For your action: Ongoing survey for socioeconomic assessment of PFAS restriction
EFCTC has launched a stakeholders survey in the context of a Socioeconomic Assessment of the impact of a possible PFAS restriction on the F-gas sector.
The aim of this project
The aim of this project is to collect information to ensure that authorities will have
the complete picture of the F-gas sector when deciding about a possible PFAS restriction.
At this stage, EFCTC is calling upon any interested stakeholder to provide information in the context of this study via the survey.
Both companies and associations can participate. The study and the survey are conducted by the independent consultancy Ricardo Energy & Environment; the data shared in the context of the survey will be covered by an NDA and will be accessible to Ricardo only.
Please note that on the 23 March, EFCTC and Ricardo held a webinar to introduce the survey; the recording is available on the EFCTC YouTube channel.
You can find more background information in the attached presentation.
Frequently Asked Questions on the EFCTC Socioeconomic Assessment of the impact of a possible REACH restriction of PFAS on the F-gases sector
Why is EFCTC doing this study?
5 countries (Denmark, Germany, Norway, Sweden, and the Netherlands) are proposing a broad REACH restriction on the group of substances known as PFAS. According to the latest communications from the authorities, some F-gases fall under the definition of PFAS that will be used in the context of the REACH restriction. The aim of the EFCTC study is to provide important data to the Socio-Economic Analysis Committee (SEAC) in the context of its opinion forming process for this proposed restriction.
EFCTC has submitted detailed information about the science and environmental effects of F-gases as part of the first consultation. However F-gases have not been excluded and more need to be done in order to demonstrate that F-gases should be managed under the F-gas Regulation.
Are you trying to stop/prevent the restriction?
Not at all. The REACH restriction process requires a number of datasets to be generated and considered. EFCTC is conducting this study in order to provide to the authority as much information as possible to demonstrate that F-gases are already successfully managed under the F-gas Regulation.
What are you intending to do with the study? How does the study fit into the REACH restriction process?
EFCTC will submit the full study to the ECHA public consultation on this restriction dossier that will be launched in the second half of 2022. The aim is to provide important data to the Socio-Economic Analysis Committee (SEAC) in the context of its opinion forming process for this proposed restriction.
What are the focus and scope of the study?
The study aims at giving a complete picture of the F-gas industry sector; therefore, our consultant will look at different downstream use sectors that involve the use of F-gases to assess how they would be affected by a REACH restriction. The different sector will be analyzed separately within the assessment.
The geographical scope of the assessment will focus solely on the European Economic Area (EEA).
The substances assessed in the study are the following:
- HFC-125, -134a, -143a, -227ea, -245fa, -365mfc
- HFO-1234yf, -1234ze, -1336mzz
Will the results of the study be shared before they are finalized?
Depending on the development of the study, EFCTC might share important milestones and initial outcomes with other associations and downstream users for feedback.
What are the downside of not participating to the study?
At the present time, the EFCTC study seems to be the only one being conducted on the impact of a possible REACH restriction on F-gases. Participation will allow the collection of sufficient data to ensure a statistically sound outcome. Not submitting a study, for example, the EFCTC study, during the ECHA consultation process due to lack of data could result in a complete ban of F-gases, without the possibility of derogations. The EFCTC study will enable ECHA to build a comprehensive database of information to determine the actions that should be taken.
What would be the expected demand on downstream users/associations?
Our consultant has prepared tailored questionnaires to collect important data from associations/companies. Overall, you will be asked to answer to about 50 questions, and more information has been given during a webinar on 23 March (recording available on EFCTC website). The survey has been launched on 4 April and will close on 15 May 2022.
Information provided in the context of the survey are covered by Non-Disclosure Agreements (NDAs)
signed between the respondent and our consultant; EFCTC and Cefic will have no access to confidential information.
If you are not able to provide a response to all the questions, we appreciate partial submissions as well. You can contact directly the consultant team and/or the EFCTC Secretariat, should you have any questions.