The German Federal Environmental Agency (Umweltbundesamt – UBA) is currently investigating longer chain perfluorinated carboxylic acids (PFCAs) of chain lengths between C9 and C20 to clarify the need to subject these substances to restriction under REACH (Regulation EC No. 1907/2006). This restriction proposal will also cover so-called precursor substances of the C9-20 PFCAs (for an overview on potential substances that might be covered by this measure, please see this document).
Additionally, information on alternatives, that are suited to substitute these substances in uses and products, will be integrated in the restriction proposal and will define its scope (phase out periods, exemptions). To be able to draft a suited measure and to be able to consider special requirements for single uses right from the beginning of the restriction process, the UBA is hereby initiating a collection of information in the value chains of these substances.
The objective of this survey is to increase the information basis on
- manufactured and imported amounts of the respective substance groups
- manufactured and imported amounts of their potential alternatives
- the type of uses the substances are applied to as well as
- the economic effects that are linked to the use of the substances.
Please note that it is highly important to provide information on all the use cases you know of (also if only small tonnages of a substance is applied) to avoid unintended consequences for market actors when a regulatory measure is implemented. This is especially true for uses that might contribute to a high added value of products or have a high socio economic value due to particular application (e.g. health care or pharmaceuticals).
Uses are also of particular relevance if they are linked to long phase-out periods of substances (for example due to long product development cycles, a long service life or safety related approval processes, that require longer transition periods for the phase out of substances).
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