Document YmVO0M0vbK6poORj9b48rq4V

PFAS Restriction under REACH: What Way Forward for Fluoropolymers? , Chemours APM , EU Focus Group , EU Focus Group 28 March 2023 Chemours in Europe Netherlands (Dordrecht) Main manufacturing site Established in 2015 Four Business segments: Titanium Technologies Thermal & Specialised Solutions (TSS) = F-Gases Advanced Performance Materials (APM) = FLUOROPOLYMERS Chemical Solutions Belgium (Mechelen) Blending facility Research Lab France (Villers-Saint-Paul) Smaller manufacturing site Geneva Research Lab Offices What are Fluoropolymers? Fluoropolymers are specialized high end performance plastics that bring unique combination of properties, making them substances of necessity rather than choice. Their durability is their main asset and the reason why they are demanded by society. Durability is precisely the benefit of FP: alternatives would weaken reliability efficiency, energy saving, innovation, etc... Fluoropolymers are part of the solutions to decarbonizing our economy, and key enablers of the EU Green Deal Their unique combination of properties make them critical to all industries and to modern life. Their applications span nearly every major sectors of the European economy where products must meet specified performance and where failure is not an option. They are expensive to manufacture and are therefore replaced whenever possible. Fluoropolymers do not pose a significant risk to human health or the environment when used for their intended purposes. They meet OECD criteria of Polymers of low concern (PLCs) as they do not degrade and their high molecular weight - No Bio-accumulation possible. Where are Fluoropolymers used? Health Energy Semicon Connectivity Electrification Aerospace & defense Internal combustion engine (ICE) vehicles Commercial vehicles & trucks Chemical processing equipment Chlor-akali production Wire & cables Oil & gas extraction and distribution Semiconductors Essential Today Semiconductors Electric vehicles Hydrogen electrolysis Energy storage 5G network Connected devices Communications equipment Wire & cables Essential Tomorrow REACH PFAS Annex XV - Our Concerns THE PROPOSAL BY 5 COUNTRIES IS FLAWED No derogations, only bans (+18 months after EiF) or "delayed bans" (+6.5 or +13.5 years after EiF) Persistency - main criterion for ban ("P-sufficient approach"): No hazard assessment No information on use resulting in emissions Nor risk assessment Insufficient analysis of alternatives No causual link between alleged presence of PFAS and actual fluoropolymers usage Wrong premises (e.g. non-fluorinated polymerization aids are `better' for the environment) Old data (e.g. HFPO-DA emissions data from 2013) Alternative RMOs not considered DIRECT IMPACT ON FLUOROPOLYMERS 1. Fluoropolymer are in scope of restriction proposal. 2. Fluorinated Polymerization aids are banned for the production of PTFE and FKM (Chemours products). 3. Transported isolated intermediates used under strictly controlled conditions are banned (contrary to REACH). OVERALL: indirect ban on high-tech economic sectors relying on fluoropolymers. OVERALL: no demonstration of unacceptable risk & no recognition that fluoropolymers can be produced responsibly SEA - Non use scenario 2026-2035 PFA in semiconductors (PFA is one type of Fluoropolymer) Projected total economic losses more than 66 billions Without PFA Europe would lose its ability to produce its own supply of chips Without PFA the ability to produce components and infrastructure would not be possible. Substitution may require +10 years and 40 years for the process to the current level of manufacturing capacity (confirmed by Intel) Case study automotive (Scenario: A complete ban of ALL fluoropolymers in Europe) Total economic losses: >439 billions 1,890 enterprises would likely cease trading and close NafionTM in Hydrogen Economy (proton-exchange membrane) Projected total economic losses: More than 1 Billion Currently no viable alternatives to fluoropolymer PEMs are available that can deliver performance requirements equivalent to NafionTM Europe would no longer be able to produce or use PEM fuel cells or electrolysers Lifetimes of fuel cells and electrolysers using nonfluorinated membranes would not be sufficient to achieve market viability Alternatives may use fluoropolymers in non-membrane applications to achieve functionality (gaskets, seals, tubing, etc.) Alkaline fuel cells rely on potassium hydroxide (KOH) obtained from the chlor-alkali process, which is heavily dependent on the use of fluoropolymer membranes EU Hydrogen Strategy, European Clean Hydrogen Alliance, REPowerEU (210 Billion by 2027), Clean Hydrogen Partnership, and Fit for 55 goals are unattainable What Way Forward for Fluoropolymers? 1. Fluoropolymers. Should get "no time-limited derogation" for manufacturing and use in applications in transportation, medical, electronics, semicon, hydrogen, communication, chemical and other industrial applications Condition: responsible manufacturing through abatement technologies & mandatory end-of-life management (ALL manufacturers & downstream users). Derogation should be extended for substances (polymerization aids) essential in manufacturing fluoropolymers, if condition on responsible manufacturing are met. 2. Substances (polymerization aids). Risks are under control (RCR <1), used only in strictly controlled settings, recovered and recycled after use, no health risks for workers at site and general population (according to RVIM), negligible amount of residues in final product (REACH art. 68 criteria not met). 3. Transported isolated intermediates. Should be exempted as they are only used in strictly controlled industrial settings. ...because Fluoropolymers can and must be manufactured & disposed of responsibly Dominating "anti-PFAS" narrative is based on old technologies based PFOS, PFOA - banned since more than 10 years in Europe! State-of-the-art abatement technologies can reduce emissions of fluorinated organic compounds to a couple of kgs per year. Permits for Dordrecht facility for emission to air and water took abatement measures into account (around 35 kgs in 2021 vs 8 tons in 2013) Fluoropolymers and polymeric PFPEs: meet OECD criteria of low concern (PLCs), do not degrade and do not bio-accumulate (high molecular weight) The largest share of fluoropolymers waste is thermally treated and immobilized (additional studies ongoing)