EEB Comments on SEAC draft opinion for D4/D5/D6
We strongly endorse the proposal to restrict D4/D5/D6. The inclusion of D6 under the scope of this restriction will prevent this potential regrettable substitution.
We would also like to support SEAC in its rejection to requests for longer transition periods that have not been substantiated with sufficient reliable data.
We would also like to encourage SEAC to consider the concept of essential uses when assessing requests for derogations and for longer transitional periods. The concept of essential use for PFAS has been developed by Cousin setal following the example of the Montreal Protocol.
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