Document 7Gjx8jYK9XpGM8zqbjXrk3Dj

TRP Date: 17.09.2021 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 rivm.nl IME@baua.bund.de @kemi.se Ml@mst.dk @miljodir.no IMeecha.europa.eu Through: Pro-K Industrieverband Halbzeuge and Konsumprodukte aus Kunststoff e.V. (pro-K), Stadelstr. 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 (Rol) dated 15th 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 15th 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 15th 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 environment. With a unique combination of functionalities, fluoropolymers are TRP SEALING SYSTEMS LTD 24 NETHERWOOD ROAD ROTHERWAS INDUSTRIAL ESTATE HEREFORD HR2 6JU Tel: UK (0)1432-279366 Fax: UK (0)1432-273017 DIRECTORS S J CHILDREN R G CHILDREN R A TOBEY BANKERS HSBC 1 BROAD STREET LEOMINSTER HEREFORDSHIRE REG OFFICE 24 NETHERWOOD ROAD ROTHERWAS HEREFORD PLACE OF REGISTRATION CARDIFF N 1588087 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: FKMA, FKMG, FEPM ................................................................................................................................................................................. .................. Service application industries: TRP Sealing systems are a gasket manufacturer predominantly for the Plate heat exchanger (PHE) sector although are also producing rubber to metal bonded gaskets for the automotive industry including for new technology EV vehicles. PHE are seen to be extremely important both ecologically and environmentally in terms of energy recovery and clean ballast, FKM polymers are an important part in making this a sustainable business sector Sincerely yours, Name and signature Warren Febery Technical Manager TRP SEALING SYSTEMS LTD 24 NETHERWOOD ROAD ROTHERWAS INDUSTRIAL ESTATE HEREFORD HR2 6JU Tel: UK (0)1432-279366 Fax: UK (0)1432-273017 DIRECTORS S J CHILDREN R G CHILDREN R A TOBEY BANKERS HSBC 1 BROAD STREET LEOMINSTER HEREFORDSHIRE REG OFFICE 24 NETHERWOOD ROAD ROTHERWAS HEREFORD PLACE OF REGISTRATION CARDIFF N 1588087 TRP SEALING SYSTEMS LTD 24 NETHERWOOD ROAD ROTHERWAS INDUSTRIAL ESTATE HEREFORD HR2 6JU Tel: UK (0)1432-279366 Fax: UK (0)1432-273017 DIRECTORS S J CHILDREN R G CHILDREN R A TOBEY BANKERS HSBC 1 BROAD STREET LEOMINSTER HEREFORDSHIRE REG OFFICE 24 NETHERWOOD ROAD ROTHERWAS HEREFORD PLACE OF REGISTRATION CARDIFF N 1588087