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1 6: Missing uses - Analysis of alternatives and socio-economic analysis The VDMA represents more than 3,600 German and European mechanical and plant engineering companies. We assume that almost 100% of our manufacturers would be affected by the proposed PFAS restriction either in their products or production processes. Only few PFAS applications / uses have already been derogated -and even for those, the manufacturing processes are not included. The following list of technologies that would be affected is to be seen as examples and NOT an exhaustive list. In this respect, it can be assumed that unknown uses are missing from the list. Non- exhaustive list of technologies: Additive Manufacturing is a key horizontal technology for mechanical engineering and numerous other industries (e.g., it deals with industrial 3D printing) Air Handling Technology (e.g., refrigeration and heat pump technology, air conditioning and ventilation technology, air pollution control, surface technology and drying technology. Construction and building machinery (e.g., construction, building material, glass and ceramic machinery manufacturers); Compressors, Compressed Air and Vacuum Technology Cleaning Systems (e.g., floor cleaning and high-pressure cleaning machines for commercial cleaning technology); Electronics, Micro and New Energy Production Technologies (EMINT): Micro Technologies (including nanotechnologies, used in many disciplines, such as micromechanics, microoptics, microfluidics, microacoustics, microassembly, microvalves or micropumps) Productronics (entire process chain of electronics manufacturing, from design and crystal pulling to optical and electrical inspection) Photovoltaic Production Equipment (photovoltaic machinery manufacturing along the entire value chain) Battery Production (member companies supply machines, plants, components, tools and services along the entire process chain of battery production: from raw material preparation to electrode production and cell assembly to module and pack production) Engines and Systems (e.g., combustion engines for mobile machinery for construction and agriculture, power and heat generation, railroads and ships) 1 2 Fire Fighting Equipment (e.g., manufacture of fire fighting vehicles, fire protection equipment and fire pumps) Fluid power (e.g., hydraulic, pneumatic and sealing technology industry) Food processing and packaging machinery (e.g., bakery machinery, process technology for meat and protein processing, beverage production machinery, dairy technology, confectionery machinery, machinery and equipment for the processing of vegetable raw materials, packaging machinery, and machinery and equipment for the production of pharmaceutical and cosmetic products) Materials Handling and Intralogistics (e.g., automated guided vehicles, industrial trucks, cranes, Intralogistic systems and continuous conveyors) Agricultural Machinery (e.g., gricultural machinery, tractors, and related software systems) Power Systems (e.g., energy plant construction - including engine plants, thermal power plants, hydropower and wind energy plants as well as storage and sector coupling technologies) Process Plant and Equipment (e.g., sterile process engineering, chemical apparatus engineering, recooling technology, water, and wastewater technology as well as process engineering for oil, gas and petrochemicals) Pumps + Systems (centrifugal pumps as well as oscillating and rotating displacement pumps for liquids of all consistencies and solids) Textile machines to produce textile materials (clothing, home textiles and technical textiles), e.g., machines for chemical fibre production, machines for nonwovens production, dyeing machines, impregnating machines, drying machines. Textile Care, Fabric and Leather Technologies (e.g., textile care technologies, sewing and garment technologies, shoe, and leather technologies as well as processing technologies for technical textiles) Valves (building and industrial valves) Waste Treatment and Recycling Technology In Table 1 and Table 2 you can find a non-exhaustive list of PFAS-uses in machinery and equipment manufacturing industry that were not covered in the restriction proposal. In most cases fluoropolymers and fluoroelastomers are used. Table 1: PFAS missing uses examples in overall machinery and equipment manufacturing industry (examples, non-exhaustive list!) Machinery and equipment manufacturing industry (examples, non-exhaustive list!) PFAS missing uses (description of uses/application) Separation technologies and filter media (PVDF, PTFE, FEP, ECTFE) e.g. used in compressed air or process gas filtration Justification for use Coating filter material, cleanability, high filtration performance ( fine filtration), food and pharmaceutical application, FDA and Regulation (EC) 1935/2004 conform 2 3 Gaskets (PTFE, FEP, PFA, FKM, FFKM, FPM) High temperature, chemical resistance, mechanical properties of sliding Shaft sealings for machinery in process technology, construction machinery, crushing machinery (FKM, FFKM) Performance, persistence chemical Plain bearing bushes, thrust washers, guide bands, support ring, strips, wiper (PTFE, FKM, FVMQ) Mechanical properties of sliding, high Temperature and chemical resistance, individual machining possible Bushings, ball, sleeves, reducers, pipe, hose, elbow (PVDF) Seals (PTFE, FKM, FFKM, FEPM, FVMQ, PTFE, PCTFE, TFM, PVDF, PFA, FEP) for e. g.: heat generators, welding and compressed gas technology, valves, painting / surface technology, air&process gas compressors and their systems; sensors (e.g. dust measuring instruments, gas analyzers etc.), overall mechanical engineering Chemical resistance, Priceperformance ratio Thermal resistance >150C, high chemical resistance, abrasion resistance, water- repellent properties, reduce friction and prevent substances from adhering, extreme durability in heating systems, combination thermal and chemical resistance, sliding and emergency dry-running properties, low friction, low wear, less leakage, long lifetime Hoses (PTFE, FKM) for e. g.: heat generators, welding and compressed gas technology, valves, painting / surface technology, compressed air systems High resistance, water-repellent properties, reduce friction and prevent substances from adhering, extreme durability in heating systems Valves lined with PFA/PTFE used in e. g.: chemical, petrochemical, pharmaceutical, energy sector, food and process industries, air&process gas compressors and their systems Protection against corrosive, pure and high-purity liquids, gases and vapors Valves/safety valves (FKM, FPM, FPDM, PTFE, PVDF) for all machines Combination of high pressures, temperatures and various chemicals O-rings, mechanical seals, flat and face seals, Piston and rod seals, Wipers, Circlips, Radial shaft seals, Stuffing boxes, e.g. in industrial valves for all machines (like pumps, compressors, etc.) Long life time, tightness, reduce friction and energy consumption, sustainability, safety, high pressure resistance, chemical resistance Sliding coatings food&beaverages compressors/oilfree compression ring) (PTFE) e.g., machines for industry, oilfree rotating piston compressors (piston and Substitution for environmentally incompatible lubricants in sliding surfaces. 3 4 Guides (PTFE) Long life time, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance Surface treatment (PTFE, PFA, FEP, PVDF) e.g. pistons, wipers, inner tube surfaces, guide rods Non-stick coating, low friction, smooth running properties, chemical resistance, wear protection Hydraulic accumulator (PTFE, FPM, FKM) Combination of high pressures, temperatures and various chemicals and harsh environmental conditions Hydraulic components e.g. cylinders, pumps, motors, control blocks, valves (PTFE, EPDM, FKM, PVDF) Combination of high pressures, temperatures and harsh environmental conditions Parts and coatings for components in refrigeration and heat pump systems (e.g. bearings, thrust washers and dynamically stressed shaft bushings, PTFE), like compressed air refrigeration dryers Chemical resistance, temperature resistance, dimensional stability even at low temperatures, pressure and temperature fluctuations, low gas permeability and low electrical conductivity. Prevent leakage of the refrigerant e.g. ammonia. At the same time, the good sliding properties of e.g. coated surfaces enable low energy consumption. High wear resistance ensures longevity and significantly reduces the effort required for maintenance and repair Ring and flat seals as well as packings and other sealing systems (e.g. PTFE, FKM) in refrigeration and heat pump systems (also compressed air refrigeration dryers) Thermal resistance >150C, high chemical resistance, abrasion resistance, ensure at various points in the plants that valves can reliably shut off, regulate and perform the safety functions. In order to meet safety requirements and reduce environmental pollution, we depend on that valves close tightly, i.e. that no refrigerant can escape into the environment, and that certain sections of the plant can be safely shut off if necessary 4 5 Electrotechnical and electronic components(sensors, electronic controls and components) - used in all machines (FKM, PVDF, FEP or ETFE) High performance and resistance are only made possible by the use of materials containing PFAS to ensure energy-efficient operation. Coatings of the windings in motors for many refrigeration components (e. g. refrigerant compressors, refrigerant pumps and control valves) Use of FKM, FFKM, PTFE, PVDF in equipment for chemical industry e.g. for polymer washing processes, production of polycarbonate, crude oils, mono ethylene glycol (MEG) within the natural gas production, aromatic heavy fuel oils & residual oils, gas oils & kerosine, diesel oils, biodiesel B100, fatty acid methyl ester (FAME), naphtha, light condensates, NGL-natural gas liquids (Alkane's), methanol, coal water from the coke production, fish processing, special degumming in vegetable oil processes, vaccines etc.(also process gas compressors) High temperatures, strong abrasion and aggressive chemical conditions Use of Fluoropolymers und PFPE in textile machinery; machinery equipment for the textile industry: e.g. textile machines for the production of textile materials (clothing, home textiles and technical textiles), e.g. machines for chemical fibre production, machines for nonwovens production, dyeing machines, impregnating machines, drying machines. Pressure vessels for thermochemical treatment of textile recycling material in order to enable circular economy. Fully automatic chemical dispensing systems (used in various industries apart from textile industry: chemical, pharma, food), Heat recovery systems for reduction of need for fossil fuel based thermal process energy. Wastewater treatment technology As sealing materials to maintain function, reduction of maintenance and prevent leakage. As construction and coating materials for components to ensure energy efficiency, material efficiency of components (reduction of wear) and highest fabric quality of processed textiles. As part of lubricants with PTFE or PFPE used at high temperatures and in harsh conditions. In electrical components as part of drive and controlling to protect them against chemicals and high temperatures bearings/sliding bushes (PTFE) in air&process gas compressors coatings (PTFE, PVDF) e.g. anti corrosion coating of piping and connections for process technology or in process gas compressors, for top coating of v-belts, coatings for bolts in aggressive media like in oil&gas industry Chemical resistance 5 6 Sealing systems in leak detectors sealing membranes in the valves of gas containers for technical gases, refrigerants, LPG and other Thermal resistance, aggressive properties and chemical resistance against gases, dielectric Corrosion protection for process instrumentation (PTFE, PFA) Tube and hose connectors, flanges, quick release couplings, tube line valves, measuring connectors (PTFE, FKM) e.g. for hydraulic fluids, vlucanisation processes, hot forging processes Chemical resistance Cables, wires, plugs (PTFE, PFA) e.g. for signal Chemical and transmitter, pressure and flow switches, valves resistance Pneumatic components e. g. valves, regulators, actuators, tubes, fittings (FKM, EPDM, PTFE, PVDF) thermal Brake Pads - PTFE O-ring preloaded PTFE seals for pneumatic applications Support rings based on PTFE for high-pressure hydraulic applications Durability, tightness, low friction and energy consumption, sustainability, safety Durability, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance PTFE-based guide elements for pistons Durability, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance O-rings on FKM and FFKM basis Long life time, tightness, reduce friction and energy consumption, sustainability, safety, high pressure resistance X-rings on FKM and FFKM basis Durability, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance O-ring preloaded translational hydraulic seals (PTFE / FKM) Durability, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance, thermal resistance 6 O-ring preloaded rotary seals (PTFE / FKM) Radial shaft seals (FKM / FFKM) Lip ring seals (FKM / FFKM) O-ring preloaded PTFE wipers O-ring preloaded hydraulic rod seals (PTFE / FKM) Special FKM and FFKM rotary seals 7 Durability, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance Durability, tightness, low friction and energy consumption, sustainability, safety, chemical resistance Long lifetime, tightness, low friction and energy consumption, sustainability, safety, chemical resistance Durability, tightness, low friction and energy consumption, sustainability, safety Durability, tightness, low friction and energy consumption, sustainability, safety, high pressure resistance Durability, tightness, low friction and energy consumption, sustainability, safety, chemical resistance Table 2: PFAS missing uses partially observed in the universal PFAS restriction proposal (examples, non-exhaustive list!) Sect or of Use PFAS uses partially covered PFAS missing uses (description of uses/application) Justification for use Machine parts as mechanical guide, low friction and bracket, bearing, roller, screw nut, thermal temperature insulator resistance Textile Machinery and equipment for industrial laundry and textile finishing (ironing, form finishing, fusing and packaging) for textile products Axial sealing to rotating shafts (Viton); Vrings, static gaskets and hoses (Viton, Teflon) for tightness, temperature and chemical resistance in the washing process 7 8 Coating for sheetmetal parts (Teflon (eg. slices or strips) for low friction and temperature resistance Antisplash film (Teflon) Flame retardant protection for injection process of plastic and elastomeres, plastic and elastomers themsleves, electric and electronic components for water repellent protection during washing process Seals (PTFE, FKM, FFKM, FPM, Viton and fluorpolymeres as base materials) Coatings (PFA, FEP, PTFE, Viton, Teflon) Coatings (PFA) Coating (PTFE) for materials such as slices or strips protection against higher temperatures, abrasion, friction, elasticity but hightness during the washing and drying process for resistance to chemical influences as corrosion protection, high diffusion resistance during, protection against high temperature and chemicals during the washing process (e.g. in the washing drum cage or ram plate of dewatering press) non-stick properties and higher chemical resistance during washing, transportation and drying process with high temperature as required for highly contaminated textiles (e.g. medical textiles) maximum of friction reduction is required during washing and drying process 8 9 Pneumatic system products (PFBS) Hydraulic system products (PTFE, FKM, FFKM, FPM) Flex-and vacuum hoses (PTFE, Teflon) of various devices for textle finishing for design related equal temperature resistance for pneumatic compressed air line and vacuum extraction of hot steam stain resistance to enhance lifetime of product and spare parts of washing and drying process enhanced resistance during washing and drying process temperature resistance Conveyor and masking tapes (PTFE, PFA) Temperature protection in fusing and laminating machines, like flags (Teflon) for sliding and scraper blades (PTFE) for dimensionally stable bondig textile surfaces or leather temperature resistance for adhesive residue- free bonding textile surfaces or leather temperature resistance Hem rails (PTFE) for adhesive-free, heat and steam-resistant folding and ironing jacket hems adhesive-free, heat and steam- resistance Frame soles (PTFE) for material - protective (heat and friction) hand ironing devices Protection against heat and friction Seals (PTFE, FKM) Hoses (PTFE, FKM) Membrane (PTFE) Durability, leakage prevention, tested and certified microbiologically (including internationally on the basis of the EN 16421 standard) and with regard to substance migration behavior (for decades) Food contact materials and packaging Drinking water supply 9 Lubricants Manufact Manufacturing equipment / (e.g. bearing uring greases) for equipme Machinery nt and equipment for industrial laundry and textile finishing Electronics and semiconductors 10 Pumps, dosing devices, electronic components, industrial printers for printed electronics, machine tools, semiconductor manufacturing, construction machinery, laser equipment, wet chemical industry (medical technology, photovoltaics, electronics production,), automation components, grippers, sensors, organic photovoltaic cells, contact microphones, stethoscopes, loudspeakers, piezoelectric devices, pyroelectric sensors, electronic components, etc Withstand extreme conditions such as high temperatures and pressures. Due to their media resistance, they extend the durability and performance of machines and products Lubricants Manufacturing equipment industrial use Applications of fluorinated gases Equipment for manufacturing grease additives Lubricants for high-temperature resistant applications in the washing and drying process High-temperature resistance Compressed air refrigeration dryers Low-flammability and energy efficiency PFSA and fluoropolymers (PTFE) / fluoroelastomers (FKM, FFKM), in PEM electrolytic cell stack: Electrolyte membrane, Anode/Cathode catalyst layers, Porous transport layers, gaskets, insulation plates, CVP, valves Fluoropolymers (PTFE) / fluoroelastomers (FKM, FFKM) in AEM electrolytic cell stack: Electrolyte membrane, gaskets, periphery Safety, performance, long life time, mechanical stability, thermal resistance, durability, chemical resistance; Hydrophobic property Chemical resistance 10 PEM electrolyser Energy sector AEM electroly ser 11 Fluoropolymers (PTFE) / fluoroelastomers (FKM, FFKM) in PEM fuel cell stack: Electrolyte membrane, Anode/Cathode catalyst layers, Gas diffusion layers, gaskets, insulation plates, CVP, valves, cables safety, performance, long life time, mechanical stability, thermal resistance, durability Wind Energy / Fuel cell wind turbine PTFE; taping foil moulds as release agent in production; sealing rings, gliding pads, lubricants, li-battery Separates rotor blades from mould during production, smooth kinematic motions, self- sustainable turbines application Survey on participation in the public consultation among member companies: The two industry associations Spectaris and VDMA have conducted a survey on participation in the consultation among member companies. The results from the 15th of September 2023 showed that 54% of the participants (out of 438 responses from total approx. 4000 member companies) have already participated or will take part in the consultation. The figure 1 demonstrates the reasons for non-participation in the public consultation, -even when affected. The most common reasons were: The effort required to prepare an ECHA submission is too big We do not receive information from our suppliers about the use of PFAS. Personnel shortage. Figure 1: Frequent reasons for non-participation in the public consultation. The overall result of the survey indicates that less than 11% of the member companies from both associations have already submitted or will submit the information on the specific PFAS uses (and possible missing uses). In order to include possible unconsidered applications, a simple and unbureaucratic process for future exemptions should be made possible. In addition, an extension of the exceptions must be ensured. 11 12 Emissions and the end-of-life phase: Machinery and equipment manufacturers are downstream users of PFAS. Fluropolymers and fluoroelastomers are reported to be the most frequently used PFAS in our industry. These polymeric PFASs have been scientifically evaluated as safe for use according to chemical stability, non-toxicity, non-bioavailability, non-water solubility and non-mobility1 . The production of industrial components normally occurs in closed systems, thus avoiding possible PFAS emissions. They are incorporated into a sealed / contained system (e.g., machine) during the use phase and are discarded properly at the end of their life cycle. Recent studies2,3 have shown that in the event of incineration, fluropolymers and fluoroelastomers decompose into volatile fluorine compounds, which can be removed from the exhaust gases, e.g., via gas scrubbers. An uncontrolled release of PFAS compounds into the environment can thus be avoided. Socio-economical aspects: Machinery and equipment manufacturing industry stands for innovation, export orientation and SMEs. The companies employ around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries, both in the EU-27 and in Germany. In the European Union, it represents a turnover volume of an estimated 770 billion euros. Around 80 percent of the machinery sold in the EU comes from a manufacturing plant in the domestic market. The dramatic results for PFAS downstream users is shown in the Report for the European Chemicals Industry Council (Cefic) "Economic analysis of the impacts of a REACH restriction on the manufacture, placing on the market and use of per- and polyfluoroalkyl substances" performed by Ricardo. The scope and potential scale of impact, as indicated by the portfolio of products that are likely to be affected by the restriction scenarios considered in this study and a consideration of potential business responses can be found in Section 6.3 for downstream users. The Table 6-2, page 48 in the above mentioned report demonstrates the average percentage of the product portfolio (in terms of turnover) that may be affected by the adoption of the proposed restriction in case of general manufacturing, e.g. machinery, equipment, vehicles, other transport equipment (excluding electrical equipment).Costs and benefits driven by the impact on participating PFAS downstream users, including impacts on sectoral turnover from exports and Gross Value Added; intermediate consumption and operating costs, capital investment and R&D expenditure; and employment are presented in Sections 6.3.1- 6.3.6. 1 Henry, B. J; Carlin, J. P; Hammerschmidt, J. A; Buck, R. C; Buxton, L W.; Fiedler, H.; Seed, J.; Hernandez, O. A Critical Review of the Application of Polymer of Low Concern and Regulatory Criteria to Fluoropolymers. Integr. Environ. Assess. Manage. 2018, 14 (3), 316-334.) 2 Krasimir Aleksandrov, Hans-Joachim Gehrmann, Manuela Hauser, Hartmut Mtzing, Daniel Pigeon, Dieter Stapf, Manuela Wexler, Waste incineration of Polytetrafluoroethylene (PTFE) to evaluate potential formation of per- and Poly-Fluorinated Alkyl Substances (PFAS) in flue gas, Chemosphere, Vol. 226, 2019, pp 898-906 (https://doi.org/10.1016/j.chemosphere.2019.03.191) 3 Dr. Gehrmann, Hans-Joachim, Dr. habil. Bologa, Andrei, Dr. Aleksandrov, Krasimir, Bergdolt, Philipp, Dr. Taylor, Philip, Dr. Schlipf, Michael, Dr. Ameduri, Bruno, Gunasekar, Priyanga, Kapoor, Deepak, Pilot-Scale Fluoropolymer Incineration Study: Thermal Treatment of a Mixture of Fluoropolymers under Representative European Municipal Waste Combustor Conditions, (2023) 12