Document wr07zROyjB8aBXBZxmKOXvV66

Input to the Public Consultation Comments for Annex XV restriction Proposal. Missing use: Coaxial Antenna Cable in High-Speed Communication Networks Enabling Rapid Data Exchange CONTENT 1. INTRODUCTION TO COMMSCOPE AND COAXIAL CABLES 2. STRUCTURE AND COMPONENTS 3. DIELECTRIC MATERIAL OF COAXIAL ANTENNA CABLES 4. APPLICATIONS IN HIGH-SPEED COMMUNICATION NETWORKS: 5. ALTERNATIVES 6. JUSTIFICATION FOR A DEROGATION REQUEST 7. PROPOSED DEROGATION 1. INTRODUCTION TO COMMSCOPE AND COAXIAL CABLES CommScope is a manufacturer of communications technology. We design, manufacture, install and support the hardware infrastructure and software intelligence that enable our digital society to interact and thrive. Working with customers, CommScope advances broadband, enterprise and wireless networks to power progress and create lasting connections. For more than 40 years, CommScope has been a leader in the development and manufacture of the coaxial cable. CommScope offers a family of high-performance coaxial cables, including cables for satellite, security, closed-circuit television (CCTV), video applications, and residential or commercial structures. The primary function of coaxial cable is to transmit signals with minimal distortion and interference. The design of coaxial cables minimizes the impact of external electromagnetic radiation and reduces signal loss, allowing for higher data transmission rates and improved signal quality compared to other transmission media. In the realm of high-speed communication networks, coaxial cables emerge as a crucial player, facilitating rapid and reliable data exchange over considerable distances. Their well-engineered structure and unique attributes make them an excellent choice for transmitting data at high speeds while mitigating signal degradation and interference. Coaxial antenna cables face extreme environmental conditions and customer demands for signal transmission quality. The ability to achieve low transmission loss in this environment require unique material properties derived from the molecular structure of fluoropolymers and is impossible to achieve with any other polymer. 2. STRUCTURE AND COMPONENTS: Coaxial cable, commonly referred to as coax cable, is a versatile and widely used communication transmission medium that plays a pivotal role in facilitating the exchange of data, signals, and information across various domains. At its core, coax cables used in high-speed communication networks comprises four essential components: 1. Central Conductor: Often constructed from highly conductive materials like copper or aluminum, the central conductor forms the pathway through which high-speed data signals travel. Its exceptional conductivity ensures efficient signal transmission even at elevated frequencies. 2. Dielectric Layer: The dielectric material surrounding the central conductor plays a critical role in maintaining signal integrity. In high-speed communication networks, advanced dielectric materials with low dielectric constants are employed to minimize signal loss and distortion. Antenna cables, also known as RF (Radio Frequency) cables, utilize PTFE, FEP or similar fluoropolymers for their dielectric insulators due to several properties that are crucial for efficient signal transmission and overall antenna performance. 3. Metallic Shield: The metallic shield serves as a guard against electromagnetic interference that can compromise signal quality. Its effectiveness becomes more pronounced in high-speed networks, where maintaining signal clarity is paramount. 4. Outer Insulating Layer: The outer insulating layer provides mechanical protection and insulation, ensuring the cable's durability and safety. Figure 1 - coax cable 3. DIELECTRIC MATERIAL OF COAXIAL ANTENNA CABLES Antenna cables, also known as RF (Radio Frequency) cables, utilize PTFE (Polytetrafluoroethylene), FEP (fluorinated ethylene propylene) or similar fluoropolymers for their dielectric insulators due to several properties that are crucial for efficient signal transmission and overall antenna performance: 1. Low Dielectric Constant: Fluoropolymers have low dielectric constants, which enable the propagation of RF signals with minimal signal loss and reduced phase distortion. This characteristic is crucial for maintaining the integrity of high-frequency signals, especially in applications where signal clarity and accuracy are paramount, such as in wireless communications. 2. Low Dielectric Loss: Fluoropolymers also exhibit low dielectric loss, which means they absorb minimal energy from the RF signals passing through the cable. This property contributes to higher efficiency in signal transmission, reduced heat generation, and improved overall signal quality. 3. Stable Performance Across Frequencies: Antenna systems operate over a wide range of frequencies, and the dielectric material used should maintain consistent electrical properties across this spectrum. Fluoropolymers offer stable performance over various frequencies, which is crucial for maintaining signal quality in broadband communication systems. 4. High Power Handling Capability: Some antenna applications require the handling of high power levels, such as in broadcasting or radar systems. Fluoropolymers can withstand higher power levels due to their low dielectric loss and excellent insulating properties, reducing the risk of signal degradation or insulation breakdown. 5. Temperature Stability: Antenna cables are often exposed to a range of temperatures, from extreme cold to high heat. Fluoropolymers exhibit excellent temperature stability, maintaining their electrical properties across a wide temperature range. This stability is essential to ensure consistent antenna performance under varying environmental conditions. 6. Chemical Resistance: Fluoropolymers have strong resistance to chemicals, moisture, and environmental contaminants. This resistance prevents degradation of the dielectric material over time, ensuring long-term reliability and consistent signal transmission. 7. Mechanical Durability: Antenna cables can be subject to mechanical stress during installation, bending, and movement. Fluoropolymers offer good mechanical strength and durability, reducing the risk of cable damage and maintaining signal integrity even under physical strain. 8. Non-Stick Surface: PTFE is known for its non-stick surface properties, which can make cable installation and handling easier and more efficient. We source for our antenna business components made of below listed fluoropolymers. The total mass used is approximately 375 tons / year. PTFE CAS No. 9002-84-0 (Polytetrafluorethylen) FEP CAS No. 25067-11-2 (Polyfluor(ethylen-propylen) The ability to achieve efficient signal transmission and overall antenna performance is a unique property derived from the molecular structure of fluoropolymers and is with the current state of technology impossible to achieve with any other polymers. 4. HIGH-SPEED COMMUNICATION NETWORK APPLICATIONS: High-speed communication networks have a wide range of applications that span various sectors and industries. Coaxial cables remain a crucial component in these networks. Some notable applications: 1. 5G networks: While 5G networks rely heavily on wireless technologies, coaxial cables maintain their significance by providing reliable, high-speed connections for antenna feedlines, backhaul, fronthaul, small cell deployments, in-building coverage and more. Their ability to offer lowlatency, high-quality connections and their compatibility with various deployment scenarios make them a crucial component in the evolving 5G landscape. 2. Telecommunications and Internet Connectivity: High-speed communication networks are the backbone of modern telecommunications and the internet. They enable fast and reliable data transfer, video conferencing, voice-over-IP (VoIP) services, and seamless browsing experiences. 3. Cloud Computing and Data Centers: Cloud computing relies on high-speed networks to provide on-demand access to computing resources and storage. These networks ensure quick data transmission between users and remote data centers, enabling efficient deployment of virtual machines, storage, and applications. 4. Smart Cities and Internet of Things (IoT): High-speed communication networks play a crucial role in creating smart cities and powering IoT devices. These networks enable real-time data collection, analysis, and control of various urban systems, such as transportation, energy management, and public safety. 5. Streaming and Online Entertainment: Services like video streaming, online gaming, and interactive entertainment heavily depend on high-speed networks to deliver high-quality content and low-latency experiences to users. These networks ensure minimal buffering, lag, and latency issues. 6. Telemedicine and Remote Healthcare: High-speed communication networks are essential for telemedicine and remote healthcare applications. They facilitate real-time video consultations, remote patient monitoring, and the exchange of medical data between healthcare professionals and patients, regardless of their geographical locations. 7. Radiating cable: A special form of a coaxial cable is a radiating cable which is used as an antenna in tunnel applications. Due to safety in longer tunnels (>500m), a mission-critical communication for fire-brigades, police, etc. is a must. This is usually done with an active Distributed Antenna System (supplied by CommScope) where RF signals from Base Stations outside of the tunnel are received at a Head End, converted into optical signals, and distributed intelligently over fiber to Remote Units which are installed inside the tunnels. These are then reconverting the optical signals into RF, amplifying the RF signals, and serving these radiating cables. In event of a fire or an accident inside the tunnel, these mission-critical communications need to work as long as possible which sets certain flammable requirements for the DAS and the radiating cables. These applications are an illustration of the critical role that high-speed communication networks play in shaping the digital landscape and driving innovation across various sectors. As technology continues to evolve, coaxial cables remain an asset, underpinning the seamless flow of data in the era of rapid information exchange. 5. ANALYSIS OF ALTERNATIVES The key function of fluoropolymers as the dielectric material in coaxial cables is to be a good dielectric insulator that provide flexibility and low friction for the cable. These cables can today only achieve the performance prescribed in industry standards with a fluoropolymer dielectric material. Standards and regulations that set performance requirements for coaxial cables: IEC 61196 IEC 60966 Regulation (EU) No 305/2011 EN 13501-6 Coaxial communication cables Radio frequency and coaxial cable assemblies Construction Products Regulation Fire classification of construction products: power, control, and communication cables CommScope is a downstream user of dielectric materials. We specify, based on the relevant standards and customer demands, the required properties but are dependent on the know-how of our suppliers for the exact formulation of the materials we buy. To date, no viable PFAS free alternatives exist, capable of meeting all the standards and customer demands. Investigations for substitution have been performed, however without positive outcomes. Additional work and time are required to identify potential alternatives and carry out all associated R&D work, testing, as well as to implement it for substituting the use of fluoropolymers. 6. JUSTIFICATION FOR A DEROGATION REQUEST Industrialization is a long and complex step-by-step methodology followed to implement a qualified material or process throughout the manufacturing, supply chain and maintenance operations, leading to the items' final certification. This includes renegotiation with suppliers, investment in process implementation and the final audit to qualify the new process throughout the supply chain. Any change in the process or in the components concerned can take several years to requalify and ensure that the level of performance achieved is as good as the previous one. To allow industrial deployment, the following milestones must be applied: 1. Literature search and prioritization of possible alternatives (3 - 6 months) 2. Manufacture of prototypes (6 months - 3 years) 3. Test of prototypes, this usually includes several iteration steps to adjust the prototype according to the test results (2 year) 4. Standardization of the new coax cable and test methods (3 years, can be partially parallel to 5: for 4 and 5 together 5 years) 5. Approval test: Sample production, test at customer site, inhouse test, third party certification (3 years, included in the 5 years for 4 and 5) 6. Change of production from fluoropolymer to an alternative material first in pre-series and then in series-production (3 years) 7. Market acceptance of the new coax cable and complete change to cables without fluoropolymer (3 years) Transitioning away from PFAS will require collaboration among stakeholders-- manufacturers, regulators, researchers, and environmentalists. A phased approach, allowing for the development and testing of safer alternatives, could minimize economic disruption while ensuring ecological benefits. Economic Implications: A ban of fluoropolymers in professional coax cables causes high additional costs for the manufacturers and even more for consumers and states due to enhancing the costs of products and services while no additional function or other direct benefit would result. Research and Development Costs: Exploring and adopting alternative materials would involve substantial research and development investments, with uncertain results. These costs could strain industry budgets and slow down innovation in the fast-paced electronics sector. Supply Chain Disruption: A sudden ban of fluoropolymers could disrupt the supply chain of alternative materials, causing delays in manufacturing and potentially affecting product availability. Product Performance: Fluoropolymers contribute to the durability and performance of highspeed communication networks. Abruptly removing them could lead to subpar product quality, negatively impacting consumer satisfaction and driving up warranty and replacement costs. Job Market: A ban might lead to job losses in manufacturing, research, and related sectors, potentially affecting local economies. Ecological Concerns: A ban of fluoropolymers could result in a thousandfold the amount of unnecessary electrical waste of the number of fluoropolymers saved. Switching to alternatives without comprehensive safety assessments could lead to unintended ecological consequences. Identifying safer alternatives with comparable properties poses a significant challenge. Fluoropolymers have been categorized as PFAS when based solely on their molecular structure. However, their environmental and toxicological profiles are distinctly different to most of the other lower molecular weight PFAS: In general, the properties of many fluoropolymers are such that they do not display the environmental and toxicological profiles associated with some PFAS that could be considered of concern; commercially popular fluoropolymers meet the OECD Polymer of Low Concern criteria. They are chemically stable, nontoxic, non-bioavailable, non-water soluble and non-mobile materials and they are deemed to have no significant environmental and human health impacts. A ban on PFAS in professional coax cables without derogation would have severe negative impacts on basic societal requirements. Improvements intended by major EU legislation like the EU Green Deal, or the EU Chips Act would be hindered or even get impossible. 7. PROPOSED DEROGATION As illustrated by us, technically and economically feasible alternatives will not be available within a five-year derogation window. Even when they can be identified, these alternatives will require regulatory approval or certification that cannot be completed within the five-year timeframe. CommScope, supplying EU critical sectors, have identified the need for the following 13.5-year derogations: Use of PTFE, FEP and other fluoropolymers as dielectric material in coax cables until 13.5 years after EiF.