Document zQ1NjroEDEEzaJ5rRnBw5EVrB

09.08.2023 Usage of PFAS-materials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH Usage of PFAS-materials based coatings in electronic boards production For ECHA's consultation Submitted by: Johannes Ballhaus Puretecs GmbH Fabrikstrage 18 73252 Owen Germany Contact: @Puretecs.de +49 1631469202 Content 1 Why is coating done for electronic boards? 2 2 Protection layer through fluoropolymers 3 3 Current materials mainly used 4 4 Technical process 5 4.1 Manual coating process 5 4.2 Automatic coating process 5 4.3 Solvent losses 6 5 Other coating technologies 6 6 Advantages of fluorinated solvents and coatings 7 7 Waste treatment 8 8 Using of alternatives 8 9 Market and industry 8 10 Derogation needs 9 1 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 1 Why is coating done for electronic boards? In general, an electronic board (PCBA) works without a protective coating. Nevertheless, it has been shown that the sensitive boards in many cases have errors and failures if they are not protected from environmental influences such as moisture, salt air, exhaust gases, aggressive gases, dust and particles by an additional protective layer on the surface. In particular due to the trend towards providing electronic boards to more and more products that were previously constructed purely mechanically or electrically, electronic boards are increasingly found in places where they need additional protection. The trend to make all things in life more flexible and smarter is leading to the electronification of many products that are stationed outdoors or mobile. These products often aim to use and save energy better or to make other areas of life more efficient. Also miniaturization and the everincreasing demands on reliability often require a protective coating. A very large number of processes and materials have been developed for the electronic protective coating application. Part of this is taken up by the ultrathin protective coatings based on fluoroacrylic polymers (fluoropolymers). Potting Parylene Varnish Soft coating Fluoropolymers Dipping in water X X Rain X X X Single drops X X X X Dewing X X X X X High humidity X X X X X Corrosive gases X X X High voltage X X X isolation Agressive liquids X X Mechanical X protection X X Process Challenging Time Suitable consuming Costs Medium High Low In this document we have the view only on fluoropolymers. Limited Medium Easy Adequate 2 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 2 Protection layer through fluoropolymers In the use for electronic assemblies, typical electronic boards, a fluoropolymer is dissolved in an HFE. In most cases the electronic assemblies are totally dipped into this unburnable, not conductive liquid. By withdraw the electronic assembly out of the liquid a thin liquid film remains on the surface. The solvent HFE evaporates quickly and the fluoropolymers remain on the surface creating the hydrophobic and oleophobic protection layer. The layer is normally very thin, typical are thicknesses around 500nm. This process has some significant advantages against other coating processes for electronic: the liquid is unburnable and not poison, this leads to a high safety for workers the liquid is inert and not electric conductible, also battery cells on the assemblies can be coated the dip coating process is very fast and cost saving compared to the slow and complicated spray processes of the most other materials the very thin fluoropolymer layer can also cover plugs and switches, the still work by pushing their metal contacts through the fluoropolymer layer, no masking required the coating layer is crystal clear and do not affect light systems like LED lamps the coating layer does not affect high frequency assemblies up to 8 GHz the coating layer does not affect the heat sink behavior in significant value the coating layer is very stable and guarantees a protection over the lifetime of the product LEDBoard coated electronic board dipped into liquid Two REM pictures of the thickness of a fluoropolymer coating, average 500nm 3 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 3 Current materials mainly used For the use of coating electronic assemblies these materials are mainly in use: 3M Novec 1700 3M Novec 2702 Acota Certonal 742 Puretecs Purocoat 17/02 UV Cytonix FluoroPel Electrolube FPC Inventec Promosolve UT AGC Sureco Taiwanfluoro TF2100 Daikin OPTOACE All these materials have in common: They are some fluoropolymers (C4 or C6, with 4 or 6 carbon atoms chain length) dissolved in a fluorinated liquid with a low boiling point (<80C) to have a quick evaporation at room temperature. 4 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 4 Technical process 4.1 Manual coating process The complete electronic board is immersed in the coating liquid. After a few seconds waiting time, the electronic board is withdrawed from the coating liquid. The electronic board is hold above the coating liquid until the last drop has dripped. The electronic board is put beside to let it fully dry. The solvent of the coating liquid typically evaporates very quickly so the electronic board can be processed further a few minutes after the coating bath. The evaporated solvent during this process is lost in the environmental air. To reduce solvent losses, users tend to make sure to have coating liquid only in open containers as long as it is absolute necessary. Immediately after use the coating liquid is poured back in the bottle and closed tightly. Drafts, open windows, fans and active air suctions are avoided to minimize the solvent losses. Moving air increases evaporation by a multiple. There is a natural urge among users to reduce solvent losses to a minimum, as solvents are typically rather expensive. 4.2 Automatic coating process To process electronic board coating with fluoropolymers, there are specially designed machines available. These machines can handle the dipping process in fluorinated solvents while be specially designed to not lose liquids and to minimize solvent losses with a cold trap. Electronic boards are typically packed close together in a basket and then be put in the coating machine. The coating machine dips the whole basket with all electronic boards into the coating liquid inside the tank. Then the basket is withdrawed and dried inside the machine. The evaporated solvent from the coating liquid in the tank and the drying electronic boards is recondensed at the cooling zone in the top of the tank (cold trap). Therefore, machine can recycle the majority of the solvent and have only minimal solvent vapor losses. These machines cost money, but are often worth it after a short time because significantly less solvent is used. A machine typically pays off with a production volume of around 600 electronic boards per day. The vast majority of highvolume production uses machines to coat electronic boards. 5 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 4.3 Solvent losses A Manual process: During the manual process, all solvents that evaporate are ultimately released into the environment. Mostly from the drying, coated components and to a smaller extent from the basic evaporation of the coating liquid. When coating manual a typical solvent loss is 3841 Gramm per square meter. B Machine process: The amount of losses for machines is regulated in the 2. BImSchV 3 (5) only for Germany and set to a maximum of 30g/h in average. As all coating dipping machines use cool coating liquid and a cold trap the evaporation level is far below this value. In Germany there is an amount of approximately 50 machines active. In the rest of Europe there might be even more than 100 machines running. All machines are typically designed to have minimal solvent losses. There is a natural urge to do this because, on the one hand, the concentration of the coating liquid can be kept constant better and, on the other hand, solvents are rather expensive and the loss of solvents costs money. Machines offer a good technical opportunity to recondense and reuse the solvents again and again. When coating with a machine a typical solvent loss is 19 Gramm per square meter. We assume the total loss of HFE solvent used for electronic coating per year: ~4 tons for Germany ~1 ton for the rest of the EU 5 Other coating technologies There are many other coating processes and materials for coating electronic assemblies. The most common method is spraying or dispensing solventbased acrylic varnishes. The solvents used for this are all flammable, often toxic and typically have an extremely high GWP. An acrylic varnish is typically processed with a high proportion of solvents; 80% solvent content is the rule. These solvents are completely emitted into the environment in all processes and machines. Example: Coating of one square meter Acrylic: Typical 40m thickness, 80% solvents Leads to 160 milliliter solvent losses Fluoropolymers: Typical 500nm thickness, 98% solvent but mainly recondensed in the machine Leads to 28,5 milliliter solvent losses This shows, that a comparable acrylic process emitts five to six times more solvents in the environment for the same result. Additionally, the most solvents of acrylics have a higher GWP as the HFE solvents used for the fluoropolymer coating. 6 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 6 Advantages of fluorinated solvents and coatings For the liquid HFE solvents: Non flammable Not toxic to human No dangerous goods Zero ozon depletion potential comparatively low global warming potential atmospheric lifespan approximately only 4 years no "forever chemical" no breakdown on persistent chemical when degrading in environmental conditions See also link: https://www.umweltbundesamt.de/sites/default/files/medien/5750/publikationen/2021 0506_texte_362021_abbau_kaeltetreibmittel.pdf For the solid fluoropolymers: Non flammable Not toxic to human No dangerous goods Only very small quantities need to be used The total amount of fluoropolymers in a product is typically very small. To coat an exemplary electronic board, only milligrams of fluoropolymers are used. Example: EUROPAcard Weight of board: 160g Amount of fluoropolymers to coat the whole board: <40mg Percentage of fluoropolymers in end product: 0,025% / 250 ppm 7 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 7 Waste treatment The fluoropolymer coatings are used for electronic boards or electronic assemblies. There are applications in industrial electronics and applications in automotive electronics. About half each. Applications in the area of consumer electronics are rather rare because protective coatings are generally avoided in consumer electronics in order to reduce production costs and because the focus is often not on longevity. This means that electronics coated with fluoropolymers tend to have a very long service life (which is extended by the coating) and are found in commercial and professional areas. Dismantling, repairs and disposal are also typically carried out professionally and commercially, as no private individuals or laypeople come into contact with such products. Electronic components are disposed of as electronic waste. The treatment of electronic waste is already high regulated. Motor vehicles are recycled in a regulated way. Fluoropolymers are not recovered during recycling but are typically not emitted or disposed of in the environment. 8 Using of alternatives As of today, there is no known solvent that dissolves fluoropolymers and redeposits them in functional layers other than HFE solvents. As of today, there are no known alternative coatings that produce an ultrathin, hydrophobic layer that protects electronic components sufficiently well and can still be contacted. In our experience, hydrophobic coatings based on nanoparticles are not suitable for electronics. The typical and most widespread alternative is coating with solventbased acrylic varnish. Coating with acrylic varnish is usually the cheaper option. There are a variety of reasons why in some cases the fluoropolymer coating is preferred over the alternatives: complex assemblies' geometries no masking of plugs and switches is desired or possible light, high frequency or radar applications In any case, fluoropolymers are used consciously because they offer a significant technical advantage. If they didn't do this, the product would naturally be coated with an alternative, cheaper process and material. 9 Market and industry In recent years, a number of companies and experts have emerged in Germany around the fluoropolymer coating process that have further developed and improved this process. There is now a certain amount of knowhow in Germany regarding this special process. In the past, this has already led to exports to Asia (China and Taiwan) and America (mainly Mexico). Smaller companies that produce electronics in particular have an international competitive advantage because the process is very easy to implement. Compared to the coating market in general, the market for electronic coatings is tiny. Furthermore, the proportion of fluoropolymer coatings among all electronic coatings is also small, we estimate around 5%. Puretecs fluoropolymer coating sellings per last 12 months: 137.000 m for production in Germany (~100kg fluoropolymer solids) 40.000 m for production in the rest of EU (~30kg fluoropolymer solids) Active customers using fluoropolymers per last 12 months: 118 customers in Germany 22 customers in the rest of the EU 8 09.08.2023 Usage of PFASmaterials based coatings in electronic boards production Johannes Ballhaus, Puretecs GmbH 10 Derogation needs We see the intention behind the proposal to ban PFAS. Protecting people's health and the environment is also our aim. Nevertheless, we see a comprehensive ban on PFAS as having adverse effects on both. On the one hand, a possible comprehensive ban would also affect the coating of electronics in Europe and thus destroy a comparatively technically advanced industry. On the other hand, if the coating processes were to change to the aforementioned alternatives, advantages would be lost because the alternatives are more dangerous for people and the environment. We do not see the known problems that PFAS have caused in the past, such as accumulation in the soil, for the application of coating electronics. The recycling cycle for electronics is well closed and we only need very small amounts of fluoropolymers to coat huge amounts of electronics. We are therefore calling for an exemption for the coating of electronics to protect this important technology and this important industry, arguing that this use of PFAS is not expected to pose a risk to people or the environment. Johannes Ballhaus 9