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IN BRIEF: FOCUS ON FEEDSTOCKS USED TO MAKE PRODUCTS HAVING MAJOR SOCIETAL VALUE

29 January 2021

In response to the European Commission public consultation on the ODS Regulation, EFCTC submitted detailed comments on a range of issues including the important use of Ozone Depleting Substances (ODS) as feedstock. EFCTC insists that maintaining the existing measures that allow the use and production of feedstock in the EU is a key requirement for the review. If use or production were to be constrained in the EU, then the downstream products would be imported into the EU.

Ozone depleting substances (ODS) are widely used as feedstocks (intermediates) to produce a wide range of refrigerants, pharmaceuticals, agrochemicals, monomers, polymers and other substances of major societal value. The chemical structures of some ODS allow high yield, resource efficient processes transforming them into non-ODS substances.

Chemical production is highly integrated, with processes designed to optimize raw material utilization and minimize waste products that for example might require destruction. Constraining the use of ODS as feedstock as a minimum could increase waste destruction which only has the same effect as feedstock use, converting ODS to a non-ODS substances. More likely is the loss of some chemical manufacturing from the EU.

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