Europaudvalget 2022-23 (2. samling)
EUU Alm.del
Offentligt
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Date: 26/08/2021
Kind attention:
Mr. Martijn Beekman - Netherlands
Dr. Mandy Lokaj - Germany
Mrs. Jenny Ivarsson - Sweden
Mr. Toke Winther - Denmark
Mr. Audun Heggelund - Norway
Mr. Mark Blainey - ECHA
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
[email protected]
Through:
Pro-K Industrieverband Halbzeuge und Konsumprodukte aus Kunststoff e.V. (pro-K), Städelstr. 10,
60596, Frankfurt am Main, Germany
The members of pro-K 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 (RoI) dated 15
th
July 2021
Dear Sir/Madam,
With regards to Registry of Intention (RoI) 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
th
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
th
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 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
 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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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 Lithium-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 of fluoropolymers would adversely impact implementation of these technologies crucial for
planet’s future
as well as in all existing applications vital for the 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 of fluoropolymers
from the PFAS restriction proposal.
Fluoropolymers processed by us:
roughly 1600 tons of polymers…………………………………………………………………
Service application industries:
Automotive, aerospace, industries, oil&gasket, food, fashion……………..…………………………………………………………
Sincerely yours,
Name and signature
Alessandro Mannara
……………………………………………………………………………………………………
Company name and address
PMG Spa via Europa 3 Cenate Sotto Bergamo Italy
………………………………………………………………………………