February 22, 2023
The restriction proposed at this stage by the five Member States seems overly broad and should adopt a scientific approach based more on risks to human health and no longer use persistence as the sole criterion.
We understand that, among PFASs, fluorosurfactants are in the “sights” of the authorities. As regards Arkema, the Group has already initiated a process to completely stop using the only fluorosurfactant still present in its manufacturing processes at its Pierre-Bénite site. Thanks to substantial investment in R&D, the site will be in a position to manufacture its fluorinated polymers in Pierre-Bénite without the use of fluorosurfactants by the end of 2024, the same as all its other production sites around the world.
Arkema does not understand notably why fluoropolymers produced without fluorosurfactants are not exempted from the proposed restriction. Arkema's fluoropolymers are considered not to pose risks to human health, have a favorable (eco)toxicological profile, and meet the OECD definition for polymers of low concern. These are high-performance materials, unique in terms of properties and durability, which contribute to a more sustainable society.
Many of the fluoropolymers and low-warming potential fluorogases covered by the restriction at this stage are central to the ecological and energy transition. They are of strategic importance for European industry and sovereignty, in particular for electric vehicle batteries, semiconductor chips, 5G, hydrogen production, the manufacture of industrial safety equipment and medical equipment, water filtration, building insulation, heat pumps and solar energy.
Finally, Arkema reiterates that it is fully committed to its fluorinated polymers and low-warming potential fluorogases businesses which are key to its customers' developments. The Group will take advantage of the opportunity of the public consultation process now underway to provide the necessary data for a scientifically sound decision.