Document wgEVkOEr82a7nqEGeeBNbe2jJ

DIG1TALEUROPE A DIGITAL view on the PFAS restriction We represent over 45,000 businesses across Europe The voice of digitally transforming industries platform services data analytics software & hardware cybersecurity telecoms semiconductors cloud technology Healthcare Manufacturing Finance Buildings Mobility 41 NATIONAL ASSOCIATIONS 100 COMPANIES 60+ Categories of uses identified in electronics* Application area Coatings *Excluding semiconductors, energy, medical, automotive, aerospace Printed circuit boards High voltage/power applications Cables and connectors Components Mechanical applications Displays Batteries Fire prevention Heat transfer Details Capacitors, dielectric films Electret films in microphones, sensors Gaskets, sealing Microphone/speaker vent membrane Piezo in acoustical equipment Rubber parts in image forming process in printers Chemical equipment Chemicals 3Others Complexity of electronics supply chain Even a simple circuit board contains dozens of different components A component consists of many articles A product contains thousands of articles Each article to be investigated for the use of PFAS 4 Towards PFAS-free electronics No drop-in alternatives for most applications In many cases, there is no alternative for PFAS yet (e.g., Li ion batteries) At least 48 months transition time Once alternative is available, product re-design normally takes minimum 24 months (selection, qualification, certification, etc.) Redesign of a complete portfolio takes longer EU RoHS phthalate restriction transition time was 4 years EU Battery Regulation final draft requirements impacting design gives 42 months Applications which have no alternatives will require timebound derogations like EU RoHS exemptions 5 Annex XV report about electronics Elements contradicting circularity for electronics and twin transition objectives 1 Apart from proposed 12-year derogation for the semiconductor manufacturing process, no derogations for the electronics sector No computing / communications products will meet 18 months transition period Huge economic impact, business closures 2 No exemption for spare parts of existing products No spare parts can be made available despite the requirement to do so under the EU Ecodesign directive/regulation As is, restriction will lead to premature obsolescence of products on the market 3 No exemption for refurbished or second-hand products / articles already on the market Use and emissions from electronics are less than 1% of the 6 total PFAS use and emission All stakeholder input to be taken into account Sufficient time required for authorities to evaluate stakeholder input Electronics industry will provide much more details in public consultation 7 Conclusions & Way forward Current proposal will force most electronic products to be withdrawn from the market due to short transition period and no exemptions Elements are contradicting the Green Deal, Circular Electronics, and particularly Ecodesign objectives Digital/Green Transition objectives impossible No refurbishment, no repair; premature obsolescence Transition towards PFAS-free electronics will take time At least 48 Months needed for transition where alternatives are available Time-bound exemptions for uses with no alternatives Exemption for spare parts and articles already on the market 8 #AStrongerDigitalEurope @DIGITALEUROPE linkedin.com/digitaleurope Thank you for your attention!