PFCA restriction report NGO comments

EEB and IPEN welcomes the opportunity to comment on this Restriction Report and thank the German and Swedish authorities for preparing this proposal. We strongly support its recommendation to restrict the manufacturing, use, placing on the market and import of C9-C14 PFCAs, their salts and related substances. We would also like to commend the Dossier Submitters for recommending that the restriction includes recycled material and articles made from recycled materials.

We are, however, extremely concerned that the restriction is not proposed to include “the manufacture of a substance where this occurs as an unintended by-product of the manufacture of fluorochemicals with a carbon chain equal to or shorter than 8 atoms”, as well as the proposed thresholds of PFCAs for mixtures and articles placed on the market. In relation to these concerns and some additional issues, we would like to submit the following information, comments and suggestions.

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