Document 76B20ngMX1KzgV2LwBbgjrB

European Chemicals Agency Telakkakatu 6, P.O. Box 400 FI-00121 Helsinki, Finland Austria, 2170 Poysdorf 01.06.2023 Regulation (EC) No. 1907/2006 (REACH) Proposal for a restriction of Per- and polyfluoroalkyl substances (PFASs) Dear Ladies and Gentlemen, We, GG Group, are a global group of companies. We have been producing technically high-quality cables, wires and harnesses for the automotive industry and various industrial sectors for more than 80 years. We focus on emobility, autonomous driving and digitalization, the most important drivers of innovation and development in our industry. Our success is based on providing high quality products, but also on our strong focus on everybody involved in this process. With more than 4000 employees at 11 locations worldwide, GG Group is one of Austria's most successful family owned industrial companies. This product portfolio permits us to process all types of thermoplastic and thermosetting plastics. In particular, fluoropolymers play a key role for safety-relevant products. Fluoropolymers are used as insulation in both the non-automotive and the automotive environment in the following cables: Cables for fault current circuit breakers (FCCB) Safety- and senorcables for e-mobility as well as for combustion engine cars Ignition cables for xenon headlights High-performance data cables Cables for clean environment (almost no VOC) Beside the product portfolio from GG there are a lot of essential cables where fluoropolymers are used as insulation: Aeropspace Medical devices Analytical devices Heating cables Chemical resistant cables Various cables for high temperature applications Cables for very low temperature (-200C) Cables for Oil and Gas Industry Gebauer & Griller Kabelwerke Gesellschaft m.b.H. Laaer Strafle 145 2170 Poysdorf Osterreich T: +43 2552 2840-0 F: +43 1 369 50 14-3212 gg-group.com gg-group.com UID: ATU 36769804 DVR: 0027472 EORI: ATEOS1000001058 Firmenbuch Nr.: FN 50725x Firmenbuchgericht: Handelsgericht Wien, Sitz Wien As GG Group not only producing the cable itself, but also does the assembling of the whole cable harness, fluoropolymers play an essential role for components for safety reasons.: Heat protection hoses Corrugated tubes Clips And many more... As fluoropolymers play an essential role for GG and for the whole cable and automotive industry, we as GG group want to give a statement regarding "Regulation (EC) No. 1907/2006 (REACH) Proposal for a restriction of Per- and polyfluoroalkyl substances (PFASs) Fluoropolymers (such es ETFE, FEP and PFA) are very expensive and difficult to work with (complex processing). Therefore, they are only used when no other alternatives are available. Fluoropolymers have an almost universal resistance to aggressive media, can withstand high mechanical and thermal load, show unreachable dielectric properties, have a very good flexibility and no other material can guarantee long term low emissions, as well as they are extreme durable. The fulfilment of the combination of these very challenging requirements makes Fluoropolymers indispensable. There are no materials on the market, neither known nor under development, which can fulfil the combination of high thermal resistance (-200 C), high flexibility, high mechanical resistance, and high chemical resistance (e.g., cables for RCCB switches and Heating cables for chemical tanks). The ban of fluoropolymers would lead to Europe not fulfilling its Green Deal goals, becoming dependent on lowwage countries against all efforts of localization and finally developing technologically backwards. This argumentation based on following circumstances: No production, import or reselling of products, which contains fluoropolymers (Mobile phones, electric devices for medicine applications, electric components for computers, chemical applications...) No production of products, which needs PFAS for their production, but not containing any PFAS in the final product 4 PFAS act as a detergent. This leads to an emigration of industry to non-Europe states, where PFAS as a detergent is allowed. Consequently, Europe is becoming heavily dependent on other continents and countries, which contradicts the EU's plan for localization. This leads on the one hand to a massive reduction in jobs and on the other hand to massive delivery difficulties as we saw during the corona pandemic. The new megatrends like green hydrogen, 5G data transmission or e-mobility, which are also part of the Green Deal, can neither be fulfilled nor improved without fluoropolymers, which leads to a technological disadvantage compared to the other continents Renewable energy such as photovoltaic panels, which is an essential part of the Green Deal will not be fulfilled, as Fluoropolymers are essential for the photovoltaics (reg. durability and efficiency). And many more... The restriction describes the ban on the manufacture and use of over 10,000 substances, including fluoropolymers such as ETFE, FEP and PFA and 35 other materials in this group, which are indispensable and irreplaceable due to their properties. The attempt of singular solution of individual environmental problems and the disregard /misunderstanding of the consequences of these decisions is openly shown with this general prohibition of use. Fluoropolymers should be exempted from all regulatory activities under the REACH restriction. Fluoropolymers can be classified as PFAS based on their molecular structure. However, their toxicological and eco-toxicological Gebauer & Griller Kabelwerke Gesellschaft m.b.H. Laaer Strafle 145 2170 Poysdorf Osterreich T: +43 2552 2840-0 F: +43 1 369 50 14-3212 gg-group.com gg-group.com UID: ATU 36769804 DVR: 0027472 EORI: ATEOS1000001058 Firmenbuch Nr.: FN 50725x Firmenbuchgericht: Handelsgericht Wien, Sitz Wien profile is essentially different from the majority of PFAS substances. Fluoropolymers that meet the OECD criteria of PLC ( = polymer of low concern) are non-toxic, non-bioavailable, non-water soluble and non-mobile molecules and are judged to have no significant impact on the environment and humans. Additionally, several case studies already proved recyclability of fluoropolymers, which also positively contributes to the EU-Green Deal. The stability of fluoropolymers can be directly translated into unique and durable performance properties in many applications. For the new megatrends such as green hydrogen, 5G data transmission or e-mobility, fluoropolymers represent the suitable basis on which these innovations become possible in the first place. We reject this undifferentiated approach of group regulation and urge the responsible government representatives in the Federal Republic of Austria and the European Union to exempt the fluoropolymers recognized by the OECD as safe materials ("PLC" = polymer of low concern) as well as the materials necessary for their production from PFAS regulation or use restrictions. Nevertheless, we support all efforts to provide fluoropolymers and their decomposition products with corresponding limit values that must be strictly adhered to during production and processing. Likewise, clear limit values regarding effects on the environment must be established and strictly complied with. The protection of the human live and the environment must have the highest priority, which does not contradict the use of fluoropolymers. We hope that the indispensable use of fluoropolymers, which in the sense of sustainability for products that positively affect the life and limb of humans, will be recognized and that fluoropolymers will be granted a full exception regarding the Regulation (EC) No. 1907/2006 (REACH) Proposal for a restriction of Per- and polyfluoroalkyl substances (PFASs). Best regards, Gebauer & Griller Kabelwerke GesmbH Gebauer & Griller Kabelwerke Gesellschaft m.b.H. Laaer Strafle 145 2170 Poysdorf Osterreich T: +43 2552 2840-0 F: +43 1 369 50 14-3212 gg-group.com gg-group.com UID: ATU 36769804 DVR: 0027472 EORI: ATEOS1000001058 Firmenbuch Nr.: FN 50725x Firmenbuchgericht: Handelsgericht Wien, Sitz Wien