Human Health Medicinal Products Sector Survey Impact of Proposed PFAS Restric=on on Pa=ent Access to Medicines & EU Strategic Autonomy Disclaimer: This document was prepared in good faith by represented associa6ons for the purposes of preparing the public consulta6on response to the PFAS Restric6on proposed under Title VIII of the REACH Regula6on.

IMPACT OF FIFLOW BB 61 ON REDNESS AND WHITENING FIFLOW products are fully fluorinated perfluorocarbons, which have a high capacity to carry gases, notably Oxygen, Nitrogen and Carbon Dioxide.

PFAS-consultation answer 1(13 Janne Kerttula ) 25.9.2023 Consequences of proposal for a restriction of PFAS for district heating and cooling and electricity sector Finnish Energy is a branch organisation for the industrial and labour market policy of the energy sector.

Briefing to Congress on Aqueous Film Forming Foam (AFFF) Replacements and Alternatives Performing the Duties of Assistant Secretary of Defense (Energy, Installations, and Environment) February 2022 The estimated cost of this report or study for the Department of Defense is approximately $3.650.

Remarks 4/26/2024 Universal PFAS restriction Overall Timeline and Important Milestones ECHA FFF restriction Scope Scope defined for RoI (exclusion WP2 and possible E-use 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.

Structure depictio PFBA PFHxA PFBS CAS NumbECNumberCode for soStructural Formular (N/A) (N/A) (N/A)|PFBS?

Regulation (EC) No. 1907/2006 (REACH) Proposal for a restriction of Per- and polyfluoroalkyl substances (PFASs) submitted by BAuA - Federal Institute for Occupational Safety and Health Bureau REACH, National Institute for Public Health and the Environment (RIVM) Swedish Chemicals Agency (KEMI) Norwegian Environment Agency The Danish Environmental Protection Agency Date: 07.02.2023 22 March 2023 Dear Sir or Madam, We welcome the opportunity to contribute to the public consultation initiated by the European Chemicals Agency regarding potential restriction of Per- and polyfluoroalkyl substances (PFASs) according to Regulation (EC) No. 1907/2006 ("REACH").

CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies PVDF and ECTFE used for sulphuric acid Description of sulphuric acid slightly yellow viscous liquid (oil of triviol) soluble in water at all concentrations Diprotic acid Corrosive due to its - strong acidic nature, - strong dehydrating property - strong oxidizing property (concentrated acid) CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies Resistance of PVDF against sulphuric acid Temperature [C] Maximal admissible concentration of H2SO4 23 96,3 50 93 100 85 120 80 150 70 (no pressure) Information based on chemical resistance tests of the raw material supplier CHEMICAL RESISTANCE AGAINST H2SO4 Chemical Resistance of PVDF against sulphuric acid resistance Brown discoloration Permeation Material properties H2SO4 Concentration Temperature Hoop stress V max Time at rupture H2O V max without rupture Effects of % C MPa hours MPa 97 10 54700 chemical media 96 50 18 37650 23 93 18 > 54900 * Resistance 96 1 8600 93 100 4 7900 12.5 against various 9800 6 > 9200 11 54530 media 93 120 3 296 9.5 80 9 > 17500 * Case studies 90 2 1825 80 150 5 > 1700 5.5 70 fCR = H2SO4 / H2O 4 > 30000 fCR 0.43 0.78 0.78 < 0.1 < 0.3 0.48 < 0.88 < 0.1 0.94 < 0.1 (0.91) 0.72 CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies Sulphuric acid - brown discoloration Test criteria: 200 h at 95C V=11,5 N/mm Stopped after 240 hours Burst pressure 20C; 0,08 bar/sec 98 bar CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies High concentrated sulphuric acid (concentration: >96,3%) SO3(g) + H2O(l) H2SO4(l) -H2O Sulfur trioxide (SO3) CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies Resistance of PVDF against sulphur trioxide, which is formed by sulphuric acid >96,3% Deshydrofluorination Permeation Increase in weight (>5%) Stress cracking corrosion Typical phenomenon if SO3 only is present in very small amounts Physical and chemical degradation ECTFE is resistant against sulphuric acid with a concentration >96,3% without any restrictions CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies Medium: Temperature: Medium: Temperature: sulphuric acid 98% 20C sulphuric acid 96% 20C - 30C CHEMICAL RESISTANCE AGAINST H2SO4 Chemical resistance Material properties Effects of chemical media Resistance against various media Case studies Medium: Temperatrure: sulphuric acid 98% 20C The solution ETHYLENCHLORTRIFLUORETHYLEN - ECTFE

High Heat Resistant Thermal Interface Material VMQ EPDM FKM Heat resistant Good Fair Excellent Fiiler additon Excellent Good Fair Volatility resistance Fair Fair Excellent

LOVAP NV - iaus-Michael Kuehnelaan 11 - 82440 GEEL Fax 01458 1706 infoBlovap.be wlovap be HARDICK BV For the attention of Mr.

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.

Alternatives listed in PFAS Annex E and reasons for non-replacement Application a) Sealing b) Wire insulation c) Immersion cooling Heat transfer fluid d) liquid crystal displays (LCD) PFAS Non-PFAS alternatives fluoroelastomers Ethylene propylene diene monomer (EPDM) silicone rubbers PTFE, PFA, ETFE, FEP, Silicone materials FEPM, PFPE Polyetheretherketone(PEEK) mica EPDM Polyvinyl chloride ceramic based polymer Hydrofluoroethers Fluorinated amines -CF3 group Mineral oils synthetic oils natural oils Hydrocarbon fluids Cyano (-CN) group Reasons why PFAS cannot be replaced by non-PFAS In sealing material applications (e.g. packing), heat resistance, solvent resistance and low gas permeability are important, and EPDM and silicone rubber provide low or medium durability but not enough property, so they cannot replace all applications and fluorinated materials must be used.