BELGIUM: The affiliation symbolizing 770,000 European technological know-how companies has known as the proposed “blanket restriction” of all PFAS, regardless of their toxicity and risk profile, disproportionate.
In a new place paper, Orgalim, which signifies corporations spanning the mechanical engineering, electrical engineering and electronics, ICT and metal technologies sectors, states “The proposed normal ban on the generation, use, and sector availability of for each- and polyfluorinated alkyl substances (PFAS) would considerably effects on our industries’ ability to create robust and responsible solutions.”
Orgalim (Organisme de Liaison des Industries Métalliques Européennes) represents 29 countrywide industry associations and 20 European sector associations, forming the EU’s major manufacturing group. In all, the corporations involved produce an annual turnover of €2,906 billion, manufactue a person-3rd of all European exports and present 11.19 million immediate work.
The team insists that Utilizing a blanket PFAS ban would jeopardise the fulfilment of the Inexperienced Offer. Listing goods this kind of as semiconductors, lithium batteries, warmth pumps, significant-temperature seals, specialised refrigeration products, systems for electricity transmission and distribution, Orgalim states: “These goods can only be generated today with the use of PFAS and would not work at all or operate drastically much less competently without the need of it. The existing proposal would consequence in diminished products longevity and a sizeable improve in squander era.”
The place paper is the latest business reaction to a proposed a ban on PFAS substances less than a new definition that would effects thousands of currently utilized products which include virtually all HFC and HFO refrigerants, as nicely as O-rings, packed glands, flat gaskets and other sealing programs utilised in air conditioning and refrigeration programs.
Double regulation
The situation paper recognises that HFO refrigerants have now been identified as an substitute “environmentally-welcoming choice with a smaller global warming potential” for the substitution of high GWP HFCs beneath the F-fuel regulation.
“However, the proposed restriction of PFAS also contains the removal of HFOs, and because they are currently coated by equally laws, it is crucial to stay away from double regulation to guarantee that there will be possibilities still left for refrigerants,” Orgalim suggests. “Therefore, the interface with other rules related to substances assembly the proposed PFAS definition (eg impending revised F-Gas Regulation) should be clarified.”
Derogations
Orgalim suggests that only applications linked with an recognized risk and exactly where options exist need to be restricted and the use of PFAS should continue to be feasible as lengthy as there is no complete-scale availability of suited and technically designed substitutes.
It phone calls for a very long-phrase normal derogation with overview right before expiration of fluoropolymers without having suitable risk and a obviously outlined technique for the software, evaluation and extension of derogationsl, specifically in the situation of a broad restriction on beforehand non-declarable substances.
“The derogations at this time envisaged are insufficient and do not just take into account the relevance of PFAS for a extensive range of uses and ongoing improvements in the technological innovation field,” the assertion says.
It also calls for indefinite derogations for spare sections, refurbished areas, and devices as properly as products and solutions currently put on the industry.
The situation paper can be browse and downloaded listed here.
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