Document zd1QBRy4DNwj13zL72zGQYM8R
EEB's initial position
Substance
referred in
No.
KEI candidates
sources (acronyms of
EIPPCB proposal
Substance considered as KEI (y/p/n)
sources from
section 3.2)
Call for
initial positions
PFCs (as listed BE, EEB, FR,
45
in Annex III ZDHC, POPs
yes
BP)
Comment #
C
MS / Comment Organisati overall
Extent of the
on
number
comment
EEB
361 92
Selected Text 4
Comment s to D1
Comment s to D1
39
Selected Text 4
EEB
364
144
Selected Text 1
Comment .
EEB
Comment from
(Organisat ion / MS)
21
Section
BAT No.
BAT section
Reference
WG's feedback before Final Meeting
WG's feedback before Final Meeting
EEB
9
Mo5n.i1to.2ring BAT 7
Technique
EEB's initial position
Please provide the rationale for
Typical monitoring/mea
your opinion. Can additional information be provided? If already
surements
available please upload it on BATIS frequency in the
and provide the filename of the
permits (continuous/
attached file below.
discontinuos)
Units used to express ELV (e.g. mg/m3,
mg/l, g/kg,... )
Typical
monitoring/mea surement
averaging in the permits
(half-hourly, hourly, daily, mothly, yearly,
other)
We would like these substances to be blacklisted in the revised TXT
BREF, as this is already established practice from the industry that
signed up to ZDHC. If not mistaken the new COM approach requires
this issue" to be considered as KE"I even if we agree that negative BAT can be stated without need for data
collection.
Negative BAT statement i.e. "BAT is not to
use the
substance group x, y, z..."
Chapter No. / Section No.
7
5
1
0
0
0
7
5
1
0
0
0
4
0
0
0
0
0
Reference
Technique letter
(e.g. (a), (b), ..)
Table No.
Parameter
(e.g. Dust,
NOx, ..)
Topic
Comme Propos nt al for
descrip modific
tion ation
PFAS
General comment about EN standards
The EIPPCB likely forgot to change
the informati on on the testing standard.
Replace "no EN standard
available" by "ISO 21675".
Chapter title
Page #
Polluta
nt /
BAT
parame ter
BAT (if techniq relevant ue (if
concer
)
relevant
ned (for monitor
) ing and
BATAEL)
Selecte d
informa tion
subject to the comme
nt
Major/ Minor comme
nt
Comme nt
descrip tion
Propos al for modific ation
Rationa le /
support ing data
linear
PFAS are
C6 or C4
or
Clarify if monomer
data is s to make
up-to- per- and
date. Add polyfluori
sentence: nated
"Current polymers.
REACH _x000D_
registratio It follows
ns include from this
C4 and C6 that data
products, not on C4
as C8 or C6 is
products unlikely
were to be
largely current
replaced data. This
years ago. said,
C8-based consump
polymers tion data
not based for C6-
on PFOA derived
Table
and
products
4.79:
imported are
into the probably
Consump
EU at a similar to
tion of
commerci those for
energy,
al scale C8; for C4
water and
require higher
resources
REACH dosages
for
Data are registratio are
treating
possibly n of their reportedl
90 m2 of
out of monomer y
690
textile Major date. s."
required.
691
The
Minor Comment Please Currently,
purchasin
also holds provide no
g cost of
for
clarity on "proper"
dendrimer
following the
C8-based
is lower
paragraph questions chemicals
than
on
in the are
fluorinate
silicone- rationale. registered
d
based
under
treatment
treatment.
REACH,
s: 27 %
_x000D_
so it is
cost
The
difficult to
decrease
purchasin
understan
compared
g and
d what a
to PFC C8-based
treatment cost data
C8-based dendrimer
product
are very
(itself a
and 49%
valuable
polymer)
cost
informatio
would be
decrease
n. We
made
compared
request
from,
to PFC
only some
except if it
C6-based
clarificatio
is
product.
n on C6
imported.
and
Or does
C8. _x000
this refer
D_
to some
_x000D_
older data
_x000D_
from the
days
when the
conversio
n from C8
to C6 was
made? _x
000D_
The C6
products
16
Rationa le /
support ing data
PFOAS Minor
Wrong abbreviati
on and technicall y imprecise formulatio n.
Replace "PFOAS"
by "PFOA" and add "and its derivative s" after the bracket.
PFOA is the
correct abbreviati on. _x000 D_ PFOA would anyway not be used as a
waterrepellent, but rather its derivative
s including polymeric ones. These are also restricted under REACH.
ISO 25101 only covers PFOS and PFOA, of which no
compoun ds are registered under Reach, meaning that any use at an industrial
scale in the EU would be illegal. Any measure ment performe
d using ISO 21675 would anyway cover those substance s as well. Another
useful feature of ISO 21675 is that it is not