September 22, 2023 Supporting comment to K.Walter's submission as part of the consultation regarding the Per- and polyfluoroalkyl substance (PFAS) restriction proposal To whom it may concern, The European Rotogravure Association (ERA), founded in 1956, has developed into the leading international. organisation of the gravure industry.

SOCIOECONOMIC ANALYSIS AND ANALYSIS OF ALTERNATIVES of the potential restriction of the per and polyfluoroalkyl substances (PFAS) used in the manufacturing of razor blades for shaving SUBSTANCE: Per and polyfluoroalkyl substances (PFAS) FROM: Razor Blades Manufacturers USE: In Manufacturing of Razor Blades for Shaving DATE: 21 September 2023 PREPARED BY: EPPA SA/NV Place du Luxembourg 2 1050 Brussels, Belgium EU transparency register: 3136750124992 SOCIO-ECONOMIC ANALYSIS AND ANALYSIS OF ALTERNATIVES of the potential restriction of the per- and polyfluoroalkyl substances (PFAS) used in the manufacturing of razor blades for shaving PROJECT TITLE: Socioeconomic analysis and analysis of alternatives of the potential restriction of the per and polyfluoroalkyl substances (PFAS) used in manufacturing of razor blades for shaving VERSION: 21 September 2023 PREPARED FOR: Razor Blades Manufacturers PERFORMED BY: www.eppa.com CITATION: EPPA, SocioEconomic Analysis and Analysis of Alternatives of the impacts of a potential restriction of perand polyfluoroalkyl substances (PFAS) used in the manufacturing of razor blades for shaving, Report for Razor Blades Manufacturers, September 2023 DISCLAIMER: The views expressed in this report are, unless otherwise stated, those of the authors and do not necessarily represent any official view of Razor Blades Manufacturers and/or any other organization mentioned in this report. 1 CONFIDENTIAL EPPA sa/nv Contents ABBREVIATIONS 4 1.

HONEYWELL GmbH Strahlenbergerstrasse 110-112 63067 Offenbach, Germany www.honeywell.com Brussels, 21 September 2023 PFAS REACH Annex XV Restriction Report 1ST Public Consultation (22 March - 25 September 2023) Request for exclusion or derogation of certain fluorinated materials used in commercial building controllers and security devices/applications from the PFAS REACH restriction Proposal.

Executive Summary The European Chemicals Agency (ECHA) is currently discussing the restriction of per- and polyfluoroalkyl (PFAS) substances.

ENTSOE identifies gaps and proposes a differentiated approach to PFAS restriction in electrical equipment Board approval| 14 September 2023 From: RDIC, SDC and PCG ENTSOE Mission Statement Who we are ENTSOE, the European Network of Transmission System Operators for Electricity, is the association for the cooperation of the European transmission system operators (TSOs).

ECHA Committee 22th of September 2023 Topic: Statement by Leclanch to PFAS-free Electrode Manufacturing In response to the PFAS restriction proposal: PFAS in the Battery Industry Today, PFAS are used prominently in lithiumion battery cell production, particularly as a binder in the electrode manufacturing process, combined with toxic solvents such as NMP, which is stateofthe art in cathode manufacturing.

HONEYWELL ADVANCED LIMITED Riverview House Harvey's quay Apartments Limerick V94R3DE Ireland 22 September 2023 PFAS REACH Annex XV Restriction Report 1ST Public Consultation (22 March - 25 September 2023) Exclusion or time-unlimited derogation of HFO-1234ze(E) propellants in technical aerosols applications from PFAS REACH restriction proposal.

HONEYWELL ADVANCED LIMITED RIVERVIEW HOUSE HARVEY'S QUAY APARTMENTS LIMERICK V94R3DE IRELAND Annex III - Hydrocarbon Refrigerants in RACHP Systems Casualties (selected incidents) Hydrocarbon Refrigerant Casualties There is no systematic monitoring of accidents due to thermodynamic systems charged with exploding hydrocarbon refrigerants (propane, butane, isobutane, methane, propylene - also so-called "natural refrigerants"), installed in- or outside buildings (refrigeration, deep freezer, fridge, cold room, heat pump, dryer, air conditioner, etc.).

Generation Wind Power PFAS containing technologies for the EU path to a climate neutral society based on the European Green Deal Distribution Final Use Transmission & Distribution Equipment Grid Access H2-Production E-Mobility Industry Buildings Juli 2023 Pumps Electrical Contacts Semiconductors Cross-sectional Technologies Electric Drives Electric Energy Storage Fuel Cell Heat Pump Wind Power (onshore/offshore) Grid Access Products: Wind turbine Relevant for: Renewable energy production Function of product: Production of electrical power by using natural wind PFAS substance used: PTFE (lubricant) PFAS containing material / component: taping foil moulds as release agent in production; sealing rings, gliding pads, lubricants, li-battery Reason for use: separates rotor blades from mould during production, smooth kinematic motions, self sustainable turbines application Lifetime of product: about 20 years Lifetime of PFAS used: depending on application Products: HV Power Converter Relevant for: Enabling grid access to connect renewable offshore power generation to the grid over longer distances Function of product: conversion of electric power from high voltage alternating current (AC) to high-voltage direct current (HVDC) for long distant power connections PFAS substance used: PVDF PFAS containing material / component: Cooling pipes (oil system) Reason for use: extrem heat- and high (aggressive) chemical resistance insulation ability, low water absorption and fire retarding ability Lifetime of product: 30 - 40 years Lifetime of PFAS used: designed for product lifetime, can be easily separated for disposal Transmission & Distribution Equipment Products: HV/MV switchgear; instrument transformer; Coils; Distribution and Power Transformer Relevant for: grid stability and security (risk prevention) - power overload protection for overhead and distribution lines; metering, protection and control of the high/medium voltage power system; power transformation Function of product: electrical switching in power T&D lines for industrial and commercial use, protection and controlling power loads; voltage or phase conversion HV to LV, electrical isolation, voltage measurement and monitoring in T&D lines PFAS substance used: solids: PTFE, PVDF, PFPE lubricants: PTFE, insulating gases PFAS containing material / component: cooling pipes, seals; sliding ring, switching nozzle Reason for use: extreme heat-, flame- and high (aggressive) chemical resistance, low electric conductivity, dielectric insulation, low water absorption, ablation of PTFE for cooling purpose - prerequisite for arc switching, reduction of friction within kinematic chain, surface protection Lifetime of product: 30 - 40 years Lifetime of PFAS used: Designed for product lifetime Electric Energy Storage Products: Lithium-Ion Batteries Relevant for: Energy storage, electric mobility, ICT (information and communications technology), medical devices, tracking, smart metering, security devices Function of product: Storage and supply of electrical energy with low energy loss, high charging speed and energy density PFAS substance used: PTFE, PVDF PFAS containing material / component: low-molecular PFAS in electrolyte , binders in the cathode of lithium batteries Reason for use: intermediate electrical energy storage with minor losses and high charging cycles Lifetime of product: Up to 20 years Lifetime of PFAS used: designed for product lifetime Hydrogen Production Energy Storage Products: Electrolyzer Relevant for: renewable energy - production of green hydrogen by electrochemical splitting of water Function of product: electrochemical conversion of (green) electrical energy into chemical energy (hydrogen as an energy carrier).

4/26/2024 WP responsible for keeping deadline WP that need to deliver Universal PFAS restriction Overall Timeline and Important Milestones ECHA FFF restriction Scope Scope defined for RoI (exclusion WP2 and possible E-use WPW7P) 2 and WP7 Scope defined for Annex XV report (ongoing assessments can still lead to changes in scope i.e. substances/substance groups to be excluded, uses to be derogated etc.) 2nd round CfE Call for Evidence for specific information (15.

Submission to the ACLM, OSA and Euromcontact from the Hospital Optometrists Committee The Hospital Optometrists Committee (HOC) would like to raise its concerns with regards to the EU's current proposal to ban a large number of chemicals which contain the element fluorine.

Comment on Proposed Restriction of PFAS Aug 25, 2023 Japan Valve Manufactures' Association (JVMA) Japan Valve Manufacturers Association (JVMA) appreciates the opportunity to provide comments to the PFAS restriction proposal. 1.

Comment on Proposed Restriction of PFAS Jul 31, 2023 Japan Valve Manufacturers' Association (JVMA) Japan Valve Manufacturers Association (JVMA) appreciates the opportunity to provide comments to the PFAS restriction proposal. 1.

Apr 25, 2023 Comment on Proposed Restriction of PFAS Conference of Fluoro-Chemical Product Japan (FCJ) On behalf of chemical manufacturers, we, Conference of Fluoro-Chemical Product Japan (FCJ), have been working tirelessly to comply with national chemical regulations.

PFOS and PFOA Conversion to Short-Chain PFAS-Containing Materials Used in Semiconductor Manufacturing Semiconductor PFAS Consortium Photolithography Working Group June 5, 2023 Acknowledgments: The PFAS Consortium would like to acknowledge the contributions of the Semiconductor PFAS Consortium Photolithography Technical Working Group for their efforts to compile this information.