Comments for Annex XV restriction report


undecafluorohexanoic acid (PFHxA), its salts and related substances

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1. Shall not be manufactured, or placed on the market as substances on their own from [date].

2. Shall not, from [date], be used in the production of, or placed on the market in:
(a) another substance, as a constituent;
(b) a mixture;
(c) an article, in a concentration equal to or above x %.

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

Link to the Consultation Guidance
Link to the Information Note

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The 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.

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 SECTION I. Personal information

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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 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 consultation on SEACs opinion but already submit relevant comments at this stage.

General Comments

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Please provide your general comments in the box below

 Specific Information Requests
1:

Additional uses:

In addition to the uses described in the Annex XV dossier, are you aware of any other present or future intentional uses, or uses where impurities are above the concentration limit proposed? The question concerns both uses in the EU and outside the EU involving imports to the EU. If such uses exist, please provide the following:

  1. Description of the use,
  2. Quantities used and information regarding the potential risks to the environment (e.g. quantified release estimates)

* Compulsory Fields



2:

Emissions of PFHxA from polymers:

PFHxA, its salts and its related substances are emitted from side chain fluorinated polymers. Such emission may also take place from fluoropolymers. The available data describing these emissions is, however, limited. Please provide any additional data you may have on the extent of these emissions.

* Compulsory Fields



3:

Textile sector:

The majority of clothing used in the EU is imported from outside the EU. Please, provide any additional data you may have on:

  • the share of imported clothing (outdoor and occupational clothing) that is treated with side-chain fluorinated polymers .
  • the share if imported clothing treated with fluoropolymers (C6-chemistry integrated in the polymer backbone)
  • the share of imported clothing treated with PFHxA, its salts and/or related substances.
  • the content of extractable perfluorinated substances and applied fluoropolymers in treated textiles.

* Compulsory Fields



4:

Coatings:

Please provide any data you may have on tonnages used in coatings and for the release of PFHxA, its salts and/or related substances from coated building and construction materials.

* Compulsory Fields



5:

Fire-fighting foams (all relevant sectors, including defence sector):

a) Have you already shifted from PFHxA, its salts and/or related substances to fluorine-free foams or are you planning to shift to those alternative foams?

  • If yes:
    • In which area did you or are you planning to shift to fluorine-free foams (e.g.: seagoing units, storage of fuel)?
    • How long did the transition to fluorine-free foams take you or how long will it approximately take to perform the transition?
    • What are/were the challenges when performing such a transition? E.g., when using the same equipment, are the residues of PFHxA, its salts and/or related substances in the equipment posing a technical challenge in relation to the concentration limit proposed?
  • If no:
    • Please, specify whether you have moved from PFHxA, its salts and/or related substances to a foam containing other fluorinated substances.
    • Please, provide information on the volumes and value of the stocks you may have on fluorinated foams in general and more specifically on foams containing PFHxA, its salts and/or related substances.
    • Please, provide information on the volumes of fire-fighting foams containing PFHxA, its salts and/or related substances currently in use in your equipment? Please, provide any information on the handling, release mitigation and waste management instructions relevant for estimating the releases and evaluating the socio-economic impacts.
    • Why did you decide not to shift to fluorine-free foams or, more specifically, to foams free of PFHxA, its salts and/or related substances?
    • What changes are necessary to allow the transition to fluorine-free foams from PFHxA, its salts/related substances? Are you already taking measures to achieve such changes? How long will it take until respective measures are in place to allow a transition to fluorine-free foams?

b) Hand-held fire extinguishers: please, provide information on the volumes and concentrations of PFHxA, its salts or related substances you use in the extinguishers, the use sectors using extinguishers containing these substances, current handling, release mitigation and waste management instructions, and any other information which would be relevant for estimating the exposures and the socio-economic impacts of the proposed restriction?

c) Are you using aqueous film-forming foams (AFFF) containing PFHxA, its salts and/or related substances for training purposes? If yes, please specify why.

d) Are you using AFFF containing PFHxA, its salts and/or related substances for testing purposes? If yes, please specify why.

* Compulsory Fields



6:

Other uses (cleaning, cosmetics, waterproofing agents, polishing products, floor waxes, food contact materials, etc.) including uses in consumer products:

Please provide any information you may hold on tonnages used of these mixtures and of the identity of the substances (within the scope of this restriction and/or any fluorinated substance).

* Compulsory Fields



7: Are you aware of any alternative fluorine-free substances or technologies for the uses of PFHxA, its salts and related substances?

* Compulsory Fields



8:

For uses where substitution is regarded as being impossible:

  • What is the use?
  • What are the main obstacles to substitution?
  • Please describe the consequences that would result from the proposed restriction and provide information about the costs associated to these consequences.

* Compulsory Fields



9:

For uses where substitution is possible now, or uses where substitution is not possible now, but it is expected to become possible within a short to medium timeframe:

  • What is the use?
  • What transitional period would be needed for this use?
  • Please describe the technical and economic consequences that would result from the proposed restriction if the transitional period were as requested, and provide information about the costs associated to these consequences.
  • What would be the consequences of a shorter transitional period? What would be the costs associated to that?
  • Would investments to enable new processes etc. be needed? If so, please provide information about the costs of these investments.

* Compulsory Fields



10:

For uses where substitution would be possible but is expected to lead to a lower quality of products or lower performance:

  • What is the use?
  • Please describe the impacts on the quality/performance of the products.
  • If possible, please provide an estimate of the economic impacts that could be expected on an annual basis.

Uses where we would in particular need the above information in relation to substitution:

  • Performance of fluorinated polymers and fluoropolymers within the scope of the proposal, compared to fluorine-free alternatives in various uses of these polymers. What are the cost implications if substitution is required?
  • Performance loss of textiles or membranes in case of substitution to fluorine-free alternatives. What would be the impacts of substitution in non-woven textiles used in the automotive and aerospace sectors, medical textiles, textiles for worker protection and membranes for treatment of effluents?

* Compulsory Fields



11:

PFAS-based alternatives:

Previously, the PFOA restriction led to the replacement of the 8:2 FTOH technology by 6:2 FTOH. Are you aware of the usability of alternative fluorotelomer substances (e.g. 4:2 FTOH, etc.) or other fluorinated substances (e.g. perfluoroalkyl ether carboxylic acids) in the different processes that now rely on 6:2 FTOH?

* Compulsory Fields



12:

Costs

  • If for your use/sector the Dossier Submitter has provided a concrete cost assessment, do you agree with the assumptions and costs used? If not, please provide additional data and evidence to support it.
  • The Dossier Submitter proposes annual reporting on the use of PFHxA, its salts and PFHxA-related substances in the production of personal protective equipment (PPE), non-woven medical textiles and impregnation agents (see paragraph 10 of the proposal entry) and the quantities and substitution efforts for fire-fighting foams that contain PFHxA, its salts and PFHxA-related substances (paragraph 12 of the proposal entry). Are there costs associated with that reporting requirement?

* Compulsory Fields



13:

Analytical methods

Are you aware of a method for chemical analysis of PFHxA, its salts and related substances present in a matrix relevant for the restriction proposal? Do you develop or intend to develop such a method?

* Compulsory Fields



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