content methods: o Are useful for general screening, but. o do not give an indication of the type of PFAS species that were/are present and their concentration. o Are mostly not validated and certified, nor commercially available (lab scale only). o Make use of expensive or very expensive equipment and are labor intensive. III. Mixed methods: "Distinguishing between PFAS substances (i.e., a molecule containing at least one carbon on which two fluorine atoms are bound) and non-PFAS organofluorine substances (i.e., molecule containing one fluorine atom bound onto one carbon atom) when measuring the total fluorine content of a product would require highly sophisticated procedures, including target and non-target analyses, that would be able to make the distinction which, to the best of our knowledge, are not yet available." [15] The absence of harmonized analytical methods and suitable analytical standards would pose serious implementation and enforceability challenges to both industry and regulators. Please refer to ATCS Response to the Public Consultation on Restriction Proposal on all PFAS: Part II - Specific Information Requests (ref 4273) for a detailed Overview of Analytical Methods for Measuring PFAS. [15] 48 SOURCES FOR PFAS IN ELECTRONICS [1] ESIA (Ref. 4447): ESIA comments on Annex XV restriction report (2023) [2] SIA PFAS Consortium (RINA): "The Impact of a Potential PFAS Restriction on the Semiconductor Sector" (2022) [3] Semiconductor PFAS Consortium: "Background on Semiconductor Manufacturing and PFAS" (2023) (via Ref. 6016 DuPont) [4] JEITA (Ref. 4543) [5] ZVEI (Draft input) [6] ACEA /CLEPA Industry Guide (public.mdsystem.com/documents/10906/17094/imds_and_technical_definitions_for_elv_exemptio ns.pdf/87f2bed7-4f98-4ccb-82bd-bc4ed3e099a0) [7] Rogers (Ref. 6006 Rogers BV) [8] RECHARGE: Application for derogations from PFAS REACH restriction for specific uses in batteries, First submission (2023) (https://rechargebatteries.org) [9] ATCS (Ref. 6395), ATCS 2nd Public Consultation Contribution, p. 46 ff [10] Infineon (Ref. 4549), [11] SEMI (Ref. 4304) [12] Continental (own data) [13] Axon Cable (Ref. 4456) [14] JAPIA (Ref. 4413), Japan Auto Parts Industries Association (JAPIA) Position to Annex XV Restriction report on 22 March 2023 about a proposal for a restriction on Per- and polyfluoroalkyl substances (PFASs), p.29 ff [15] ATCS (Ref. 4274), ATCS 1st Public Consultation Contribution - Specific information requests, p. 37 ff 49 III. LUBRICANTS SUMMARY The uses of PFAS in lubricants has already been presented in our first submission from May 24th. However, we collected some more insight from suppliers and OEM and wished to bring some addition to the data presented in our first submission. AUTOMOTIVE USES PFPE is used in case of extreme conditions, e.g., extreme temperature differences, maximum durability, possibly in some production plants, Sunroofs to minimize friction, bearings, inside engines etc. High Pressure Ducts Hoses And Reservoirs Console Unit Restraining Devices - Diagnostic Rear Shock Absorbers Housing And Seals Internal Hydraulic or Mechanical Controls and Pumps Power Take-Off Turbocharger Supercharger Exhaust Gas Recirculation Mufflers Sensors Signal Conditioning Devices Stabilizer Bar Rear Suspension Members External Controls - Hydraulic Overhead Console Wheels Traction Battery Actuator Window Display Modules Impacted parts in automotive Strut Front Suspension Members Emission Control - Distributor Mechanisms Jack And Jack Handle Differential Assembly Housing End Couplings and Yokes Parking Brake Controls (Cable) Spare Wheel Frame Mounting Coolant Pump and Flow Control Hinges & Check Side Doors Electric Horns Driver-Operated External Controls - Floor Shift Main molding & lid Manual Control Unit Compressor Transmission Door components Clutch Steering Column Brake by Wire Pulley in alternator Electrical turbocharger Electric motor for battery electric vehicle (BEV) Fuel cell compressor Driver-Operated External Controls Front Shock Absorbers Power Closure Mechanisms Suspension Levelling Power Source Steering Column and Shaft Cab Suspension Levelling Mechanism Multiple Function Controls FEM Carrier Subframe Floor Console Switches Receiver Tubes And Hoses Automatic Control Unit Master Cylinder In-Vehicle Entertainment System Cab Tilting Mechanisms Engines Seats Bearing O-Rings Air conditioner Mirror Steer by Wire IMPACTS TO THE END USER (CONSUMER) AND END OF LIFE/ DISPOSAL (IF APPLICABLE) It might also lead to higher costs for consumers/vehicle owners as parts that usually outwear the whole lifetime of a vehicle must be changed during the lifetime of the vehicle, e.g. engines to move an outer mirror or seats etc. Further use cases are still under evaluation. 50 IV. NON-EXHAUSTIVE LIST OF APPLICATIONS OF FLUOROPOLYMERS AND FLUOROELASTOMERS 48 Volt Power Cabling AC Compressor AC Inverter AC Lines, Receiver Drier and Accumulator Accessory Drive (FEAD, READ) Acoustic Control Components Active Anti-Roll Air Cleaner Air Distribution Duct Components Air Suspension Alarm Horns and Sirens Applied Decorative Trim - (IP) Applied Decorative Trim - Floor Console Applied Decorative Trim - Side Doors Applied Parts - (IP) Applied Parts - Floor Console Automatic / Automated Manual Selector Assembly Auxiliary Water Pump Badging Battery 48V Super Capacitor and Ancillaries Battery Cables Battery, Heat Shield & Battery Management System Belt Driven Integrated Starter Generator (BISG) Body Control Module Body Dash and Cowl Body Side Booster, Master Cylinder and Reservoir Assembly Brake Pipes and Hoses Cabin Rear Trim Cargo Retention Center Stack Charge Port Bowl and Flap CHMSL (Center High Mount Stop Light) Cladding, Body and Wheel Arch Climate Sensors Closure Panel or Knee Bolster (IP) System Description Exhaust Manifold Exterior Usability Appearance and Protection External Communications & Connectivity Interior NVH Pads Internal and External Noise Synthesis Jack and Emergency Tools Fasteners First Row Door Window Lift Assy Fixed Roof Glazing Floor Console Armrest/Lid Floor Console Main Moulding Forward Looking Camera (IPMA) Forward Looking Radar Front Bumper Skin, Foams and mounted Grilles Keyless Vehicle Lighting - Ambient Instrument Panel (IP) & Consoles Load Compartment Floor Trim Load Compartment Fuse Box / Passive Load Compartment Side Trim Load Compartment Transverse Trim Low Pressure Ducts Low Voltage Power Electronics Front Door BIW Front Door Exterior Frame Finisher Main Floor Trim Module - Auto or Powershift Trans as Shipped Front Door Interior Frame Finisher Front Door Trim Panel Front Drive Unit Front End Module Carrier Front Fenders Front Floor Module - Body Part Assembly Module - Cockpit complete Module - Cooling Pack Noise Insulation, Hood and Engine Bay NS Powertrain Mounting System Oil Filter, Level Indicator and Cooler Front Foundation Brakes FrontPropshaft Front Side Door Dynamic Weatherstrip Front Side Door Glass Front Springs and Dampers Front Stabilizer (Anti-Roll) Bar Front Structure Onboard Charger Overhead Console Parcel Shelf / Blinds Passenger Entertainment Displays Pedals Pillar Trim Lower Pillar Trim Upper Front Sub-Frame Complete Power Amplifier Front Suspension Knuckle Assembly Power Outlet & Lighter Front Suspension Links / Arms Upper and Lower Power Side Door Mechanism Front User Interface Display Front Wheel Arch Liners and Baffles Fuel Cell Fuel Distribution Fuel Evaporative Control Fuel Filler (Refueling) Power Transfer Unit Powertrain and Auxiliary Control Modules Powertrain Control Modules: Mounting Hardware Powertrain Control: Sensors and Actuators Radiator Radiator Grill (non-bumper mounted) Fuel Filler and Flap Radio Frequency Key Rear Suspension Knuckle Assembly Rear Suspension Links/Arms Upper & Lower Rear Wheel Arch Liners and Baffles Rear Wheel Steering Actuation Restraint Electronics Road Wheel and Tyre Assembly Roof Bars and Roof Rack Seat Belts Seat console Seats Second Row Door,Qtr& Rear Closure Window Lift Assy Side Door Latches and Exterior Handles Side Doors Hinges and Checks Spare Wheel and Tyre Assembly Speakers Special Protective Structures Stability Control Systems Starter Motor Static Sealing and Structural Adhesive Steering Column Steering Wheel Sun Visors Sunroof Assembly Supplemental Front Lamps Supplemental Rear Lamps Supplementary Heat Source Surround Cameras Suspension Controls Switch gear Towing and Recovery Attachments Towing Electrical Traction Battery Traffic Horns (Electric) Transmission Dress Items (Auto) Transmission Dress Items (Manual) Transmission Oil Cooler 51 Clutch Actuation Assembly Column Cowl Consumer Electronics Interface Module Convertible Top Assembly Fuel Tank Assembly Gear Shift Module (GSM) Generator/Alternator Grille Opening Panel/Front Sheet Metal Cooling Fan and Shrouds Cross-Car Beam (IP) Curtain Airbag System Cylinder Block DCDC Converter Dressed Engine Exterior Covers Driver Airbag and Cover Driver Information Module (Instrument Cluster) Headlamp Cluster Headliner Assembly Heat Insulation and NVH Shields Engine Bay & Underfloor High Pressure Ducts High Voltage Fuse Box High Voltage Power Cabling Hood BIW Panel Hood Hinges EDS Components & Fasteners Electric Vehicle Supply Equipment (EVSE) Electric Water Pump Emission Control Components Emissions Additive Storage, Supply and Conditioning Engine Bay Fuse Box / Passive Engine Compartment Trim / EBox Engine Cooling Hood Latch & Actuation Hood Support and Struts Hose Set - Coolant (includes Expansion Tank) HVAC Auxiliary Unit HVAC Main Unit Infotainment Antennas and Cables Infotainment Head Unit Infotainment Remote Control and Headphones Engine Covers Inner Handles Engine Ventilation Instrument Panel Main Molding EW Powertrain Mounting System Interior Lighting Exhaust Gas Recirculation Interior Mirror Rear AC Control Module Rear Bumper Skin and Foams Rear Closure BIW Panel Rear Closure Dynamic Weatherstrip Rear Closure Exterior Handle and Actuation Rear Closure Finishers Rear Closure Hinges Rear Closure Interior Trim Panel Rear Closure Latches Rear Closure Support & Checks Rear Combination Lamp Transmission Oil Cooler Pipes Turbocharger or Supercharger Under Engine Closures, Rock Shields and Engine Bay Air Guides Underfloor Closures Upper Exterior and Roof Finish Vacuum Distibution Components Windscreen & Tailgate Washer System Wiper Assembly Front Wiper Assembly Rear Wiring harnesses Accessory Drive Belt (V, micro-V) Rear Door BIW Rear Door Exterior Frame Finisher Rear Door or Rear Quarter Trim Panel Tensioner, Idler and Pulley Mechanical or Electrical Waterpump Cooland Hose Rear Drive Unit Rear Floor Fuel Hose Thermostat Rear Foundation Brakes Rear Propshaft Rear Side Door Dynamic Weatherstrip Coolant Thermostat Radiator Cap Expansion Tank Cap Rear Side Door Glass Rear Spoiler Rear Springs and Dampers Electrical-turbocharger Electric motor for battery electric vehicle Fuel Cell Compressor Rear Stabilizer (Anti-Roll) Bar Rear Sub-Frame Complete Synchronous Belt 52 Short description of product Lacquers Paints - mixtures Assembly elements Valve Actuators Sealing ring Washers, screws, nuts Bearings Bushings Bushings Process - Raziol Drylub WA 03 T V. NON-EXHAUSTIVE LIST OF PFAS USED IN LACQUERS AND IMPACTED PARTS Identification Affected components / mixtures Affected components / mixtures CAS number Lacquer, topcoat Lacquer, topcoat Lacquer Lacquer, topcoat Horn Spring Buckle spring Metal pillar loop Screw 9002-84-0 9002-84-0 9002-84-0 9002-84-0 paints for our MAKE parts (decoration) screws, nuts, bolts, headlamps, rearlamp Pressure Equalizing Membrane Actuators Filter: die Cut Filter Media Gear: Torque regulation Gas Tightness Products Coating: e.g. Zinc flake with topcoat (GEOMET 500B acc. ISO 10683) Slotted bushing in actuator housing drive unit Process lubricant (shrinking, stuffing) Actuators Exhaust system Exhaust Valvle Canning 9002-84-0 9002-84-0 9002-84-0 9002-84-0 FMACP PTFE 5 25190-89-0 69991-61-3 9002-84-0 69991-61-3 370097-12-4 9002-84-0 Low frictio n Durability Function of PFAS in the material Heat resistance / Temperature retention Chemical / fuel stability Pressure equalization (membrane) X X X X X X X X X X X X X X X X Others Noise reduction Noise reduction X X X 53 Short description of product Thread Spacer fabric Textile - Insert - deep garnet Seat trim cover VI. NON-EXHAUSTIVE LIST OF PFAS USED IN TEXTILES Identification Affected components / PFAS mixtures CAS number PA66 5.1.b unfilled Thermoplastics PET 5.1.b unfilled Thermoplastics PET 5.5.2 Textiles (in polymeric compounds) 5% FAA/ Fluoroalkyl Acrylate as 9.2 Lubricants 2% PTFE FAA mat class 6.2 Adhesives, sealants Propane, 1,1,1,2,2,3,3-heptafluoro-3-((trifluoroethenyl)oxy)-, polymer with tetrafluoroethene and trifluoro(trifluoromethoxy)ethene Propanoyl fluoride, 2,3,3,3-tetrafluoro-2-(1,1,2,3,3,3-hexafluoro-2(heptafluoropropoxy)propoxy)-, polymer with trifluoro(trifluoromethyl)oxirane, reaction products with 3-(ethenyldimethylsilyl)-N-methylbenzenamine 165178-32-5 185701-88-6 Propanenitrile, 3,3'-[[4-[[2-bromo-4-nitro-6(trifluoromethyl)phenyl]azo]phenyl]imino]bis- (9CI) Ethene, tetrafluoro-, polymer with trifluoro(trifluoromethoxy)ethene Perfluoropolyether Ethene, tetrafluoro-, homopolymer Ethylene, tetrafluoro-, polymer Propene, 1,1,2,3,3,3-hexafluoro-, polymer with 1,1-difluoroethene Propane, 1,1,1,2,2,3,3-heptafluoro-3-((trifluoroethenyl)oxy)-, polym. 2,2,2-Trifluoroethyl acrylate 1-Hexene, 3,3,4,4,5,5,6,6,6-nonafluoro-, polymer with ethene and tetrafluoroethene 246871-16-9 26425-79-6 60164-51-4 9002-84-0 9002-84-0 9011-17-0 26655-00-5 407-47-6 68258-85-5 Function of PFAS Durability Others (X) Anti soiling 54