Document ze82GJEYqYRNBoJj4q9Na9N3

Agenda Tour de Table Introduction to 3M EU Policy Agenda: Green Deal & Chemicals Strategy for Sustainability 3M 2021. All Rights Reserved. 3M Confidential. 2 3M in Europe, Middle-East & Africa 3M located in 53 countries across 7 regions 21,000+ employees including 1,500 scientists, 5,800 customer-facing employees, and 11,100 workers in Manufacturing & Supply Chain 44 manufacturing sites and 20 Distribution Centers 3M 2021. All Rights Reserved. 3M Confidential. 4 Our 4 Business Areas for Government, Industry & Society Safety & Industrial Transportation & Electronics Health Care Consumer Personal safety Adhesives and tapes Abrasives Closure and masking Electrical markets Automotive aftermarket Industrial minerals Display materials Automotive and aerospace Electronics materials Commercial solutions Advanced materials Transportation safety Medical solutions Oral care Separation and purification sciences Health information systems Drug delivery Food safety Home improvement Stationery and office Home care Consumer health care 3M 2021. All Rights Reserved. 3M Confidential. 5 3M supports the EU Single Market & Green Deal: science based legislation to support innovation & jobs 3M is committed to promoting innovation, safe use of their products, sustainable manufacturing and stewardship across the industry. 3M advocates for a balanced regulatory environment based on scientific facts to ensure European industries remain competitive and sustainable. 3M & PFAS as a practical example: 3M manufactures, imports, uses, and supplies various PFAS and PFAS containing products for numerous, primarily industrial, applications. We produce in Zwijndrecht, Belgium & Gendorf, Germany (2 out of 44 sites). 3M participated to Calls for Evidence related to evaluating restriction options for PFAS. 3M 2021. All Rights Reserved. 3M Confidential. 9 Chemicals Strategy for Sustainability Need to maintain consistency between different Green Deal objectives. Keep the chemicals policy framework in Europe proportionate & science based. Maintain regulatory predictability for investments: the REACH regulation is a success story and is achieving its objectives. Let's preserve the established norms and framework. It takes time to implement agreed targets, and constantly `moving the goalposts' can be both costly and wasteful. It is critical that the re-opening of REACH & the Classification, Labelling and Packaging (CLP) Regulation remains "surgical". Let's build on what has been successfully achieved to date and not change the foundations. 3M 2021. All Rights Reserved. 3M Confidential. 10 Grouping of substances (Cefic position) Regardless of how grouping is used, Cefic believes it needs to be based on the following key principles: The grouping process should be transparent for all stakeholders; Grouping should consider risk and hazard profiles in addition to structural similarity; Similar family name or backbone should not be confused with similar hazard profile; Identification of substances in a group should be based on a unique substance ID to facilitate digitalisation; A proposed regulatory measure should be enforceable. It is critical that grouping is based on solid scientific standards and applied coherently across REACH independently of its purpose. 3M Company 2016. All Rights Reserved. 3M Confidential. 12 Design Considerations Applying ' essential use concept: Strengths Limitations Provides a potential framework for evaluating necessity Academic approach with limited implementation detail Suggests coordination with industry and governments via existing processes (ie. REACH socio-economic assessment) Seeks to restrict all `non-essential' uses, irrespective of availability of alternatives or other impacts on business and society Does not balance the benefits of the uses with the risks; trade-offs in product performance and safety are not central considerations The main challenge for implementing the concept is its subjectivity 3M has attempted to integrate some of these concepts in our chemical management 3M 2021. All Rights Reserved. 3M Confidential. 14 3M Considerations on Essential Use Concept Essential use definitions and tools for evaluation are encouraged to be grounded in existing governance and processes, such as the REACH principles. Key features for the integration of the concept in REACH should be: - Balance essentiality with specific risk assessments of the uses at stake and the principle of proportionality - Ensure a proper, robust analysis of alternatives - Adopt clear and transparent guidelines Essential use evaluations are multi-dimensional and should address considerations such as societal benefit, environmental stewardship and the availability of alternatives - Evaluation of alternatives should include the lifecycle assessment (LCA) to avoid regrettable substitutions Definitions should not be static and encourage future innovation or emergency situations (ie. learnings from COVID crisis) Avoid creating rigid tools and/or definitions in isolation - Balance of directive, yet intent-based guidance, that can be adaptable to the vast and diverse applications - Tools should not be a pass/fail, one-size-fits all Implementation issues need to be clarified and resolved with a broad coalition of support 15