Threshold limit for PFOA restriction seems unrealistic in REACH proposal
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A proposed REACH restriction on the use of perfluorooctanoic acid (PFOA) in the EU would effectively prevent the use of all fluoropolymers in products say two electronics trade bodies, according to a report of Chemical Watch on 25 June 2015.

The proposal is submitted to Echa by the German and Norwegian authorities last year. It calls for a restriction on the manufacture, use or placing on the market of PFOA and related substances (linear and branched derivatives) as substances on their own, or as constituents of other substances, in a mixture or articles. In addition, it says articles or any components containing one of the substances in concentrations equal to or greater than 2 ppb of a single substance shall not be placed on the market .

The Japanese Electronics and Information Technology Association said adopting the proposed threshold would be the same as restricting almost all fluoropolymer compounds.

PFOA itself is not directly used in electronic products, while fluoropolymers are base plastic materials for a wide variety of electronic applications, such as communication chips, electrical switches, etc. With no alternatives or substitutes available for the said applications, the proposal to restrict PFOA and PFOA-related substances at 2ppb for articles seems unrealistic.

Other comments suggested to raise the threshold limit may be easier and more cost-effective for both companies and authorities to enforce. It should be set at a level that eliminates the manufacturing, use and placing on the market of long‐chain substances while still allowing manufacturing, use and placing on the market for the essential alternatives.

The next stage in the process will see the Rac and Socio-Economic Analysis Committee (Seac) prepare and adopt opinions on the proposal for further public consultation.

【中文版】

Further information
Germany and Norway propose a restriction on Perfluorooctanoic acid (PFOA), its salts and PFOA- related substances
DIGITALEUROPE Comments on REACH PFOA Restriction Proposal
ANNEX XV PFOA Restriction Report

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