Document wDEkXQ3ERODzd3pxoEORZLmX3
Science. Applied to Life. "
Meeting with EC DG GROW (Director Carlo Pettinelli & Team)
Online meeting 24 September 2020
Ref. Ares(2023)3666686 - 26/05/2023
Agenda
Tour de Table Introduction to 3M EU Policy Agenda: Green Deal & Circular Economy Chemicals Strategy for Sustainability PFAS
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Introduction to 3M
3M in Europe, Middle-East & Africa
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3M located in 53 countries across 7 regions
21,000+ employees including 1,500 scientists, 5,800 customer-facing employees, and 11,100 workers in Manufacturing & Supply Chain
44 manufacturing sites and 20 Distribution Centers
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We are the company with ideas that stick.
Our 4 Business Areas for Government, Industry & Society
Safety & Industrial
Transportation & Electronics
Health Care
Consumer
Personal safety Adhesives and tapes Abrasives Closure and masking Electrical markets Automotive aftermarket Industrial minerals
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Automotive and aerospace Electronics Transportation safety Display materials Commercial solutions Advanced materials
Medical solutions Oral care Separation and purification sciences Health information systems Food safety
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Stationery and office supplies Home improvement Home care Consumer health care
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EU Policy Agenda & Green Deal
3M supports the EU Single Market & Green Deal: science based legislation to support innovation & jobs
3M is committed to promoting innovation, safe use of our products, sustainable manufacturing and stewardship across the industry.
3M advocates for a balanced regulatory environment based on scientific facts to ensure European industries remain competitive and sustainable.
3M & PFAS:
3M manufactures, imports, uses, and supplies various PFAS and PFAS containing products for
numerous, primarily industrial, applications. We produce PFAS in 2 sites: Zwijndrecht, Belgium and Gendorf, Germany.
Performance. Credibility, Transparency
3M participated to the Call for Evidence related to an evaluation of restriction options for PFAS.
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Sustainability at 3M - Apply science to improve every life
Design solutions that do more with less material, advancing a global circular economy.
Innovate to decarbonize industry, accelerate global climate solutions and improve our environmental footprint.
2020 3M Sustainability Report
Create a more positive world through science and inspire people to join us.
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Alignment with the UN Sustainable Development Goals
The UN SDGS serve as a global pledge to leave no one behind in pursuit of social, environmental and economic peace and prosperity
Circular Economy: Up-Cycling Fluoropolymers in Germany
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Up-Cycling
Ground breaking for a closed loop!
Why Up-Cycling perfluoropolymers?
Perfluorinated polymers are materials with very special features everybody appreciates in their applications, from cook and baking equipment and contemporary architecture to making our cars more efficient and less oil and gas corsuming to protecting our chemical plants from harmful substances.
Life became cleaner and safer with using perfluoropolymers in many aspects, but when the end of life has been reached tne valuable material goes to incineration or landfill disposal. So across countries we see that landfill deposits flow over - cost for waste management is increasing and valuable (irreplaceable) raw materials are disposed in stead of being kept in the value chain. Fully fluorinate, unfilled material commonly goes into Re-Cycling processes, degrading the material to very fine powder or wax, but with limited usability.
This document will show you the benefits for all parties involved, if fully fluorinated poly mers are Up-Cycled instead of disposed. How we do it and how you can contribute to saving resources and cost.
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Chemicals Strategy for Sustainability
3M Viewpoint on the Chemicals Strategy for Sustainability
REACH has helped provide predictability and a level playing field. That needs to be maintained. Any legislative proposal or regulatory process needs to be based on sound science. Unacceptable risks associated with a substance need to be demonstrated before any risk
management option is carried out. Regarding the reported PFAS Action Plan:
o Restricting the 4,000+ PFAS substances risks uprooting the scientific basis of REACH and impacting European industries' ability to innovate in technologies central to achieving a European green deal and the circular economy.
o An overly narrow regulatory focus on Persistence only will undermine innovation, including to produce durable and high performing materials that support societal sustainability goals.
o A blanket restriction on PFAS would impact many sectors and have far-reaching effects on innovation, investment and jobs in Europe - need to involve all stakeholders.
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PFAS
PFAS: Many Important Applications
Low Emission
Transportation
Combustion Engine & Alternative Energy Aerospace
Corrosion Protection & Emission Reduction Chemical & Power plants
Fire-safe, durable roof for large events
Semi Conductor & Pharmaceutical Manufacturing
Medical Applications
Fire Suppression
Energy Recovery
& Heat Transfer
Data Center Cooling
The majority of PFAS uses today are in applications with high societal value and important to the functioning of our modern life
Some of these critical applications are supporting the Green Deal agenda - example of specialty chemicals
Protecting art & valuable assets from fire
Cooling data centers without using energy
Protecting people from fire with low GWP solution
Reducing climate impact of the energy sector
Cooling batteries in EVs
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Fluoropolymers are also in critical applications
Fluoropolymer sales to key sectors in the EU (2015)
Transport
18.500 Tonnes
300 Cm
Chemicals & power
16.500 Tonnes 220 cm
Cookware
3.500 Tonnes
60 Cm
Electronics
3,500 Tonnes
50 Cm
Food & pharma
3.000 Tonnes 40 Cm
Textiles & architecture 3.000 Tonnes 40 Cm
Medical applications
1,500 T
20 Cm
Renewable energy
500 Tonnes
<5 Cm
Other
2,000 Tonnes 30 Cm
G Gr
r S> ()
GI
TOTAL
52,000 Tonnes 780 Cm
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Example application and benefit of fluoropolymers
Fluoropolymer fuel hoses enable fuel savings and reduce damage from emissions, worth - 140m per year in EU
Corrosion prevention saving hundreds of millicns of each year in the EU
Easy clean non-stick properties, allows cooking with less fat
il n semiconductor manufacturing, enabling progress In IT that has generated trillions of C globally in the last 20 years
Safer and cheaper food and pharma by preventing contamnation and material failure
Enabling novel and ursque 'landmark* architectural designs
Reduces the risks of falure. cross-infections and clogging of medical equipment
PV module producten efhc^ncy increases which save 40m - 90m each year in the EU
Statistics on sectors where fluoropolymers are used
Nearly 5 mJiion employed > 2 millien employed
Europe accounts for 41% of global medeal device patents
Source: Plastics Europe (2017) Socio-economic Analysis of the European Fluoropolymer Industry
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Fluoropolymers - 4 reasons for exclusion from a restriction
Fluoropolymers are highly stable high molecular weight materials. They have no bio-availability and no mobility in the environment
Fluoropolymers do not degrade in the environment They are indispensable in many applications with high
societal value Fluorinated emulsifiers are used in a controlled way in
the manufacture of some fluoropolymers
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3M Considerations on PFAS
Legislative and regulatory measures based on grouping of 4,000+ substances with different chemical structure, physiochemical properties and an extremely wide range of applications across industrial sectors is neither scientifically justified nor appropriate and highly difficult to implement.
Instead of a blanket approach, we believe PFAS of concern can be better addressed under REACH when grouped according to their structure.
High molecular weight fluoropolymers should be excluded from restriction as they are polymers of low concern and important to many key sectors.
Persistence on its own is not enough to assess or demonstrate an unacceptable risk to human health and environment and, therefore to ban or restrict substances being manufactured, imported, or used in products, particularly in such a broad fashion.
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3M Considerations on Essential Uses
The essential use concept could not replace a proper impact assessment process and could not be used to bypass a proper risk assessment.
Applying the essential/non-essential use concept in the absence of a demonstrated unacceptable risk would mean that products would be banned on the basis of unnecessarily intrusive judgements of what is good or bad for society, which is by nature relative and must remain evolutionary.
Applying the essential/non-essential use concept should allow the use of substances when the benefits to society, including socio economic benefits, outweigh the demonstrated unacceptable risk, if any, and for which there are no equally performing, technically and economically feasible alternatives available. Such an analysis should also account for a life cycle assessment point of view.
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Other Considerations
Most PFAS are manufactured for industrial uses. Most are manufactured in closed systems and under controlled conditions. PFAS-enabled articles have well controlled waste streams, including recovery and recycling (e.g. medical devices, automotive, electronics), so typically PFAS-containing materials in those uses would not add to the environment at the end-of-life of products.
The majority of PFAS uses today are in applications of high societal value and important to the functioning our modern life (e.g. electronics, automobiles, airplanes, solar panels, medical imaging, medical devices, medicines, buildings, and many others). 3Mmanufactured PFAS products are used in many critical mainly industrial applications where they present significant socio-economic benefits and have no technically and economically feasible alternatives with equal performance.
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We are a company that helped Neil Armstrong take one small step on the moon.