Document zdxKMkjZJxzy0jqmgjER27oEB

"Exemption Application from PFAS Restrictions for Ionic Liquids" I. About CHORI CHORI CO., LTD. is a specialized trading company with a history of over 160 years, dealing in a wide range of businesses including textiles, chemicals, and non-ferrous metals. In particular, the chemical sector encompasses a broad business, including natural minerals, inorganic chemicals, organic chemicals, petrochemicals, pharmaceutical and agricultural intermediates, food additives, chemical fertilizers, and chemical feedstuffs. The annual revenue exceeds USD 2.2 billion, CHORI is one of Japan's leading companies [1]. CHORI also deals with ionic liquids. CHORI has been certified as the exclusive sales agent for Zhejiang Lande, which is the world's largest ionic liquid manufacturer. CHORI plays a leading international role in the ionic liquid world market. II. About Ionic Liquids Ionic liquids are a new type of liquid that maintains a liquid state under 100-degree Celsius specific conditions, and they are widely used in various industrial fields due to their unique properties [2]. Here's an overview of ionic liquids: Chemical Structure: Ionic liquids typically consist of combinations of cations (positively charged ions) and anions (negatively charged ions). The choice of cations and anions allows for the adjustment of the properties and characteristics of ionic liquids, making customization for various applications possible. Characteristics: Ionic liquids typically remain in a liquid state at room temperature and exhibit high thermal stability. They are non-volatile and have high boiling points, making them suitable for use under high vacuum or high-temperature conditions. They often possess excellent electrical conductivity, solubility, and chemical stability, making these properties valuable in various industrial fields. Applications: Ionic liquids find wide applications in various industries, including organic synthesis chemistry, catalysis, electrode materials, electrolytes, energy storage technologies, metal refining, gas absorption, green chemistry, analytical chemistry, and biological research, among others. Notably, they play a crucial role in the development of sustainable chemical processes and energy conversion technologies, such as battery electrolytes for electric vehicles (EVs), and are gaining attention as environmentally friendly alternatives. Research and Development: Research and development related to ionic liquids are advancing steadily, with ongoing efforts to synthesize new ionic liquids and improve their properties. This is expected to lead to new applications and industrial uses. Ionic liquids are drawing attention in fields such as chemistry, energy, the environment, and materials science due to their diverse properties and applications. Their potential value as a sustainable technology is highly regarded. III. PFAS-Relevant Substances in Ionic Liquids on EU issue bis (trifluoromethylsulfonyl) imide (Hereinafter abbreviated as TFSI) is one of the most famous anions in the world. TFSI as the anion are commercially available, and the following substances are examples. Please note that these are just examples, and the available substances are not limited to these. LDAM-102: Tributylmethylammonium bis(trifluoromethylsulfonyl)imide CAS NO.405514-94-5 LDIM212: 1-Ethyl-3-Methylimidazolium bis(trifluoromethylsulfonyl)imide CAS NO.174899-82-2 BMPTFSI: N-methyl, butyl pyrrolidinium bis(trifluoromethylsulfonyl)imide CAS NO.223437-11-4 PP14TFSI: N-methyl, butylpiperidinium bis(trifluoromethylsulfonyl)imide CAS NO.623580-02-9 LDPY405: (N-butylpyridinium bis(trifluoromethylsulfonyl)imide) CAS NO. 187863-42-9 LDPR423: (N-(2-Methoxyethyl)-N-methyl-pyrrolidinium bis(trifluoromethanesulfonyl)imide) CAS NO. 757240-24-7 The use of the above-mentioned substances is determined by a multitude of complex factors, including the applications and purposes of each end user, compatibility with other substances, among others. Therefore, there is potential for increased sales of any of these substances in the future. However, it's worth noting that in the EU, PFAS are defined as substances that contain one or more -CF3 or -CF2- groups within their molecular structure. As a result, TFSI anions are structurally classified as PFAS in the EU. That is a big problem. But for the following reasons, we doubt this decision. IV. Safety of TFSI anion EU is considering"one-size-fits-all" regulations for PFAS. However, there hasn't been sufficient research conducted on the potential harm of TFSI anions. For instance, while PFAS are a cause for concern due to their potential for long-term accumulation in the body and carcinogenic effects, as far as our research indicates, there haven't been experimental findings suggesting such harm from TFSI anions. As an example, there are reviews stating that no studies have confirmed the carcinogenicity of the most well-known TFSI salt, LiTFSI [3]. In light of this situation, it is believed that applying "one-size-fits-all" regulations to ionic liquids containing TFSI may be premature due to insufficient information [4]. V. The environmental impact of TFSI anion: Compared to common compounds like PFAS (per- and polyfluoroalkyl substances), TFSI anions are generally considered to have a lower environmental impact. VI. Alternative substances for TFSI anion Regarding the primary application of ionic liquids containing TFSI anions, which is as electrolyte additives for electric vehicles (EVs), research and development have been ongoing at research institutions worldwide since around 2000. However, as of September 2023, to the best of our knowledge, no alternative substances have been announced. VII. The social and economic losses & impacts resulting from the restriction of ionic liquids (with PFAS anions) The primary application, electric vehicles (EVs), represents an indispensable and crucial market for mitigating global warming and reducing CO2 emissions. Ionic liquids (with PFAS anions) play a significant role in enhancing the safety of EVs as electrolyte additives [5], [6]. The importance of safety in electric vehicles (EVs) can be explained as follows: High-Voltage Batteries: EVs utilize high-voltage lithium-ion batteries. These batteries are highly efficient and have a high energy density. However, this high voltage and stored energy pose increased risks in the event of accidents or failures. Therefore, the design, manufacturing, handling, and protection of these batteries are of utmost importance. Fire Risk: EV battery packs can potentially ignite when exposed to high temperatures, presenting a fire risk. In the event of battery damage or accidents, fires can jeopardize the safety of occupants. Consequently, battery pack designs must incorporate measures to mitigate fire risks. Several research papers have discussed how ionic liquids can address these issues effectively in EVs [7] ~ [9]. The global market for ionic liquids is expected to grow to 65,000 metric tons per year by 2024, reaching a market size of USD 2.5 billion. There is a concern that EVs that cannot utilize ionic liquids may compromise safety, potentially hindering their widespread adoption [10]. VIII. Conclusion Based on the explanations provided, it can be argued that at the current juncture, imposing PFAS restrictions on ionic liquids lacks rationality from a safety perspective and is far from acceptable definitely in the viewpoint of social and economic losses. Therefore, we strongly request a review and revision of PFAS restriction provisions to exclude ionic liquids from such regulations as soon as possible. Additionally, it should be noted that this viewpoint is not limited to our company alone, but it is also the opinion of Zhejiang Lande, a global manufacturer of ionic liquids. IX. Reference: [1] https://www.chori.co.jp/english/company/pdf/Corporate_Profile_EN_View202307.pdf [2] https://chemicals.basf.com/global/en/Intermediates/Product_groups/Ionic_liquids.html [3] https://cfpub.epa.gov/si/si_public_record_Report.cfm?dirEntryId=358288&Lab=CPHEA [4] https://pubs.acs.org/doi/10.1021/acs.chemrev.7b00246 [5] https://www.fortunebusinessinsights.com/industry-reports/electric-vehicle-market-101678 [6] https://www.iea.org/news/global-electric-car-sales-have-continued-their-strong-growth-in-2022-after-breakingrecords-last-year [7] https://www.sciencedirect.com/science/article/abs/pii/S2589778022000070 [8] https://pubs.rsc.org/en/content/articlelanding/2021/ee/d0ee04002a [9] https://www.researchgate.net/publication/340713918_Ionic_Liquid-Based_Electrolytes_for_Energy_ Storage_Devices_A_Brief_Review_on_Their_Limits_and_Applications [10] https://zhuanlan.zhihu.com/p/652672090