Document VMa2QR0JKJbpq7gVMZvwmQ8j

Classification: General Business Use SHPP's Inputs to the Public Consultation Comments to Annex XV PFAS Restriction Proposal Question number 6: Missing uses: PTFE Used as an Anti-Drip Additive in Flame Retardant Polycarbonate Resins and Blends for Electric Vehicles Charging Devices Executive Summary SABIC's Specialties business (SHPP) produces a range of highly differentiated products, including high-performance thermoplastics, compounds, and additives that meet complex thermal, mechanical, optical, and electrical property requirements. Flame retardant polycarbonate (FR PC) resins and blends with Polytetrafluoroethylene (PTFE) anti-drip additives play a safety-critical role while providing functionality in Electric Vehicle (EV) charging devices, such as both parts of the charging coupler (plug and inlet), charging station enclosures, and connectors. To fully functionalize the FR PC resins and blends for such applications, the materials need to be inherently tough to withstand harsh environments to provide device integrity, especially during cold temperature impact events and maintenance activities. This ensures the device continues to function properly, and does not produce any electrical hazards (short circuit, shock hazard) or fire hazards. Because these plastics are inherent insulators, they also provide a significant reduction in electrical shock resistance when used in these high-voltage applications. By increasing ignition resistance, these materials help to prevent injuries and property damage by lowering the probability of a fire event. If a flame event does occur, they help prevent the loss of life and property by reducing the risk of a small fire growing out of control. All the safety and functionality advantages must be maintained over time in the outdoor environment. This environment requires UV and water/moisture resistance, and property retention over a wide range of temperatures including cold temperature impact and ductility. The specific devices where these FR PC resins and blends are used all see high voltages. A failure of any one of these devices would, at best, compromise the charging system functionality, but it could also lead to immediate fire hazards and immediate or hidden shock hazards to anyone interacting with the system - maintenance, repair, adjacent activities, etc. A recent review published by the Society of Environmental Toxicology and Chemistry (SETAC) in 2023 states that emissions of PTFE during the use phase of final products are negligible because PTFE is bound within the polymer. The emissions in the waste stage depend on the pre-treatment method. PTFE does not release substances of toxicological or environmental concern, and fluoropolymers are stable and not expected to transform to dispersive nonpolymeric PFAS. Evaluating the possible alternatives shows that no known alternatives provide the same performance functions and the same/better safety and socio-environmental benefits. Finding an alternative to PTFE in FR PC resins and blends is challenging and would require at least 57 years of research and invention. Additionally, numerous tiers, OEMs and moulders across Classification: General Business Use the globe would need to re-design and re-test their tooling, components and systems, which could take 7-10 years to fully replace. Therefore, it could take at least 12-17 years to develop a new material solution with the same performance and environmental benefits as PTFE, and to replace it in existing applications. Therefore, SHPP requests a 12-year derogation for PTFE used in FR PC resins and blends for use in EV charging device applications. Substance Information: Substance Name: Poly(1,1,2,2-tetrafluoroethylene) Synonyms/Abbreviations: PTFE Molecular formula: (C2F4)n EC/List no.: 618-337-2 CAS number: 9002-84-0 Type: Solid Application: PTFE used as an anti-drip additive in flame retardant polycarbonate resins and blends for EV charging devices 2 Classification: General Business Use Table of Contents Executive Summary 1. Technical description.........................................................................................................3 1.1 Application description.............................................................................................4 1.2 Function of material/article and PFAS content......................................................6 1.3 PFAS properties required in material/article.........................................................7 2. End-of-Life.........................................................................................................................8 2.1 Concerning Exposure to the Environment .............................................................8 3. Availability of substitutes...................................................................................................9 3.1 Alternative applications............................................................................................9 3.2 Alternative substances ..............................................................................................9 4. Development of possible substitutes................................................................................11 4.1 Actions taken to develop alternative applications or alternative substances ....11 4.2 Stages and timeframes needed to establish possible substitutes .........................12 5. Request for derogation for use of PTFE as an Anti-Drip Additive in Flame Retardant Polycarbonate (FR PC) Resins and Blends for EV Charging Devices.................................12 1. Technical description 3 Classification: General Business Use 1.1 Application description SABIC's Specialties business, SHPP B.V. (hereafter "SHPP"), produces a range of highly differentiated products, including high-performance thermoplastics, compounds, and additives that meet complex thermal, mechanical, optical, and electrical property requirements. Injection mouldable, PTFE-containing flame-retardant polycarbonate (FR PC) resins and blends are commonly used in EV charging devices such as the charging coupler (both plug and inlet), charging station enclosures, connectors, etc. These compounds typically comprise a neat base polycarbonate resin or blend,, a flame retardant, and a PTFE polymer, which serves the purpose of an anti-drip additive. Additionally, these FR PC formulations may include other additives and pigments. FR PC compounds containing PTFE are a semi-finished product in the form of plastic pellets that are subsequently injection moulded or extruded into shapes and final parts. The primary purpose of these compounds is to provide flame-, electrical-, and impact-resistance to indoor and outdoor charging device applications and to help ensure the safe, reliable functioning of the applications over the lifetime of the device. These compounds are in many cases optimized for the specific requirements of the final applications. Some examples include: Excellent flame resistance Cold temperature impact and ductility/flexibility Overall mechanical / impact strength Temperature resistance / long-term thermal aging Weather resistance (retention of properties) - UV and water exposure High continuous use temperatures Corrosion resistance Intricate moulded-in functionality (e.g., interlocking connector pieces) Over the past 25 years, FR PC resins and blends using PTFE as an anti-drip additive have been utilized in electrical applications due to their differentiated properties. Typically, these applications must undergo complex and extended-life testing and meet demanding regulatory and industry prevailing standards requirements to ensure their safety and functionality throughout their expected or mandated lifespan. The injection moulding tools used to fabricate the components using the PTFE anti-drip compounds are often complex and designed to fabricate parts to very tight tolerances and to fulfil the applications' technical and regulatory requirements. Any significant change in composition/formulation of the compound, such as eliminating the PTFE and/or replacing it with a possible alternative, could result in needing to modify or replace the injection moulding tool to produce parts with the same final design and geometry. Also, a change in formulation or properties of the compound will likely trigger further mandatory design changes in adjacent parts that are not directly affected by this material change, because the parts must function together as a system in an assembly. Any of these changes could take years in EV charging 4 Classification: General Business Use devices, depending on the complexity, materials used in fabrication and the number of tools per application. Furthermore, the final assembly would often need to be completely re-tested and re-specified to ensure proper functioning over its lifetime. Since EV charging devices are regulated and safety critical, new materials often require extensive and severe long-term testing, which can take several years of qualification and validation to complete a substitution. Given the retesting and re-specifying, coupled with changes in design and production, part substitution can easily take several years to complete, and the more complex devices could extend the timeline further. Some examples of the above-mentioned components are given here: Charging Couplers Both parts of the charging couplers, plug and inlet, are essential, safety critical elements of the charging system. These parts protect humans by preventing direct contact with the electrical connections. The plug should last for decades (the lifetime of the charging station), while the inlet should last the lifetime of the EV. Of the two, the plug is likely the part that will be affected the most by environmental aspects, such as drops and exposure to sunlight. EV Charging Stations Enclosures of EV charging stations protect the electrical components of the charging system, and should be resistant to weather, water, and chemicals, and be impact-resistant over a range of temperatures, with an emphasis on exhibiting low-temperature toughness. 5 Classification: General Business Use 1.2 Function of material/article and PFAS content For EV charging devices, the PTFE anti-drip FR PC resins and blends provide flammability performance with minimal flame retardants to preserve electrical properties, cold temperature impact resistance and other mechanical properties, heat resistance and more. These properties facilitate maintenance-free, reliable, and proper functioning of safety-critical devices and sub-components over a long lifetime that can be up to 20 years or more. PTFE is used as an anti-drip additive that allows the PC resin or blends to achieve required flammability performance with less flame retardant additives. In general, flame retardant additives are only added for flammability performance and could lessen other properties such as impact, ductility, and outdoor weather performance. The PTFE preserves those other properties necessary for EV charging devices. PTFE as an anti-drip agent is typically used in the range of 0.1-0.5% by weight. Due to the high voltages and currents involved, EV charging systems have a risk of fire and a risk of electrical shock. EV safety standards use material fire resistance and electrical insulation requirements as two critical safety elements to help mitigate these risks. For fire resistance, there are several common industry test standards that require materials to resist ignition, burning, and dripping flaming particles. One common standard is "UL 94, the Standard for Tests for Flammability of Plastic Materials for Parts in Devices and Appliances,"1 which is now harmonized with IEC 60707, 60695-11-10 and 60695-11-20 and ISO 9772 and 9773. The device standards tend to use the higher flame classifications of either V-0 or 5VA/B for materials that are used as enclosures, structural parts, and electrical insulators. Both ratings require that samples do not drip flaming particles during the tests. Since thermoplastics are designed to be shaped/flowed by heat, direct flame application can lead to melting and dripping before or during ignition. Any flaming melting/dripping has the chance of spreading flame beyond the initial event and is almost always more pronounced in thinner rather than thicker gauges of thermoplastics, all else being equal. Based on Table 2 (section 4.1), PTFE is the only viable additive that can inhibit dripping and retain all the other properties necessary for EV charging applications. Since charging stations might be installed outdoors, long-term weatherability and temperature resistance are properties critical to both performance and safety. Standards such as UL 746B2 and 746C3 use long-term aging tests (UV, water exposure, and temperature) to ensure that properties such as flame and electrical resistance, and mechanical strength are retained for safe operation. Specifically, an outdoor rating of f1 comes from UL746C, and Relative Thermal Index Testing (RTI) comes from UL 746B. A relatively simple RTI test takes 8-10 months (up to 2 years if more complicated), while f1 testing takes about 3 months. Assuming there is laboratory availability, additional time is needed for sample preparation and logistics, which can add another 3 months to the process. PTFE as an additive is exceptional in that it is highly 1 https://www.shopulstandards.com/ProductDetail.aspx?productId=UL94_6_S_20130328 2 https://www.shopulstandards.com/ProductDetail.aspx?productId=UL746B_5_S_20180815 3 https://www.shopulstandards.com/ProductDetail.aspx?productId=UL746C_7_S_20180205 6 Classification: General Business Use resistant to thermal and UV degradation, does not migrate out of the PC resins and blends when exposed to water, and does not significantly change other properties while improving flame performance. As voltages increase and devices have space/size limitations (e.g., charging couplers), a key electrical property requirement of EV charging devices can be the Comparative Tracking Index (CTI) Test (versions of this test are IEC-601124 and ASTM D36385). This test measures the resistance of a material to form a conductive, carbonized track on its surface that could lead to a short circuit, a fire, and/or an otherwise neutral part being energized (risk of electrical shock). To minimize the amount of material and to design smaller, more efficient parts, the best CTI rating is usually requested by EV system OEMs, meaning a CTI voltage of > 600V, also called a CTI Performance Level Category (PLC) of 0 according to the UL746A6 standard. Many additives can degrade CTI performance (e.g., carbon fibers, which are conductors). PTFE as an anti-drip additive does not degrade CTI performance. 1.3 PFAS properties required in material/article The PFAS used in these types of formulations is a fully fluorinated polymer Polytetrafluoroethylene (PTFE). The types of PTFE used as an anti-drip/enhanced structural integrity additive in engineering thermoplastic compounds help the overall FR additive package by providing the following key product attributes: Increased resistance to ignition Reduced rate of flame spread once a fire has started Flame retardant formulation strategies for thermoplastics typically are combinations of multiple additives. These generally fall into two classes that typically work synergistically: flame suppressants and anti-drip additives. PTFE additives provide a unique, critical role as structural integrity/anti-drip agents, which allow for minimal FR additives. During melt processing high mechanical shear exists, PTFE compounds that are designed to be anti-drip additives do not melt during melt processing but undergo a physical form change from being semi-spherical particles to highly elongated fibrils in this high temperature, high shear environment. These very high aspect ratio fibrils form an entangled network inside the polymer matrix. During a flame event, this network does not burn/ignite but helps promote char formation and provides much higher melt strength to the plastic part, significantly improving resistance to deformation and/or loss of structural integrity as the polymer matrix burns (e.g., no flaming drips and enhanced resistance to further heat release from the flame initiation point). A non-exhaustive list of other properties that make PTFE anti-drip additives in FR PC resins and blends differentiated materials in electrical applications are: high melting point 4 https://webstore.iec.ch/publication/32739 5 https://www.astm.org/d3638-21e01.html 6 https://www.shopulstandards.com/ProductDetail.aspx?productId=UL746A_6_S_20120906 7 Classification: General Business Use high resistance to thermal degradation very high resistance to chemicals very low surface energy electrically non-conductive inert reactivity due to perfluorinated structure and high molecular weight. 2. End-of-Life Emissions during the use phase of final articles are negligible, because PTFE is bound within the polymer. However, it is understood that PTFE in products will eventually enter the waste stage with levels in the polymer matrix at 0.1-0.5% by weight. 2.1 Concerning Exposure to the Environment A recent review published by the Society of Environmental Toxicology and Chemistry (SETAC) in 2023 states that emissions of PTFE during the use phase of final products are negligible because PTFE is bound within the polymer. The emissions in the waste stage depend on the pre-treatment method. PTFE does not release substances of toxicological or environmental concern, and fluoropolymers are stable and not expected to transform to dispersive nonpolymeric PFAS. When the articles containing PTFE anti-drip additives reach their end-of-life, various waste (pre-) treatment methods are commonly practiced by the industry, e.g., recycling/re-use, landfilling and incineration. Thorough incineration will decompose PTFE without formation of non-polymeric PFAS. When recycling/reuse and landfilling are chosen, polymeric PTFE remains as a fluoropolymer that is not water soluble or mobile and therefore, does not present the specific risks nor hazards as those of non-polymeric PFAS. There is considerable data demonstrating that PTFE do not release substances of toxicological or environmental concerns7. In contrast to non-polymeric PFAS, PTFE being a polymeric material is chemically, thermally, and biologically stable and therefore is not expected to transform to dispersive nonpolymeric PFAS when disposed of in landfill. A recent study presented results from OECD guideline biodegradation studies demonstrating that PTFE is stable under environmentally relevant conditions. Furthermore, fluoropolymers that meet the criteria to be considered Polymer of Low Concern (PLC), have negligible leachables, unreacted monomers, and oligomers most likely destroyed in fluoropolymer use processing and would therefore not be expected to significantly contribute to landfill leachate. 7 Korzeniowski, S.H., Buck, R.C., Newkold, R.M., kassmi, A.E., Laganis, E., Matsuoka, Y., Dinelli, B., Beauchet, S., Adamsky, F., Weilandt, K., Soni, V.K., Kapoor, D., Gunasekar, P., Malvasi, M., Brinati, G. and Musio, S. (2023), A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers. Integr Environ Assess Manag, 19: 326-354. https://doi.org/10.1002/ieam.4646 8 Classification: General Business Use Available data reveal that fluoropolymers are mineralized (i.e., all C-F bonds broken, hydrofluoric acid generated, and scrubbed to calcium fluoride) under commercial Waste-toEnergy (WtE) incineration operating conditions. In recent pilot scale studies representative of full-scale WtE facilities, the most common form of end-of-life destruction conducted on PTFE found that combustion converted the fluorine into controllable hydrogen fluoride gas and that, of the 31 PFAS studied, no fluorine-containing products of incomplete combustion were produced above background levels. Further, a recent study investigating the presence of PFAS in waste incinerator flue gas stated: "based on a literature review, RIVM (the Dutch National Institute for Public Health and the Environment) expects that most of the PFASs will largely degrade during the incineration process and then be removed when the flue gases are cleaned. The remaining PFASs are expected to be removed during the recovery of the carbon dioxide". The RIVM report8 affirmed that PTFE is the most stable fluorine-containing polymer. The RIVM report concluded that complete thermal decomposition of PTFE is achieved at a temperature of approximately 800C. 3. Availability of substitutes 3.1 Alternative applications There are no known alternatives to PTFE used as an anti-drip agent in FR PC resins and blends for EV charging applications that result in the same flammability, electrical, impact, weathering, and other properties and application performance. Alternative formulations/compositions would require potentially long-term re-testing of the material, and part re-design and re-qualification. Any alternative solution must first be technically feasible and meet regulatory requirements. It is then likely that in most cases the parts made from the alternative solution will either have a shorter lifetime/more waste (because of failures related to impact/ductility) or will be unable to meet other application requirements such as CTI ratings > 600V. In-service failures of parts also carry the risk of fire and electrical shock events. 3.2 Alternative substances EV charging device manufacturers must constantly balance meeting both safety standards and real-world performance requirements. While there are many thermoplastics available that can meet some of the requirements for EV charging equipment, as listed in the Table 1 below, none of them have the balanced properties necessary to meet all the requirements for a given charging device. In addition to flame resistance and a CTI value of > 600V, two key physical properties a material must have for these types of applications are cold temperature impact resistance and ductility/flexibility. Impact resistance is the material's inherent resistance to 8 Bakker, J., Bokkers, B., & Broekman, M. (2021). Per- and polyfluorinated substances in waste incinerator flue gases (RIVM Report 2021-0143). https://www.rivm.nl/bibliotheek/rapporten/2021-0143.pdf 9 Classification: General Business Use permanent deformation or breaking caused by a force acting upon it (e.g., a collision with another object, a drop, etc.). Ductility/flexibility is a materials inherent ability to bend without breaking. There are several ways to determine a material's impact resistance and ductility. Common methods are called Notched Izod or Charpy Impact (NI) and Tensile Elongation (TE). These techniques measure the amount of energy that a material can absorb during impact or the amount of elongation (as a percentage of the initial gauge length) that a material will deform before breaking. These tests are performed in controlled laboratory settings, following standardized test methods such as ASTM D2569/ ISO 18010 for NI and ASTM D63911/ISO 52712 for TE. The higher the values in these tests, the tougher the material is and the more resistant it is to cracking or breaking. FR PC resins and blends are used so prevalently in the EV charging device industry because of the unique balance of flame resistance and toughness they can provide. Table 1 shows a broad range of materials' flame resistance, as measured by their UL94 V-0 and 5VA/B ratings, along with their weatherability, cold temperature impact retention, and inherent toughness compared to an FR polycarbonate blend with PTFE as an anti-drip agent reference.. Impact and ductility data is shown as a percentage decrease in Notched Impact and Tensile Elongation. Material (non-reinforced) Property New Polycarbonate Blend w/ PTFE Anti-Drip PPE/PS Polyetherimide PPSU PEEK Polypropylene Copolymer FR, Talc Filled Polyamide FR, Glass Fiber Filled Flame Resistance Passes UL94 V-0 < 1.0 mm T Flame Resistance Passes UL94 5V-A/B < 2.5 mm T T Property Comparison Impact/Crack Resistance Notched Izod Impact, % of Reference 100% (Ref) Ductility Elongation @Break, % of Reference 100% (Ref) 12% (88% decrease) 4% (96% decrease) 83% (17% decrease) 11% (89% decrease) 13% (87% decrease) 11% (89% decrease) 14% (86% decrease) 55% (45% decrease) 55% (45% decrease) 46% (54% decrease) 12% (88% decrease) 2% (98% decrease) Weatherability f1 (per UL) Property Retention Limited grades available T T T T Impact/Crack Resistance Cold Temperature Impact Retention T T T Surface Tracking CTI > 600 V T T T T Table 1. Property comparisons of existing materials As can be seen in Table 1, several materials can achieve the necessary flame resistance. However, none of these materials have a comparable toughness to the FR PC blend with a PTFE anti-drip additive. The significantly lower ductility and toughness makes most of these materials unsuitable for use in applications that require inherent resistance to cracking and breaking, which are ubiquitous requirements in the design and manufacturing of EV charging devices. 9 Standard Test Methods for Determining the Izod Pendulum Impact Resistance of Plastics (astm.org) 10 ISO 180:2019 - Plastics -- Determination of Izod impact strength 11 Standard Test Method for Tensile Properties of Plastics (astm.org) 12 ISO 527-1:2019 - Plastics -- Determination of tensile properties -- Part 1: General principles 10 Classification: General Business Use Also, most of the alternative materials cannot achieve the necessary mix of other properties, such as cold temperature impact retention, outdoor weatherability, and CTI > 600. 4. Development of possible substitutes 4.1 Actions taken to develop alternative applications or alternative substances Owing to its unique physical property profile leading to exceptional performance as an antidrip additive (e.g., high heat resistance, excellent compatibility across a broad range of materials, chemically inert, fibrillation/deformation under shear, inherent resistance to ignition, efficacy at very low loadings), there are no known direct replacements for PTFE as an antidrip agent in FR PC resins and blends for EV charging applications. FR PC resins and blends are often desired for their cold temperature impact strength. For these PC resins and blends, there are several strategies that can be employed to increase resistance to dripping by increasing melt strength or the stiffness of the material with either viscosity enhancers or mechanical fillers. For example, melt strength can be improved by incorporating compatible polymers to increase the zero-shear viscosity of the system (e.g., highly branched PC). Because this approach significantly increases the viscosity of the system, it does improve the system's resistance to deformation as the temperature increases. Similarly, glass fibre or other inorganic fillers (e.g., clay, talc, carbon fibre) can be added to increase the stiffness or modulus of the material. Table 2 shows the flame resistance, CTI performance and the inherent toughness of formulations using these strategies as compared to a PTFE anti-drip additive. PTFE Replacement Property PTFE Branched/High Viscosity Resin Mineral (Glass, Talc, Clay) Carbon Fiber Flame Resistance Passes UL94 V-0 < 1.0 mm T T Property Comparison in PC Flame Resistance Passes UL94 5V-A/B < 2.5 mm T T T Impact/Crack Resistance Notched Izod Impact, % of Reference 100% (Ref) 14% (86% decrease) 16% (84% decrease) 10% (90% decrease) Ductility Elongation @Break, % of Reference 100% (Ref) 44% (56% decrease) 6% (94% decrease) 1% (99% decrease) Surface Tracking CTI > 600 V Does not lessen CTI performance Irrelevant due to not meeting flame requirements T T Table 2. Comparison of the flame resistance, CTI performance, and ductility/toughness of various classes of PTFE anti-drip replacement options compared to a polycarbonate blend reference sample with a PTFE anti-drip additive. As can be seen by the property comparisons, these approaches have a significant effect on the impact resistance and ductility of the materials. Unlike PTFE, these additives must be used at relatively high loadings (10-50 times or more than PTFE loadings) to have a significant effect on anti-drip properties. These high loadings of fillers cause a dramatic decrease in the ductility 11 Classification: General Business Use and impact resistance of the material, and some deteriorate the CTI performance. This significant trade-off in properties makes them unsuitable for use in applications that require inherent resistance to cracking and breaking and excellent CTI performance, which are prevalent requirements in the design and manufacturing of EV charging devices. 4.2 Stages and timeframes needed to establish possible substitutes There are no alternatives to PTFE available today for use as anti-drip agents in FR polycarbonate resins and blends that result in the same extraordinary properties and application performance for EV charging applications. A wide range of potential alternatives have already been tested and found to fail to provide the necessary properties. A new round of extensive, fundamental laboratory research will be needed to attempt to identify a completely new material, unknown today, that may potentially be developed into an alternative to PTFE. SHPP expects it may take up to 8 years to carry out this basic research. If a new alternative material is identified it would take several more years to test, qualify, certify, and start manufacturing parts from this replacement material. Companies may need to make changes to their manufacturing equipment and processes to use the new material in their moulding lines. These changes to manufacturing equipment and processes may be significant and require extensive time and capital investment. Product requalification is a very time-consuming exercise that will require extensive resources over many years. The completion of this task will require sufficient test house capacity and transition time to requalify all existing flame retardant polycarbonate resin and blend parts in products that are used in Europe for EV charging device safety and performance. For a company with a wide range of existing product designs, SHPP estimates it could take up to 5 years to carry out the necessary manufacturing equipment changes and product requalifications. 5. Request for derogation for use of PTFE as an Anti-Drip Additive in Flame Retardant Polycarbonate (FR PC) Resins and Blends for EV Charging Devices Given the two derogation choices, SHPP respectfully requests a 12-year derogation. Since there are no PTFE alternatives available which can provide the same performance functions and the same/better safety benefits, a 12-year derogation is absolutely needed. The material industry will need to develop a better solution (or equivalent) if possible, and all the moulders and OEMs from the EV charging industry who use this type of material will need to re-design and re-test their parts, devices, and systems. Since the proposed derogation is only for PTFE, one additional point of reference is the UK's recently published PFAS regulation proposal. They limited their proposed restriction to certain and specific PFAS substances and did not apply the restrictions to an entire class of fluorine substances. Of particular note, they are excluding fluoroplastics and fluoroelastomers (such as 12 Classification: General Business Use PTFE, PVDF, etc.), which they consider as low hazard groups, from their proposed regulation. Presumably, this is because fluoropolymers (such as PTFE) are not water soluble, are not mobile, and do not present the same level of environmental hazards as low-molecular-weight non-polymeric PFAS. SHPP believes this also provides a basis for a total exemption of PTFE from the potential REACH restrictions if one is to be considered. 13