Comments for Annex XV restriction report

Substance name: PFNA; PFDA; PFUnDA; PFDoDA; PFTrDA; PFTDA; their salts and precursors

EC Number: 206-801-3; 206-400-3; 218-165-4; 206-203-2; 276-745-2; 206-803-4

CAS Number: 375-95-1; 335-76-2; 2058-94-8; 307-55-1; 72629-94-8; 376-06-7

Scope: Shall not be manufactured, used or placed on the market as substances, as constituents of other substances and in a mixture. Articles or any parts thereof containing one of the substances shall not be placed on the market.

Before you fill in the form, read the Public Consultation Guidance and the specific Information Note
as they explain both the process and the proposal itself.

Link to the Public Consultation Guidance
Link to the Information Note

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All non-confidential comments will be made publicly available once a month during the duration of the public consultation.

The Public Consultation is intended to provide ECHA’s Committees with scientific and technical information to assist them in the development of their opinions. Although other information can be submitted, any abusive comments will not published monthly and only published at the end of the process without any response from the Dossier Submitter or the Rapporteurs.

SECTION I. Personal information
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SECTION II. Organisation
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SECTION III. Non-confidential comments

It is possible to provide both general comments on the Annex XV restriction report subject to this Public Consultation and answers to the specific questions posed. In both cases, it is necessary to provide supporting evidence to allow ECHA’s Committees to take your comments into account. It is important not to leave the submission of any socio-economic information until the public consultation on SEACs opinion but already submit relevant comments at this stage.

  GENERAL COMMENTS
  Select the relevant boxes that cover the content of your comments and provide your non-confidential comments below, (maximum 9 000 characters)
 









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SPECIFIC INFORMATION REQUESTS
  1:

The only confirmed intentional use/import of C9-C14 PFCAs or related substances identified in the restriction report is for semiconductor industry. C9-C14 PFCAs are potential alternatives to PFOA. The proposed restriction would prevent industry switching to C9-C14 PFCAs after the PFOA restriction enters into force.

Are you aware of any other present or future intentional uses either in the EU, or outside the EU for articles imported to the EU? If such uses exist, please provide the following:

  • Description of the use
  • Quantities used and information regarding the potential risks to the environment (e.g. quantified release estimates)
  • Technical and economic information on those applications or uses, for which alternatives are not available and/or the performance of alternatives is not considered adequate. This should include information on potential alternative substances or technologies and justification of why they are not feasible.

The above information would be particularly welcomed from the semiconductor and the cosmetic industries and if a time-limited derogation is necessary.

  * COMPULSORY FIELDS

  2:

According to the restriction report, the proposed thresholds (25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA related substances) allow the continued use of alternatives to C9-C14 PFCAs, e.g. based on ‘C6 chemistry’, where C9-C14 substances may be present as impurities.

Are you aware of uses of other substances (e.g. substances with a carbon chain longer than 14) in the EU or in imported articles, that would be affected by the proposed restriction due to concentrations of impurities of C9-C14 PFCAs that are higher than the proposed thresholds? If such uses exist, please provide the following:

  • Description of the use
  • Quantities present as impurities and related concentrations, and information regarding the potential risks to the environment (e.g. quantified release estimates)
  • Technical and economic information on those applications or uses, for which alternatives are not available and/or the performance of alternatives is not considered adequate. This should include information on potential alternative substances or technologies and justification of why they are not feasible.
  * COMPULSORY FIELDS

  3: The restriction report foresees a derogation for the manufacture of C9-C14 PFCAs, their salts or related substances where these occur as an unintended by-product of the manufacture of fluorochemicals with a carbon chain equal to or shorter than 8 atoms. Please describe technical or economic reasons why this by-product fraction cannot be avoided.
  * COMPULSORY FIELDS

  4: Are C9-C14 PFCAs, their salts or related substances found in recycled materials and at what concentrations? How would the recycling sector be impacted by the proposed restriction?
  * COMPULSORY FIELDS

SECTION IV. Non-confidential attachment

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SECTION V. Confidential Attachment

If needed, attach confidential information below (for example: studies, laboratory tests, additional contact details, business data, etc.). Do not add the same information already provided in the previous sections here. Confidential information will only be used by ECHA, including its Committees, by the Member State competent authorities and by the European Commission.

If you upload a confidential attachment, please justify the reasons for confidentiality of the information in the field below. This will facilitate ECHA’s work if it receives requests for access to documents.

Upload Confidential Attachment:
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