Arkema Kynar® PVDF
Comments on Annex XV restriction report
Restriction on the manufacture, placing on the market and use of PFAS
Second Submission - Executive summary
Arkema, a PVDF fluoropolymer producer, welcomes the opportunity to share data and information in the context of evolution of the EU restriction proposal on PFAS. A first submission made in June focused on the data sharing on safety during the life cycle including toxicological and ecotoxicological information, emissions along the whole life cycle, end-of-life management, and socio-economic impacts. In its first submission, Arkema recommended that fluoropolymers produced without PFAS polymerization aids should be exempted.
This second submission focus on sharing available information on applications and markets, product properties, existence and viability of alternatives, emissions along the life cycle by application.
Those data are supported by technical references and provided in respect of the scientific approach of Reach regulation that must remain the rule for risk analysis.
Kynar® FSF® PVDF homopolymers and copolymers are produced without the use of PFAS polymerization aids and are used in industrial applications. They are designed for extreme inertness in harsh environments, flame & smoke properties, weather resistance, durability, and ease of processing. They are of strategic importance for European industry and sovereignty as well as the EU Green Deal, the Chips Act, the Net zero industry act and the Sustainable and Smart Mobility Strategy, the EU water protection and management.
10 key markets are described in detail in this answer to the public consultation:
1. The chemical processing industries
Kynar® FSF® PVDF is used in piping, pumps, valves used for transportation of corrosive chemicals within the chemical process industry ensuring a safe and durable functioning of chemical production plants.
2. Oil & Gas transportation
Kynar® FSF® PVDF is used in Oil & Gas flexibles supporting the development of mobile floating units while resisting to external extreme conditions and to aggressive products preventing leakages during the 20 years+ lifetime required by the standard with which the installation should comply.
3. Semi-conductors manufacturing
Kynar® FSF® PVDF is used for ultra-pure water transportation which is an essential and unavoidable element of semi-conductors manufacturing plants. PVDF is a material of choice in this application due to its unparalleled high purity and inertness properties. As of today, only PDVF is compliant with the specific standards set of this application regarding absence of leachable and metallic contaminants.
4. Construction coatings
Kynar® FSF® PVDF is used in architectural metal coatings formulation providing unparalleled protection against weathering, aging, UV and pollution. Due to its long life (more than 50 years and counting) without mechanical degradation or color fading, Kynar® FSF® PVDF construction coatings offer the best durability and product performance.
5. Lithium-Ion Batteries
Kynar® FSF® PVDF is used as cathode binder and separator coatings in Li-Ion batteries. The separator between the cathode and the anode material prevents short circuit while allowing ions movement, ensuring safety of usage during the whole lifetime of the battery. The cathode binder ensures adhesion of conductive material to the metal substrate and thus the electrode integrity during the whole lifetime of the battery. As it is a quite new application, PVDF has been included since the beginning of the Li-Ion battery technology development and design.
6. Water Filtration Membranes
Kynar® FSF® PVDF is used to produce wastewater filtration membranes. PVDF offers specific properties for high-end membranes like superior resistance to the cleaning chemicals used in the wastewater treatments and in terms of efficiency of pathogen/virus removal, guaranteeing a safety of usage during the whole life time of the filtration membrane.
7. Flexible Photovoltaic Cell Manufacturing,
Kynar® FSF® PVDF is used as a film in the multilayer construction of photovoltaic panels. It provides transparency while UV and moisture protection to other components of the panels during the whole lifetime of the panels.
8. Sterile filtration and aseptic processing for the pharmaceutical industries
Kynar® FSF® PVDF is used in many filtration articles within the pharmaceutical industry: for vaccines production, for sterilization of cancer therapies, for syringe filters used for treatments and blood analysis. PVDF is the only material enabling to reach pore size small enough to remove virus efficiently.
9. Wire and Cables
Kynar® FSF® PVDF is widely used as an insulation material, protecting cables from external aggression (mechanical and chemical) and providing flame & smoke resistance. It is a crucial material that complies with safety standard in building construction.
10. Polymer Processing and Recycling Aids
Kynar® FSF® PVDF is used as an additive in polyolefins allowing a lower processing temperature, reducing waste during extrusion and allowing end of life management with recyclability enabled by better processability.
Regarding the End Of Life management, PVDF, as a thermoplastic polymer, provides the advantage to be mechanically recyclable or fully mineralized through incineration in many of the applications described.
For all those applications Kynar® FSF® PVDF has been selected for its unique combination of properties that enables to guarantee the safety and durable performance during the whole life time.
Based on the Scientific and Economic data provided in this answer to the public consultation, as mentioned in Arkema’s preferred option is to support a more segmented approach based on the level of risk of the substance to facilitate the effectiveness and the implementation of the restriction.
In conclusion, within this approach and as stated in Arkema’s first answer to the public consultation, Arkema considers that fluoropolymers produced without PFAS polymerization aids should be exempted. Potential emissions as well as the end of life can be effectively managed through alternatives and appropriate regulations such as the Waste directive, the Landfill directive and the industrial emissions directives.
As an alternative option to the exemption of Kynar® FSF® PVDF, Arkema could support selective sector specific derogations established on the absence of alternative. Based on the information gathered from our customers and downstream users, in many applications no viable alternatives are available or, when considered, would require a strong downgrading of the properties compromise required by the applications and that would be incompatible with the need to guarantee safety and durability in these critical applications for the society.