Europaudvalget 2022-23 (2. samling)
EUU Alm.del
Offentligt
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To
Mr. Audun Heggelund
Norway Environment Agency
Mr. Martijn Beekman
National Institute for Public Health and the Environment
Dr. Mandy Lokaj & Mr. Carl Dannenberg
Federal Institute for Occupational Safety and Health (BAuA)
Ms. Jenny Ivarsson
Swedish Chemical Agency
Mr. Toke Winther
Ministry of Environment and Food of Denmark
Brussels, 19 October 2021
Subject: EFCTC Cover note to the submission to the second Stakeholder Consultation on PFAS
Dear Mr. Heggelund, Mr. Beekman, Dr. Lokaj, Mr. Dannenberg, Ms. Ivarsson, Mr. Winther,
On behalf of the European FluoroCarbons Technical Committee (EFCTC)
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– a Sector Group of the European
Chemical Industry Council (Cefic), I would like to share with you additional information regarding our
submission to the Second Stakeholder Consultation on PFAS closed on 17
th
October 2021.
EFCTC has already provided data in the context of the call for evidence in July 2020 and worked to provide
additional information during this second round. It should be noted that the submission of information
should not be considered as an agreement on the inclusion of F-gases in the scope of the proposed REACH
restriction.
Notwithstanding that you are collecting a broad range of information across a large group of fluorinated
products and, at present, the clarity of the scope of your proposal for a REACH restriction is not yet
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EFCTC is comprised of Arkema, Chemours, Daikin, Honeywell and Koura and represents the five major
manufacturers and suppliers of hydrofluorocarbon (HFC) refrigerants and air-conditioning gases in the EU.
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EFCTCRue
Belliard
40, Box 15, B-1040 Brussels
Rue Belliard 40, Box 15, B-1040 Brussels
anc
@cefic.be
www.fluorocarbons.org
EU Transparency Register n° 64879142323-90
 EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren
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defined, we believe that F-gases should not be included within this restriction proposal. As we have
already explained in our submissions, the use and emissions of F-gases are already managed successfully
under the F-gas regulation (Reg. 517/2014) which aims at reducing F-gas emissions by two thirds of 2010
levels by 2030 through a well-established quota system. Furthermore, scientific studies and analyses, that
we have cited, demonstrate that F-gases are not persistent.
As is further confirmed by their REACH registrations, F-gases are not persistent, nor bio-accumulative or
toxic. Most of them break down to non-persistent substances, only a small group produces very low
concentrations of a naturally occurring inert and nonbioaccumulative substance called trifluoroacetic acid
(TFA), which, although persistent, is a naturally occurring, inert and nonbioaccumulative substance.
Rigorous studies show that concentrations of TFA in the environment from the degradation of HFOs do
not present a risk to humans or the environment. These studies and their conclusions have been carefully
evaluated and summarized by the UNEP Environmental Effects (EEAP) and Scientific Assessment Panels
(SAP) to the Montreal Protocol.
More broadly, HFOs and HFCs play a crucial role in the context of the EU Green Deal and EU
decarbonization goals through their efficiency in use, good toxicological profiles, low flammability, and
energy efficiency.
EFCTC remains ready to provide further information to ensure that the data sets on F-gases are as robust
and comprehensive as possible, confirming that they should not fall into the scope of the upcoming
proposed restriction due to their chemical properties and the impacts on use and emissions both now
and, in the future, from the existing regulations.
Yours sincerely,
Nick Campbell
EFCTC Chairman
About EFCTC
The European FluoroCarbons Technical Committee is a Cefic Sector Group that monitors legislation
related to HFCs (hydrofluorocarbons), and HFOs (hydrofluoro-olefins) in the EU and at global level.
Fluorocarbons are used as feedstock, as refrigerants, as solvents and as blowing agents for insulation
plastic foams.
Contact:
EFCTC Chairman:
EFCTC Secretariat:
Dr. Nick Campbell,
[email protected]
Angelica Candido,
[email protected]
Elisa Consoli,
[email protected]
2
EFCTCRue
Belliard
40, Box 15, B-1040 Brussels
Rue Belliard 40, Box 15, B-1040 Brussels
anc
@cefic.be
www.fluorocarbons.org
EU Transparency Register n° 64879142323-90