Europaudvalget 2022-23 (2. samling)
EUU Alm.del
Offentligt
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engineering plastics
mcp
Unit 27 Kingstons Commercial Centre
Downhall Road
Matching Green
Essex
CM17 ORB
Phone: 01279 739399
Fax: 01279 730919
Email: [email protected]
Date: 15'^ September 2021
Kind attention:
Mr. Martijn Beekman - Netherlands
Dr. Mandy Lokaj - Germany
restrictiePFAS(a)rivm.nl
[email protected]
Mrs. Jenny Ivarsson - Sweden [email protected]
Mr. Toke Winther - Denmark [email protected]
Mr. Audun Heggelund - Norway [email protected]
Mr. Mark Blainey - ECHA
[email protected]
Through:fluorseals S.p.A - Via Triboiina, 20/22 - 24064 Grumello del Monte(BG)- Italy
The members offluorseals S.p.A mainly focus on processing of Fluoropolymers, part manufacturing
and its applications, the involvement of downstream users in PFAS process.
Subject: PFAS restriction proposal & request for exemption of FLUOROPOLYMERS
Reference: PFAS - Registry of restriction intentions until outcome (Rol) dated 15'^ July 2021
Dear Sir/Madam,
With regards to Registry of Intention (Rol)filed by 4 EU Member States(Germany,the Netherlands,
Sweden, and Denmark) & Norway for the restriction of PFAS, we, a member of fluoropolymer
downstream user industry, hereby, would like to share some salient facts related to the importance
of fluoropolymers, critical functionalities, performance and benefits of its applications to society,
while acknowledging concerns regarding PFAS emissions related to the use of fluoropolymers and
their end of life.
Registry of Intention for PFAS restriction was announced by ECHA on 15'^ July 2021, to prepare a
restriction proposal for PFAS. Fluoropolymers are also included in the scope. The restriction proposal
is intended to be submitted to ECHA by 15'^ July 2022.
Fluoropolymers are a distinct subset of PFAS and are inherently safe, non-mobile, non-bio
accumulative and non-toxic. Fluoropolymers are different from other PFAS as they do not share the
Company Registration Number: 4115504
 EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren
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toxicological and environmental profiles associated with PFAS of concern. Fluoropolymers have
unique set of physicochemical properties,they meet OECD polymer of low concern criteria, and are
considered to have insignificant environmental and human health impact.
Fluoropolymers ensure safety, reliability, durability and critical performance In numerous
technologies, industrial processes and everyday applications that are important for human health,
safety, and the environment. With a unique combination of functionalities, fluoropolymers are
irreplaceable across many key sectors/applications. Alternatives to fluoropolymers, if exist, escalate
safety risks, carbon footprint, technology regression, and do not match the advanced performance
of fluoropolymers. Most importantly, restriction on fluoropolymers will make EU industry lose its
technological superiority over other economies and could put Europe's climate and energy goals at
risk. Overall,fluoropolymers contribute heavily to Europe's socio-economic status and are critical for
the betterment of the society.
The fluoropolymer downstream user industry acknowledges the concerns regarding PFAS emissions
due to the use of fluoropolymers and end of life processes. We wish to assure the authorities and EU
Member States that, we are implementing Best Available Technologies to ensure reduction in PFAS
emissions in a systematic way and eventually eliminating them to achieve EU's sustainability goals.
Parallelly, we are consciously working on recyclability and reusability to meet circular economy goal.
Fluoropolymers play an important role in achieving EU Green Deal objectives and UN Sustainable
Development Goals(UN SDG) because of their vital use In LIthlum-ion batteries. Green hydrogen.
Fuel Cell, Solar and Wind energy. No new-age technologies are possible without the use of
fluoropolymers. Restriction on the use offluoropolymers would adversely impact implementation of
these technologies crucial for planet's future as well as in all existing applications vital forthe society.
Considering the benefits of fluoropolymer applications to environment and society, low PFAS
emissions and initiatives being taken by the processing industry to further minimize emissions and
closing the loop by implementing circular economy wherever possible, we request for a complete
exemption offluoropolymers from the PFAS restriction proposal.
Fluoropolymers processed by us: PTFE, PFA, FEP, PCTFE, PEEK
Service application industries:
Fluid Control, Medical, Chemical Process, Seals & Gaskets
Sincerely yours.
Paul J. Lee
Director
Company Registration Number: 411S504