DIGITALEUROPE Comments on REACH PFOA Restriction Proposal

DIGITALEUROPE, the association representing the digital technology industry in Europe, welcomes the opportunity to comment on the Annex XV Restriction Report: Proposal for a Restriction for Perfluorooctanoic acid (PFOA), PFO salts and PFO-related substances, published on 17 October 2014.

While PFOA is usually not directly contained in electronic products, Fluoropolymers are base plastic materials used in a wide variety of electronic applications. As downstream users of Fluoropolymers, we do not have a direct influence on the upstream process of chemicals used for manufacturing Fluoropolymers. Irrespective of whether long chained perfluorinated substances such as PFOA or their short chained alternatives are used for manufacturing of Fluoropolymers, thermal or other decomposition will highly likely lead to trace contamination with PFOA. While these impurities of PFOA are contained in very low concentrations, the proposed threshold of 2ppb would lead to a de facto restriction of all Fluoropolymers.

For the ICT and consumer electronics industry, the use of Fluoropolymers is key to the functionality of many product applications. Examples include lithium-ion battery chemistry and wire coatings on transformers and in power supplies coated with Fluoropolymers. Fluoropolymers are used as a low-loss material for high frequency applications like communications chips and printed circuit boards. The same is valid for other electronic parts such as electrical switches, electromagnetic solenoid valves, transducers, magnetic separators, electrical insulators and capacitors. Fluoropolymers are also used in structural components of electronic products, such as washers and gaskets; anywhere where heat, electrical isolation and chemical resistance are needed.

For these Fluoropolymer applications there are neither alternatives nor substitutes. The proposal to restrict PFOA and PFOA-related substances at 2 ppb for articles therefore presents a serious concern for our industry.

In the light of the above, DIGITALEUROPE proposes to include in the restriction a derogation for fluoropolymers, thus excluding fluoropolymers from the scope. This is will ensure that (unintended) consequences outside the intended scope will not occur.