Document zZqkVqapa3YYa2KY5qEGy01a

PFAS PUBLIC CONSULTATION: OVERVIEW BRIEFS SUBMITTED BY EUPC Brussels, 25 September 2023 EuPC is the leading EU-level Trade Association, based in Brussels, representing European Plastics Converters. EuPC now totals about 51European Plastics Converting national and European industry associations, it represents close to 50,000 companies, producing over 50 million tonnes of plastic products every year. The European plastics industry makes a significant contribution to the welfare in Europe by enabling innovation, creating quality of life to citizens and facilitating resource efficiency and climate protection. More than 1.6 million people are working in about 50,000 companies (mainly small and medium-sized companies in the converting sector) to create a turnover in excess of 280 billion per year. Introduction and general comment Following our initial submission, EuPC comments on specific applications. Since those are very diverse, each application is covered in a separate submission. This document gives an overview on the submitted briefs. Fluoropolymers should be excluded from the scope of the restriction Based on the non-toxic properties described in the briefs, fluoropolymers should in our view be excluded from the scope of this restriction. We however provide additional information showing both its negligible emission and the disproportionate socio-economic impact that would be linked to its substitution. Derogation for uses solely in industrial settings Substances used solely in industrial settings should be derogated with appropriate risk management measures at manufacturing plant level if appropriate. Inclusion of a review clause In case fluoropolymers would not be derogated, the adequate transition periods should be granted. In addition to that, the restriction should include a review clause and process whereby it may be evaluated whether or not the alternatives could be successfully placed on the market potentially allowing if needed extension of those transition periods. Contact: @eupc.org; @eupc.org Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 41 24 Fax: +32 (0)2 732 42 18 @eupc.org www.plasticsconverters.eu Page 1 of 5 PFAS PUBLIC CONSULTATION: OVERVIEW BRIEFS SUBMITTED BY EUPC Summary of submitted briefs of all sectors SECTOR & REFERENCE TO SUBMISSION APPLICATIONS FOOD CONTACT MATERIALS AND PACKAGING Additives for thin PP and PE films PFAS USED SOCIO-ECONOMIC IMPACT PVDF HFP; HFP/VDF/TFE Polymer; PTFE; PE-TFE Up to 2,75 million T film impacted: 150 bn Substitution costs: 1 bn Waxes, greases and sprays; Printing inks Grease-proof paper PTFE; 3,3,4,4,5,5,6,6,7,7,8,8,8Tridecafluorooctane-1-sulphonic acid; Poly[trifluoropropyl(methyl)siloxane] Perfluoroalkylethyl acrylate(mixture); Diphosphoric acid, polymers with ethoxylated reduced methyl esters of reduced polymerized oxidized tetrafluoroethylene; 2-Propenoic acid, 2-methyl-, polymer with 2-hydroxyethyl 2- methyl-2-propenoate, a-(1-oxo-2-propen-1-yl)- w-hydroxypoly(oxy-1,2-ethanediyl) and 3,3,4,4,5,5,6,6,7,7,8,8,8-tridecafluorooctyl 2- propenoate, sodium salt Potential presence of short chain and C6 based PFAs REQUESTED TRANSITION PERIOD 6.5 years after Entry into Force for virgin material Articles containing recyclate: Subsequent gradual reduction of FP content in film for a period of +6 years (therefore 6.5 + 6 years = 12.5 years) 6.5 years after Entry into Force Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 4124 Fax: +32 (0)2 732 42 18 El@eupc.org www.plasticsconverters.eu Page 2 of 5 PFAS PUBLIC CONSULTATION: OVERVIEW BRIEFS SUBMITTED BY EUPC SECTOR & REFERENCE TO SUBMISSION FOOD CONTACT MATERIALS AND PACKAGING APPLICATIONS PFAS USED Caps and closure for heat and PFTE; FKM; EFTE; PVDF; PFA chemical resistant packaging AUTOMOTIVE & TRANSPORT Plastic fuel systems (i.a. seals, FKM; FVMQ; ETFE; PTFE; FEP; THV joints, gaskets) MEDICAL DEVICES, VETERINARY MEDICINE, RESEARCH AND LIFE SCIENCE MEDICAL PACKAGING Medical devices: Drug Powder Inhalers, Pen Injectors, Process fluid connectors PCTA Catheters Research & Life science: Labware (i.a. Spatulas, Fittings, Containers, Parts of HPLC system) PE/EVOH/PE films for pharmaceutical and veterinary applications Pharmaceutical blister packaging PTFE; PFPE; FEP PTFE, FEP PTFE; PFA HFP; VDF PCTFE SOCIO-ECONOMIC IMPACT REQUESTED TRANSITION PERIOD 12 years after Entry into Force 1 bn All gasoline powered fuel systems in EU concerned 13.5 years after Entry into Force 13.5 years after Entry into Force 20 years 13.5 years after Entry into Force 13.5 years after Entry into Force Requalification costs: 2 bn 13.5 years after Entry into Force Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 4124 Fax: +32 (0)2 732 42 18 El@eupc.org www.plasticsconverters.eu Page 3 of 5 PFAS PUBLIC CONSULTATION: OVERVIEW BRIEFS SUBMITTED BY EUPC SECTOR & REFERENCE TO SUBMISSION APPLICATIONS PFAS USED PLASTIC SHAPES FOR MACHINING Engineering polymer shapes for machining: automotive/chemical industries/food contact/packaging/medical/ electronica and semiconductors/parts in machines PTFE, PVDF, PFA Lubricant or coatings of tooling systems PTFE PLASTIC COMPOUNDS AND MASTERBATCH ES High performance thermoplastic compounds for injection moulding articles of small dimensions PTFE Non-dripping agent in combination with flame retardants PTFE Additive for polyolefin film extrusion PVDFHFP; HFP/VDF/TFE Polymer OTHER SECTORS Plastic pipe systems and fittings PTFE; FKM; FFKM; PVDF; ECTFE SOCIO-ECONOMIC IMPACT REQUESTED TRANSITION PERIOD R&D costs: 15 Mio. for whole sector 13.5 years after Entry into Force 13.5 years after Entry into Force Minimum 10 years 3 years Please refer to submission on FCM & Packaging Time-unlimited derogation Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 4124 Fax: +32 (0)2 732 42 18 M@eupc.org www.plasticsconverters.eu Page 4 of 5 PFAS PUBLIC CONSULTATION: OVERVIEW BRIEFS SUBMITTED BY EUPC SECTOR & REFERENCE TO SUBMISSION OTHER SECTORS APPLICATIONS Lamination foils for window profiles and faades PFAS USED PVDF Artificial leather upholstery PVDF Semiconductors manufacture PVDF, PTFE SOCIO-ECONOMIC IMPACT REQUESTED TRANSITION PERIOD Avenue de Cortenbergh 71- B-1000 Brussels Phone: +32 (0)2 732 4124 Fax: +32 (0)2 732 42 18 El@eupc.org www.plasticsconverters.eu Page 5 of 5