AR226-2757 E.

Response Opinion for PFAS Proposal On behalf of Beijing Qingchi Technology Co., Ltd., we would like to exp greetings to the five countries proposing the ECHA and PFAS m control protocol.

PFAS derogations requests for spare parts and pre-owned products We represent over 45,000 businesses across Europe The voice of digitally transforming industries platform services data analytics software & hardware cybersecurity telecoms semiconductors cloud technology Healthcare Manufacturing Finance Buildings Mobility 41 NATIONAL ASSOCIATIONS 100 COMPANIES 60+ Categories of uses identified in electronics* Application area Coatings Printed circuit boards High voltage/power applications Cables and connectors Components Mechanical applications Displays Batteries Fire prevention Heat transfer Chemical equipment Chemicals Others *Excluding semiconductors, energy, medical, automotive, aerospace Details Capacitors, dielectric films Electret films in microphones, sensors Gaskets, sealing Microphone/speaker vent membrane Piezo in acoustical equipment Rubber parts in image forming process in printers Annex XV report on electronics 1 Apart from proposed 12-year derogation for the semiconductor manufacturing process, no derogations for the electronics sector No computing / communications products will meet 18 months transition period Huge economic impact, business closures 2 No derogation for spare parts of existing products No spare parts can be made available despite the requirement to do so under the EU Ecodesign directive/regulation As is, restriction will lead to premature obsolescence of products on the market 3 No derogation for refurbished or second-hand products / articles already on the market Use and emissions from electronics are less than 1% of the total PFAS use and emission Derogation needed | Spare parts to repair consumer electronic products 7 years derogation needed to avoid premature obsolescence of existing consumer electronic products Impractical to design, qualify & produce PFAS-free spare parts for consumer products manufactured before PFAS restriction Precedents in other REACH substance restrictions REACH restriction 68 on C9-C14 PFCAs (belong to PFAS family) Compliance with other EU legislation EcoDesign regulation mandates spare parts for electronic displays until at least 7 years after placing the last unit on the market Guarantee obligations in proposed Right to Repair Directive Impact of no exemption 77% of EU prefer to repair a consumer product than buy new one 30% of EU have repaired a product within past six months EU consumer electronics repair sector employs 104,000 people and generates 14.5 billion Euros revenues Derogation needed | Spare parts to repair professional B2B products 15 years derogation needed to avoid premature obsolescence of existing professional b2b electronic products Additional considerations apply for equipment with long lifetimes (e.g. telecommunication networks, industrial HVAC, industrial printing,...) lifetimes and contracted maintenance periods usually extends to 10 to 15 years in the product's first application (up to 25 years in some cases) The availability of spare parts is essential to realize the lifetime potential of such products In many cases spare parts for professional users have already been manufactured and are commercially available for customers at short notice, which is often contracted No drop-in replacements (especially for fluoropolymers) PFAS-free spare parts are not drop-in alternatives as dimensional changes from alternative materials generally necessitate product re-design For products that are no longer commercially available it is unrealistic to design PFAS-free spare parts Extended `repair as produced' provisions in EU legislation RoHS Directive Art. 4(4) + 4(5) provide that restrictions do not apply to spare parts for products that were placed on the market before an exemption expired, or spare parts recovered from products placed on the market before restrictions applied Derogation needed | Re-supply of pre-owned products Impractical to expect products manufactured before PFAS restriction to comply Without an exemption, resale of pre-owned products will be banned Functional products would be discarded as waste No additional PFAS emissions (products already on market) Normal practice in EU regulations and directives REACH restrictions 68, 51, 45, 20, 19, 18a, etc Persistent Organic Pollutants (POPs) Regulation All CE Marking directives and regulations Compliance with ESPR Requires products to be easier to refurbish and reuse products Impact of no exemption No EU second-hand car sales (20% of components contain PFAS) Global support from 25 leading industry associations around the world Questions for discussion 7 years derogation for spare parts to repair consumer electronic products What additional information is needed to substantiate this derogation?

ETFE PFAS Request the ETFE product exemption in the PFAS draft :ETFE, CAS NO.:65324-12-1 Product name: ETFE, CAS NO.: 65324-12-1 : Submitter: Wang Yafeng, Zhejiang Chengbao Wire and Cable Co., LTD :2023 8 23 Date: August 23,2023 ETFE, CAS NO.:65324-12-1 We apply for the exclusion of the substances mentioned from the PFAS ban.

Vi 4 iton Fluoroelastomers Specifying the Right Materials of Construction for Nonmetallic Flue Duct Expansion Joints -------------- Technical Information OPtahrefrorNmaannfcievoCrainpaatbeiditHeysdroofcFalruboornoEsllaassttoomemrasvrss.

Socio-economic assessment of the US Fluoropolymer Industry Final report Wood Environment & Infrastructure Solutions UK Limited - February 2020 @ nem sasoina wood.

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.

AR226-2997 STUDY TITLE: CHROMOSOME ABERRATION ASSAY IN CHINESE HAMSTER V79 CELLS IN VITRO REPORT DATA REQUIREMENTS: OECD Guideline 473 EEC Directive 92/69 EPA 40 CFR Ch. 1 (7-1-86 ed. 798.5385) AUTHOR: Dr.

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.

AR226-3017 Study Titir Skin Irritation Test vith H-21095 in Rabbits Laboratory Project ID Baskell Laboratory Report Mo. 311-95 Author M.

Comment on Proposed Restriction of PFAS Aug 24, 2023 Japan Valve Manufactures' Association (JVMA) Japan Valve Manufacturers Association (JVMA) appreciates the opportunity to provide comments to the PFAS restriction proposal. 1.

References to SSNC's response to the universal PFAS restriction public consultation Awad, R., Johann Bolinius, D., Strandberg, J., Yang, J.

AR226-3138 TRADE SECRET Study Title H-24256: Eye Irritation Test in Rabbits Laboratory Project ID: DuPont-3615 AUTHOR: Deborah A.

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.

Call for comments for the Stockholm Convention on the revised draft Risk Profile for chlorpyrifos and the draft Risk Management Evaluations for MCCPs and long-chain PFCAs - AGC Chemicals Europe Ltd response Please use this space to provide any comments on document 3 (draft RME on Long-chain PFCAs).