The Socio-Economic Analysis (SEA) report produced by the Ricardo Group for the ESA was uploaded to the ECHA public consultation platform within the time frame, along with our position statement. The document is comprehensive and analyses all the data provided by ESA members, associated upstream and downstream users, and other industry organisations.
One of the key messages of the SEA is that only 20% of seals that use Fluoropolymers could be replaced by alternatives within the next 12 years. This is primarily because no other materials offer the same sealing capability in a range of applications. Even if alternatives did exist, the approval and research required, not to mention the cost involved to validate a replacement both within the sealing industry and externally, would take more than 12 years. The risk of failure is too high to assume replacements could be found and validated within the timeframe suggested by the PFAS restriction proposal.
If you would like a copy of the ESA SEA report, please contact Mark Neal.
The ECHA work programme for 2024 is expected to be released in November/December and will provide more specific dates for key milestones. It is unlikely that there will be any response to the public consultation or output from the review process before Q2 2024.
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