The undersigning organisations would like to provide further comments to strengthen the restriction proposal on the following topics:
-Threshold values. For articles, the proposed threshold values should be replaced by a single value of the order of 1 μg/m2 of extractable substances in scope, or, alternatively 3 g/m2 of extractable substances in scope, or, alternatively 3 ppb. The exact value, however, should be derived by independent experts based on real data and using a transparent methodology. In the following, we explain and justify that such a threshold is both necessary for the effectiveness of the restriction and feasible with validated, broadly available analytical methods. We also refute claims by industry stakeholders that although there are methods that can register concentrations lower than the suggested limit values, they are not applicable to all matrices and cannot be accessed in practice by enforcement authorities.
-Alternatives. Many fluorine-free alternatives have been omitted in the dossier.We provide here (section 2) a list of substances and of cases of practical uses that should be considered.
-Labelling.Articlesandmixturesforclaimedessentialusesbenefittingfromaderogationor a transition period under this restriction should be labelled; this way the purchaser can make an informed choice and proper waste management can be ensured….