WEBVTT 1 00:00:00.296 --> 00:00:02.017 Safer Chemicals Podcast. 2 00:00:02.737 --> 00:00:04.858 Sound science on harmful chemicals. 3 00:00:11.421 --> 00:00:11.621 Hello, 4 00:00:11.921 --> 00:00:12.461 I'm your host, 5 00:00:12.561 --> 00:00:13.102 Adam Elwan, 6 00:00:13.222 --> 00:00:21.125 and today we're focusing most of the episode of the Safer Chemicals Podcast to unpacking our Risk Assessment Committee's opinion on restricting PFAS. 7 00:00:21.906 --> 00:00:22.926 We'll be speaking with the Chair, 8 00:00:23.126 --> 00:00:23.987 Roberto Scazzola, 9 00:00:24.227 --> 00:00:27.128 about what the opinion concludes and what it means going forward. 10 00:00:28.556 --> 00:00:33.820 The Committee for Socio-Economic Analysis has also agreed on its draft opinion during their latest meeting. 11 00:00:34.981 --> 00:00:37.704 The opinion has not yet been formally adopted and a 12 00:00:38.044 --> 00:00:39.865 60-day consultation will now start. 13 00:00:40.766 --> 00:00:42.027 We'll be joined by Maria Otati, 14 00:00:42.067 --> 00:00:42.768 the Committee Chair, 15 00:00:42.988 --> 00:00:47.872 to explore the key points of the draft and what information the Committee is looking for during the consultation. 16 00:00:48.973 --> 00:00:50.915 We'll also briefly cover two other topics, 17 00:00:51.095 --> 00:00:57.360 the harmonised classification of cannabidiol and the latest developments on the restriction proposal for chromium-6 substances. 18 00:00:58.476 --> 00:00:58.596 So, 19 00:00:58.876 --> 00:00:59.256 Roberto, 20 00:00:59.417 --> 00:00:59.697 Maria, 21 00:00:59.937 --> 00:01:00.837 thank you both for joining us. 22 00:01:01.698 --> 00:01:02.438 Pleasure to join you, 23 00:01:02.478 --> 00:01:02.678 Adam. 24 00:01:03.059 --> 00:01:04.179 Absolute pleasure. 25 00:01:04.259 --> 00:01:05.040 Always good to have you. 26 00:01:05.500 --> 00:01:05.680 Now, 27 00:01:05.940 --> 00:01:06.561 for our listeners, 28 00:01:06.641 --> 00:01:10.803 I'm sure you've all heard about the wide uses of PFAS in things like cookware, 29 00:01:11.023 --> 00:01:11.923 waterproof jackets, 30 00:01:12.004 --> 00:01:12.824 and food packaging. 31 00:01:13.384 --> 00:01:14.245 In this episode, 32 00:01:14.365 --> 00:01:18.487 we explain why the Risk Assessment Committee considers their very persistent nature, 33 00:01:18.807 --> 00:01:20.808 combined with properties such as mobility, 34 00:01:21.309 --> 00:01:22.269 bioaccumulation, 35 00:01:22.449 --> 00:01:24.350 and long-range environmental transport, 36 00:01:24.691 --> 00:01:27.172 to pose a concern for both human health and the environment. 37 00:01:28.044 --> 00:01:31.227 We'll walk you through the key points of the opinion step by step with Roberto. 38 00:01:32.087 --> 00:01:35.550 So let's kick things off by talking about the hazards of PFAS. 39 00:01:35.991 --> 00:01:39.714 The committee points to persistence as the kind of big driver for action, 40 00:01:39.954 --> 00:01:42.897 even though toxicity does vary among different PFAS. 41 00:01:43.597 --> 00:01:44.498 So why persistence? 42 00:01:44.558 --> 00:01:45.319 Why on its own? 43 00:01:45.679 --> 00:01:48.721 Why is it such a powerful reason to regulate these substances? 44 00:01:49.842 --> 00:01:50.483 If you allow me, 45 00:01:50.583 --> 00:01:50.803 Adam, 46 00:01:50.843 --> 00:01:55.287 I would like first to express my big thanks to the team of people for this big achievement. 47 00:01:55.427 --> 00:01:56.328 I think this is a... 48 00:01:56.688 --> 00:01:58.289 result of the work of rapporteurs, 49 00:01:58.390 --> 00:01:59.611 members and stakeholders. 50 00:01:59.612 --> 00:02:01.993 So we all worked together to make this possible. 51 00:02:02.353 --> 00:02:04.375 It was about three years of work for RAC. 52 00:02:04.995 --> 00:02:05.476 And finally, 53 00:02:05.516 --> 00:02:07.497 we reached the adoption of the RAC opinion. 54 00:02:07.537 --> 00:02:09.419 So that's clearly a great achievement. 55 00:02:09.799 --> 00:02:10.100 However, 56 00:02:10.140 --> 00:02:11.281 this is only half of the work, 57 00:02:11.381 --> 00:02:11.581 right, 58 00:02:11.641 --> 00:02:11.901 Maria? 59 00:02:12.582 --> 00:02:13.062 Exactly. 60 00:02:13.082 --> 00:02:15.144 And I would like to second the thanks that 61 00:02:15.484 --> 00:02:21.590 Roberto has made to all these parties and most especially to the rapporteurs who did a huge amount of work in both committees. 62 00:02:22.570 --> 00:02:23.511 So why we did so? 63 00:02:24.608 --> 00:02:28.090 Good to remind that we had five countries submitting a restriction proposal. 64 00:02:28.190 --> 00:02:28.870 And the main reason, 65 00:02:28.910 --> 00:02:29.650 as you have mentioned, 66 00:02:29.651 --> 00:02:32.431 is the very persistent properties of PFAS. 67 00:02:32.812 --> 00:02:33.812 So what does it mean? 68 00:02:33.972 --> 00:02:35.833 Once the PFAS reach into the environment, 69 00:02:35.834 --> 00:02:36.933 they stay there for a very, 70 00:02:37.033 --> 00:02:38.054 very long time. 71 00:02:38.794 --> 00:02:39.414 And in addition, 72 00:02:39.454 --> 00:02:45.477 there are also other hazards that result in significant concern for human health and the environment. 73 00:02:46.017 --> 00:02:46.497 In addition, 74 00:02:46.557 --> 00:02:48.098 many studies found that PFAS, 75 00:02:48.558 --> 00:02:49.899 once it is in the environment, 76 00:02:49.979 --> 00:02:52.420 can really interact with different matrices. 77 00:02:53.140 --> 00:02:56.402 even reaching the blood of workers and growing stock over time. 78 00:02:56.922 --> 00:03:02.726 This is also probably the reason why the five countries started in its first place this specific restriction dossier. 79 00:03:03.486 --> 00:03:03.666 Right, 80 00:03:03.726 --> 00:03:03.946 okay. 81 00:03:04.166 --> 00:03:06.468 And with such a broad and persistent group of chemicals, 82 00:03:06.528 --> 00:03:10.810 it makes sense that the definition of kind of what counts as a PFAS becomes incredibly important, 83 00:03:11.530 --> 00:03:12.991 which actually brings us to the next point. 84 00:03:13.031 --> 00:03:18.314 So the committee also supports using the OECD definition when grouping PFAS. 85 00:03:18.935 --> 00:03:21.476 That's the one that captures any chemical with at least 86 00:03:21.836 --> 00:03:25.678 one fully fluorinated CF2 or CF3 group. 87 00:03:26.158 --> 00:03:29.819 So what does using such a broad definition actually mean in practice, 88 00:03:30.380 --> 00:03:33.381 especially for companies trying to stay compliant across the EU? 89 00:03:34.521 --> 00:03:36.302 That's probably the most important point. 90 00:03:36.382 --> 00:03:38.103 Substance identity is fundamental. 91 00:03:38.403 --> 00:03:43.565 All relevant actors must understand what is in the scope of the restriction and what is not. 92 00:03:44.166 --> 00:03:49.948 This is really a grouping approach so that one harmful PFAS is not substituted by another one. 93 00:03:50.088 --> 00:03:51.309 that is slightly different, 94 00:03:51.389 --> 00:03:54.551 but displays actually the same as Ardos property. 95 00:03:55.671 --> 00:04:04.336 Perhaps to mention that the dossier submitter had in mind also to exclude specific subgroups related to their possible degradability. 96 00:04:04.876 --> 00:04:05.597 Unfortunately, 97 00:04:05.797 --> 00:04:08.158 RAC didn't find enough evidence to support this. 98 00:04:08.298 --> 00:04:12.741 So we stick basically to the OECD broad definition for this case. 99 00:04:14.241 --> 00:04:16.142 Once you define PFAS this broadly, 100 00:04:16.203 --> 00:04:17.643 the next question becomes, 101 00:04:17.783 --> 00:04:18.684 how do you treat them? 102 00:04:18.988 --> 00:04:20.569 from a risk management perspective. 103 00:04:20.970 --> 00:04:21.190 Here, 104 00:04:21.310 --> 00:04:24.893 the committee is proposing to treat them as non-threshold substances, 105 00:04:24.953 --> 00:04:26.494 so similar to persistent, 106 00:04:26.754 --> 00:04:27.555 bioaccumulative, 107 00:04:27.675 --> 00:04:28.596 and very persistent, 108 00:04:28.956 --> 00:04:31.038 and very bioaccumulative substances. 109 00:04:31.378 --> 00:04:32.739 So in simple terms, 110 00:04:32.940 --> 00:04:36.362 non-threshold means that there's no safe level of exposure, 111 00:04:36.843 --> 00:04:39.045 and any release is considered potentially harmful. 112 00:04:39.625 --> 00:04:43.068 What does that mean in practice when we talk about acceptable exposure levels? 113 00:04:44.169 --> 00:04:47.792 That's a scientific concept that is based on the adverse effects. 114 00:04:47.952 --> 00:04:50.798 irrespective of the concentration of specific chemicals. 115 00:04:51.339 --> 00:04:56.329 So in a way you can say there is no safe concentration once it is released into the environment. 116 00:04:56.509 --> 00:04:57.451 In such a way, 117 00:04:58.073 --> 00:04:58.734 any release, 118 00:04:58.914 --> 00:04:59.536 any emission... 119 00:05:00.020 --> 00:05:01.720 could mean actually that there is a risk. 120 00:05:02.881 --> 00:05:09.163 This was also proposed by the dossier submitter and RAC basically agreed with this specific approach. 121 00:05:09.343 --> 00:05:10.143 And as you mentioned, 122 00:05:10.144 --> 00:05:16.865 it's something that RAC has been used in other dossiers related to persistent bioaccumulative and toxic substances. 123 00:05:17.785 --> 00:05:19.746 There is also another aspect is the fact that, 124 00:05:20.486 --> 00:05:20.906 however, 125 00:05:21.266 --> 00:05:24.007 the greater the amount of emissions into the environment, 126 00:05:24.067 --> 00:05:28.368 also the greater is the risk because the stock into the environment will continue to increase. 127 00:05:28.648 --> 00:05:31.849 So there is also this dimension that has been considered by RAC. 128 00:05:32.490 --> 00:05:32.610 So, 129 00:05:33.050 --> 00:05:33.450 of course, 130 00:05:33.550 --> 00:05:37.632 this is the purely risk assessment scientific approach. 131 00:05:38.172 --> 00:05:40.993 And we acknowledge that the decision maker or SEC, 132 00:05:41.033 --> 00:05:47.576 they could also consider other elements that not necessarily linked only to the risk related to the release of a substance. 133 00:05:49.176 --> 00:05:49.336 Right. 134 00:05:49.537 --> 00:05:53.598 At this perspective is important because it does put all PFAS under a, 135 00:05:54.078 --> 00:05:56.800 or let's say PFAS uses under a much brighter spotlight. 136 00:05:56.820 --> 00:05:57.820 So even those where... 137 00:05:58.308 --> 00:05:58.548 You know, 138 00:05:58.568 --> 00:06:01.149 toxicity or bioaccumulation might be less clear, 139 00:06:01.869 --> 00:06:04.230 which actually brings us to fluoropolymers. 140 00:06:04.391 --> 00:06:10.573 So the committee recognizes that fluoropolymers have limited evidence of bioaccumulation and ecotoxicity, 141 00:06:10.973 --> 00:06:14.155 yet they still fall within scope of the restriction proposal. 142 00:06:14.635 --> 00:06:15.175 So firstly, 143 00:06:15.435 --> 00:06:17.216 what exactly are fluoropolymers? 144 00:06:17.236 --> 00:06:18.156 Let's start with the basics. 145 00:06:18.216 --> 00:06:21.998 And what made the committee conclude that they're part of the broader PFAS restriction? 146 00:06:23.038 --> 00:06:27.040 Fluoropolymers are actually a plastic made from monomers that contain this strong 147 00:06:27.260 --> 00:06:28.561 carbon-fluorine bonds. 148 00:06:28.641 --> 00:06:30.601 So they make them extremely stable, 149 00:06:31.122 --> 00:06:32.902 also resistant to heat and chemicals. 150 00:06:32.962 --> 00:06:38.345 So all very good properties that are normally looked at when you engineer actually a product. 151 00:06:39.265 --> 00:06:41.486 There are a lot of different kinds of fluoropolymers. 152 00:06:41.526 --> 00:06:44.947 Perhaps the most well-known is polytetrafluoroethylene. 153 00:06:45.007 --> 00:06:45.908 Definitely know that one. 154 00:06:45.928 --> 00:06:46.068 Yeah. 155 00:06:46.828 --> 00:06:47.568 My favorite. 156 00:06:48.589 --> 00:06:48.889 Probably, 157 00:06:48.949 --> 00:06:49.209 you know, 158 00:06:49.249 --> 00:06:51.230 it's commercial name we will not mention today, 159 00:06:51.350 --> 00:06:54.811 but it's used widely in cookware and other actually uses. 160 00:06:55.171 --> 00:06:56.732 So it's true that fluoropolymers 161 00:06:56.892 --> 00:06:57.713 are persistent, 162 00:06:58.273 --> 00:07:01.735 but it's also true they are generally not mobile or bioaccumulative, 163 00:07:01.835 --> 00:07:03.096 as you have mentioned earlier. 164 00:07:04.417 --> 00:07:09.040 Most of the concerns are related to the emissions once they are produced. 165 00:07:09.140 --> 00:07:11.082 So in the production of fluoropolymers, 166 00:07:11.322 --> 00:07:12.783 other PFAS are emitted. 167 00:07:13.343 --> 00:07:16.885 There are also concerns related to the waste stage of fluoropolymers. 168 00:07:16.966 --> 00:07:17.446 For instance, 169 00:07:17.466 --> 00:07:19.347 when you dispose them via incineration, 170 00:07:19.687 --> 00:07:23.650 you can produce additional PFAS that can be volatile or non-volatile, 171 00:07:23.970 --> 00:07:26.512 or you can even have emission of micro and nano size. 172 00:07:26.632 --> 00:07:27.693 polymer particles. 173 00:07:27.933 --> 00:07:31.394 So RAC assesses this as sufficient ground for concern to act. 174 00:07:32.675 --> 00:07:32.855 Right. 175 00:07:32.856 --> 00:07:38.538 So even though fluoropolymers themselves may not show the same toxicity or mobility as other PFAS, 176 00:07:39.038 --> 00:07:41.279 their life cycle still creates PFAS emissions. 177 00:07:41.339 --> 00:07:42.540 So during production, 178 00:07:42.760 --> 00:07:43.020 use, 179 00:07:43.200 --> 00:07:44.081 and from what I hear, 180 00:07:44.121 --> 00:07:45.321 especially during disposal. 181 00:07:45.781 --> 00:07:46.902 And that's really the key here. 182 00:07:47.002 --> 00:07:48.983 So the concern isn't just the polymer, 183 00:07:49.103 --> 00:07:50.784 but everything that comes with it. 184 00:07:50.785 --> 00:07:51.064 Indeed. 185 00:07:51.364 --> 00:07:51.504 Well, 186 00:07:51.644 --> 00:07:53.225 let's move on to volatile PFAS, 187 00:07:53.365 --> 00:07:54.485 like fluorinated gases. 188 00:07:54.646 --> 00:07:56.586 These can easily evaporate into the air, 189 00:07:56.807 --> 00:07:59.168 and they're used in things like refrigerators. 190 00:07:59.428 --> 00:08:01.649 I guess the most common example that people can relate to. 191 00:08:02.129 --> 00:08:05.030 The committee calls them very persistent and very mobile, 192 00:08:05.250 --> 00:08:08.392 with global warming potential and long-range transport. 193 00:08:08.792 --> 00:08:11.753 And their degradation increases trifluoroacetic acid, 194 00:08:11.854 --> 00:08:12.394 or TFA, 195 00:08:12.514 --> 00:08:13.374 levels globally. 196 00:08:13.874 --> 00:08:16.676 Can you tell us more about the issue with fluorinated gases? 197 00:08:16.776 --> 00:08:16.936 How? 198 00:08:17.236 --> 00:08:21.257 well understood are the environmental and health impacts of rising TFA levels, 199 00:08:21.597 --> 00:08:22.978 and what are the biggest knowledge gaps? 200 00:08:23.978 --> 00:08:24.138 Well, 201 00:08:24.258 --> 00:08:25.038 some PFASs, 202 00:08:25.058 --> 00:08:26.059 as you have mentioned, 203 00:08:26.079 --> 00:08:26.899 are volatile, 204 00:08:26.939 --> 00:08:28.619 so especially fluorinated gases. 205 00:08:28.679 --> 00:08:29.880 So they can evaporate, 206 00:08:30.020 --> 00:08:31.100 drift with the wind, 207 00:08:31.300 --> 00:08:34.241 and also contribute to the widespread environmental pollution, 208 00:08:34.641 --> 00:08:36.222 even to very remote areas, 209 00:08:36.302 --> 00:08:36.842 mountains, 210 00:08:36.902 --> 00:08:37.762 or even the arctic. 211 00:08:38.482 --> 00:08:42.583 So fluorinated gases are also the major contributors to PFAS submissions, 212 00:08:42.803 --> 00:08:43.524 as you've mentioned, 213 00:08:43.544 --> 00:08:44.764 because they have... 214 00:08:45.084 --> 00:08:45.404 uses, 215 00:08:45.444 --> 00:08:47.105 they can actually result in high emissions. 216 00:08:47.205 --> 00:08:51.046 Can you imagine when a refrigerator actually leaks a fluorinated gas, 217 00:08:51.086 --> 00:08:53.726 so you will have immediate release into the environment. 218 00:08:55.207 --> 00:08:56.567 So they're found in refrigerants, 219 00:08:56.667 --> 00:08:57.527 cooling systems, 220 00:08:57.587 --> 00:08:58.648 but also electronics. 221 00:08:59.248 --> 00:08:59.968 The concerns, 222 00:09:00.008 --> 00:09:00.788 as you've mentioned, 223 00:09:01.048 --> 00:09:02.849 is that they are very persistent, 224 00:09:03.029 --> 00:09:03.849 very mobile, 225 00:09:03.969 --> 00:09:05.910 and some have global warming potential. 226 00:09:05.970 --> 00:09:09.811 So they can increase actually the effect of climate change, 227 00:09:09.951 --> 00:09:11.671 but also long range transport. 228 00:09:11.672 --> 00:09:14.552 So you can find them very far away from the point. 229 00:09:14.712 --> 00:09:15.272 of emission, 230 00:09:15.833 --> 00:09:19.155 even if the committee has acknowledged there are some exceptions. 231 00:09:19.795 --> 00:09:28.760 What is also quite important is that many of the fluorinated gases can degrade and break down into other PFASs such as TFA. 232 00:09:29.681 --> 00:09:33.663 And this substance is currently under scrutiny by RAC in a different process. 233 00:09:33.763 --> 00:09:37.225 So they are looking into specific hazards. 234 00:09:37.405 --> 00:09:39.626 And probably by the end of this year, 235 00:09:39.666 --> 00:09:41.828 there will be more information related to this point. 236 00:09:42.108 --> 00:09:42.508 you 237 00:09:42.788 --> 00:09:43.869 There are some exceptions. 238 00:09:43.990 --> 00:09:45.411 This has been mentioned in the opinion. 239 00:09:45.832 --> 00:09:46.212 However, 240 00:09:46.973 --> 00:09:52.180 all the concerns that I've mentioned earlier have been sufficient to include this category in the scope of this restriction. 241 00:09:53.407 --> 00:09:57.569 The committee has also been calculating the PFAS volumes and related emissions. 242 00:09:58.029 --> 00:10:00.330 Can you tell more about the committee's conclusions on those? 243 00:10:00.530 --> 00:10:04.772 Does this also include the eight new sectors that were not assessed in detail by the committee? 244 00:10:05.653 --> 00:10:05.773 Yeah, 245 00:10:05.993 --> 00:10:12.075 this is a fundamental step to identify the most relevant sectors where PFAS are used, 246 00:10:12.135 --> 00:10:14.436 both in terms of volumes and emissions. 247 00:10:14.977 --> 00:10:16.958 So RAC has developed its own approach, 248 00:10:17.198 --> 00:10:20.059 partially modifying what the dosage submitter has proposed. 249 00:10:20.415 --> 00:10:24.657 The focus was on the original 14 sectors plus the PFAS manufacturing. 250 00:10:26.077 --> 00:10:27.218 So what are the results? 251 00:10:27.678 --> 00:10:29.739 Is that based on the available information, 252 00:10:30.479 --> 00:10:39.423 a total volume of about 270,000 tons of PFAS have been estimated to be in use in the European Economic Area in 2020. 253 00:10:40.023 --> 00:10:42.724 And the top three uses were what we call TULAC, 254 00:10:42.804 --> 00:10:43.885 so textile, 255 00:10:44.005 --> 00:10:44.585 upholstery, 256 00:10:44.845 --> 00:10:46.426 leather and similar uses, 257 00:10:46.606 --> 00:10:48.467 fluorinated gases and transport. 258 00:10:49.103 --> 00:10:51.645 RAC also estimated the emissions. 259 00:10:52.706 --> 00:10:53.006 However, 260 00:10:53.066 --> 00:10:55.288 there is a different degree of certainty about this, 261 00:10:55.328 --> 00:10:57.069 and we will comment on this in a moment. 262 00:10:57.510 --> 00:10:59.832 And the top few uses are basically the same. 263 00:11:00.532 --> 00:11:09.359 I should also mention that RAC could not assess in detail the eight new sectors that have been added in the final revision of the background document by the dossier submitter. 264 00:11:09.820 --> 00:11:10.220 However, 265 00:11:10.600 --> 00:11:18.667 RAC mentioned the estimation provided by the dossier submitter and provided them to the decision maker in a way that they can also consider them. 266 00:11:18.907 --> 00:11:20.447 if any action will be taken on them. 267 00:11:21.928 --> 00:11:22.108 Right. 268 00:11:22.148 --> 00:11:22.348 Okay. 269 00:11:22.468 --> 00:11:23.348 Thanks for clarifying that. 270 00:11:23.888 --> 00:11:24.089 Now, 271 00:11:24.529 --> 00:11:25.109 looking ahead, 272 00:11:25.389 --> 00:11:27.850 how effective could this restriction actually be? 273 00:11:28.190 --> 00:11:31.351 A full ban would obviously reduce PFAS risks the most, 274 00:11:31.771 --> 00:11:36.512 but restrictions always involve balancing the risk reduction with socioeconomic aspects. 275 00:11:37.192 --> 00:11:37.352 Now, 276 00:11:37.492 --> 00:11:39.473 the committee supports a broad restriction, 277 00:11:39.693 --> 00:11:42.474 but also gives guidance if derogations are considered. 278 00:11:42.514 --> 00:11:43.754 Can you walk us through that? 279 00:11:44.695 --> 00:11:44.835 Well, 280 00:11:44.875 --> 00:11:45.995 from a risk reduction, 281 00:11:46.443 --> 00:11:47.844 A restriction on manufacture, 282 00:11:48.044 --> 00:11:53.546 use and placing on the market of PFAS is the most effective measure because being non-threshold substance, 283 00:11:54.086 --> 00:11:55.467 the more you reduce emissions, 284 00:11:55.607 --> 00:11:58.068 the lower will be actually the relevant risk. 285 00:11:58.869 --> 00:12:04.451 So therefore the proposed derogations were normally not supported by the committee with a few exceptions, 286 00:12:04.531 --> 00:12:05.112 for instance, 287 00:12:05.113 --> 00:12:07.533 the protective equipment where the, 288 00:12:08.553 --> 00:12:08.833 let's say, 289 00:12:08.913 --> 00:12:12.535 restriction in the use of PFAS could actually lower the performance and expose 290 00:12:12.875 --> 00:12:16.817 actually the user of those equipment to significant health and safety risks. 291 00:12:17.297 --> 00:12:22.979 So a full restriction could definitely avoid an important quantity of PFAS emitted. 292 00:12:22.999 --> 00:12:26.581 The committee estimated in the order of a million of tons in a period of 30 years, 293 00:12:26.582 --> 00:12:29.022 so very high actually volumes, 294 00:12:29.182 --> 00:12:29.542 despite, 295 00:12:29.543 --> 00:12:29.902 of course, 296 00:12:29.903 --> 00:12:32.023 the uncertainties that we already mentioned. 297 00:12:32.523 --> 00:12:42.407 The committee recommended strongly to input actually additional risk management measures that will actually help reducing and minimize the emissions into the environment. 298 00:12:42.767 --> 00:12:47.088 And this can be achieved through supply chain communication on PFAS uses, 299 00:12:47.628 --> 00:12:53.210 clear consumer labeling for consumer about safe use and proper disposal of waste, 300 00:12:53.710 --> 00:13:00.672 but also site-specific PFAS management plans where information is provided about the use of those products, 301 00:13:00.872 --> 00:13:01.833 emission monitoring, 302 00:13:02.053 --> 00:13:03.613 including also reporting to ECHA. 303 00:13:04.674 --> 00:13:05.914 So listening to all this, 304 00:13:06.054 --> 00:13:09.175 it's kind of clear that even the most ambitious restriction And. 305 00:13:09.667 --> 00:13:11.989 only works if the rules can actually be enforced, 306 00:13:12.109 --> 00:13:12.309 right, 307 00:13:12.349 --> 00:13:12.849 on the ground. 308 00:13:13.410 --> 00:13:15.551 And that nicely bridges us to enforcement, 309 00:13:15.571 --> 00:13:22.076 because even the best designed restriction depends on whether it can be enforced consistently across all EU countries. 310 00:13:22.096 --> 00:13:25.178 So what does the committee say about the enforcement aspect? 311 00:13:26.199 --> 00:13:26.399 Well, 312 00:13:26.419 --> 00:13:28.020 that's a very important point. 313 00:13:28.680 --> 00:13:29.201 First of all, 314 00:13:29.241 --> 00:13:36.105 we took note of the forum opinion that covers exactly the enforcement possible issues related to the implementation of the restriction. 315 00:13:36.466 --> 00:13:38.247 The committee found it very useful. 316 00:13:38.739 --> 00:13:42.342 And there were some elements related to how to apply analytical methods, 317 00:13:42.422 --> 00:13:47.827 but also the concentration limit and whether they could be achievable or not for certain PFAS. 318 00:13:48.407 --> 00:13:50.969 What is clear is that in agreement with Forum, 319 00:13:51.249 --> 00:13:57.635 RAC is calling for an harmonized enforcement and standardization of the methods that are needed for sampling and analysis. 320 00:13:57.695 --> 00:14:01.418 This will be very important to make actually this restriction work. 321 00:14:02.298 --> 00:14:02.479 Right. 322 00:14:02.499 --> 00:14:02.919 And anyway, 323 00:14:02.999 --> 00:14:03.800 enforcement authorities, 324 00:14:03.820 --> 00:14:04.240 I suppose, 325 00:14:04.260 --> 00:14:07.663 have quite some time to prepare because any restriction will only come into place once. 326 00:14:07.903 --> 00:14:08.864 the decision has been made. 327 00:14:09.044 --> 00:14:09.364 Indeed, 328 00:14:09.544 --> 00:14:09.844 indeed. 329 00:14:10.204 --> 00:14:10.384 Right. 330 00:14:10.785 --> 00:14:10.925 Well, 331 00:14:11.085 --> 00:14:11.805 last question for me, 332 00:14:11.825 --> 00:14:12.305 I promise. 333 00:14:12.766 --> 00:14:14.827 So if a full PFAS ban, 334 00:14:14.867 --> 00:14:16.107 as opposed to a wide restriction, 335 00:14:16.268 --> 00:14:16.968 works so well, 336 00:14:17.608 --> 00:14:18.509 what's holding us back? 337 00:14:19.029 --> 00:14:22.011 Is it that some uses just simply can't be replaced yet? 338 00:14:22.171 --> 00:14:25.312 Or is the challenge more about feasibility and implementation? 339 00:14:26.073 --> 00:14:27.954 This is a difficult question for RAC, 340 00:14:27.994 --> 00:14:29.895 and it's more in the territory of SEAC. 341 00:14:29.975 --> 00:14:32.736 And I think Maria will comment in a second. 342 00:14:33.257 --> 00:14:37.339 I can only say that RAC have found a lot of uses of PFAS in many sectors. 343 00:14:37.679 --> 00:14:43.545 And decision makers must consider many aspects that are not only related to the risk for human health and environment. 344 00:14:43.605 --> 00:14:47.228 And this is probably why the role of SEAC on opinion making is so important, 345 00:14:47.248 --> 00:14:49.871 because it complements the opinion of RAC. 346 00:14:50.860 --> 00:14:51.000 Well, 347 00:14:51.040 --> 00:14:51.340 thank you, 348 00:14:51.400 --> 00:14:51.781 Roberto. 349 00:14:51.841 --> 00:14:53.122 So to wrap up this part, 350 00:14:53.682 --> 00:14:56.004 PFAS are a complex family of chemicals, 351 00:14:56.064 --> 00:14:57.525 if that wasn't clear already by now, 352 00:14:57.865 --> 00:15:00.026 but the committee's takeaway is even clearer. 353 00:15:00.066 --> 00:15:02.128 So because they persist and accumulate, 354 00:15:02.528 --> 00:15:04.890 any release adds to a long-term problem. 355 00:15:05.470 --> 00:15:07.151 That's why minimizing emissions, 356 00:15:07.271 --> 00:15:10.613 whether through a full ban or carefully controlled derogations, 357 00:15:11.034 --> 00:15:11.834 is so important. 358 00:15:12.615 --> 00:15:16.978 And whatever direction the decision makers take next will have a real impact on Europe's health, 359 00:15:17.238 --> 00:15:17.638 industry, 360 00:15:17.878 --> 00:15:19.279 and innovation for years to come. 361 00:15:20.644 --> 00:15:21.064 Time for you, 362 00:15:21.125 --> 00:15:21.385 Maria. 363 00:15:21.485 --> 00:15:24.047 Let's bring you in to look at the socioeconomic side of all this. 364 00:15:24.087 --> 00:15:26.329 So to give our listeners a bit of context, 365 00:15:26.590 --> 00:15:30.253 what exactly is the committee's role in the PFAS evaluation process? 366 00:15:30.473 --> 00:15:33.756 And how does it differ from the scientific risk assessment side of things? 367 00:15:35.017 --> 00:15:35.217 Well, 368 00:15:35.218 --> 00:15:36.539 as Roberto has explained, 369 00:15:36.739 --> 00:15:40.883 the Committee for Risk Assessment looks at the risk to human health and the environment. 370 00:15:41.403 --> 00:15:43.125 But then SEAC takes that into account, 371 00:15:43.185 --> 00:15:44.606 but looks at the broader picture, 372 00:15:44.626 --> 00:15:45.046 I would say. 373 00:15:45.146 --> 00:15:46.608 So our role is to assess... 374 00:15:46.928 --> 00:15:49.490 all the socioeconomic impacts of the proposed restriction, 375 00:15:49.571 --> 00:15:51.612 not just what RAC is looking at, 376 00:15:51.813 --> 00:15:54.615 but also the full picture and much more than that. 377 00:15:55.476 --> 00:16:00.060 It's necessary to do that before you can take a decision on whether the proposed restriction is proportionate, 378 00:16:00.080 --> 00:16:00.581 which is done, 379 00:16:00.721 --> 00:16:00.961 you know, 380 00:16:01.021 --> 00:16:02.622 later on in the process. 381 00:16:03.823 --> 00:16:08.488 So what do I mean when I say socioeconomic impacts of the proposed restriction? 382 00:16:09.308 --> 00:16:14.811 People tend to think about socioeconomic impacts as cost to industry or monetary costs, 383 00:16:14.871 --> 00:16:16.392 but it's a lot wider than that. 384 00:16:16.412 --> 00:16:16.692 I mean, 385 00:16:17.153 --> 00:16:20.635 we are talking about costs and benefits of a restriction. 386 00:16:21.415 --> 00:16:22.736 When we're talking about the benefits, 387 00:16:22.776 --> 00:16:26.258 we mean all the good impacts to society of implementing a restriction. 388 00:16:26.298 --> 00:16:33.002 And there is the closest link to RAC because we take their assessment regarding how the risks to human health and the environment are reduced. 389 00:16:33.003 --> 00:16:33.822 That's one of the, 390 00:16:33.962 --> 00:16:34.222 you know, 391 00:16:34.242 --> 00:16:36.964 it's always the key positive impact. 392 00:16:37.540 --> 00:16:39.901 But when we are talking about negative impacts to society, 393 00:16:40.662 --> 00:16:44.324 we in general will start by looking at the availability of alternatives. 394 00:16:44.464 --> 00:16:46.465 So that allows us to understand the impacts. 395 00:16:47.005 --> 00:16:47.125 So, 396 00:16:47.345 --> 00:16:47.925 for instance, 397 00:16:48.026 --> 00:16:51.467 if alternatives are easily available and replacing them is cheap, 398 00:16:51.627 --> 00:16:53.969 then the negative impacts of a restriction won't be huge. 399 00:16:54.029 --> 00:16:55.690 They should be fairly straightforward. 400 00:16:55.750 --> 00:16:56.690 Costs are going to be low. 401 00:16:57.430 --> 00:16:59.471 But if alternatives are not available... 402 00:17:00.592 --> 00:17:03.033 and this may be that they're not available at all, 403 00:17:03.173 --> 00:17:08.496 or there may be some available alternatives that they have performance that's much inferior to PFAS, 404 00:17:09.357 --> 00:17:10.938 then we try to understand what happens. 405 00:17:11.478 --> 00:17:14.440 And that's what really determines what the cost would be. 406 00:17:14.840 --> 00:17:15.801 So in some cases, 407 00:17:15.841 --> 00:17:16.261 it may be, 408 00:17:16.281 --> 00:17:16.621 of course, 409 00:17:16.622 --> 00:17:17.702 that companies may close. 410 00:17:17.703 --> 00:17:19.182 There would be impacts on employment there, 411 00:17:19.222 --> 00:17:19.783 for instance, 412 00:17:19.784 --> 00:17:20.103 as well. 413 00:17:21.484 --> 00:17:22.264 In some cases, 414 00:17:22.364 --> 00:17:25.846 it may be that the performance of what they produce may be lower. 415 00:17:26.266 --> 00:17:27.307 And depending on the sector, 416 00:17:27.308 --> 00:17:29.108 the impact of that could range from 417 00:17:29.592 --> 00:17:29.952 I don't know, 418 00:17:29.953 --> 00:17:32.354 a consumer product which performs a little bit worse, 419 00:17:33.094 --> 00:17:38.417 to certain medical devices not being available and not working with consequent health impacts. 420 00:17:38.657 --> 00:17:40.538 There may also be environmental impacts if, 421 00:17:40.578 --> 00:17:41.279 for instance, 422 00:17:41.619 --> 00:17:45.681 a battery can't work and therefore there may be more carbon emissions. 423 00:17:46.102 --> 00:17:53.546 So basically our task is to get to the bottom of this and to provide the decision makers some advice on how these negative and positive impacts balance together. 424 00:17:53.886 --> 00:17:55.867 So just for my own understanding, 425 00:17:56.288 --> 00:17:56.808 the kind of 426 00:17:57.088 --> 00:18:01.290 an analysis of alternatives that feeds into the kind of impacts then to society. 427 00:18:01.631 --> 00:18:03.432 Is that something that will be covered also as part of, 428 00:18:03.492 --> 00:18:04.452 I guess we'll come to this later, 429 00:18:04.472 --> 00:18:07.514 but also part of the consultation that it'll serve to feed into that? 430 00:18:08.755 --> 00:18:09.015 Yes. 431 00:18:09.075 --> 00:18:09.335 I mean, 432 00:18:09.575 --> 00:18:17.419 conclusions on the analysis of alternative are part of the consultation and those conclusions are quite crucial to understand the impact. 433 00:18:17.439 --> 00:18:17.839 So yes, 434 00:18:17.900 --> 00:18:22.422 definitely this is something where in some cases we've got quite a lot of info, 435 00:18:22.462 --> 00:18:23.503 in some not so much, 436 00:18:23.703 --> 00:18:24.963 and we're looking for it. 437 00:18:25.123 --> 00:18:25.324 Okay. 438 00:18:25.344 --> 00:18:26.084 And that will then impact. 439 00:18:26.104 --> 00:18:26.584 the opinion. 440 00:18:27.644 --> 00:18:27.925 All right. 441 00:18:28.265 --> 00:18:28.405 Well, 442 00:18:28.605 --> 00:18:30.565 thanks for reminding us of the committee's role in all this. 443 00:18:31.105 --> 00:18:35.227 Can you then talk about the key points of the draft opinion that will go for our consultation? 444 00:18:36.327 --> 00:18:36.487 Well, 445 00:18:36.547 --> 00:18:42.949 basically SEAC supported a broad restriction with you specific derogations where cost to society outweigh the benefits. 446 00:18:43.209 --> 00:18:46.370 And this is to ensure the proportionality of the proposed restriction. 447 00:18:46.390 --> 00:18:46.890 So basically, 448 00:18:46.891 --> 00:18:52.572 we consider that there will be some derogations that are required to make a restriction proportionate. 449 00:18:53.548 --> 00:18:57.291 So for each of the sectors and uses identified by the dossier submitter, 450 00:18:57.652 --> 00:18:59.613 we analysed case by case, 451 00:18:59.693 --> 00:19:00.394 use by use, 452 00:19:00.754 --> 00:19:05.318 whether derogations are indeed justified and needed to ensure that proportionality. 453 00:19:05.918 --> 00:19:09.702 And we had basically three broad categories of conclusions. 454 00:19:09.703 --> 00:19:10.822 We had yes, 455 00:19:10.902 --> 00:19:13.905 no and can't conclude for some uses. 456 00:19:14.105 --> 00:19:14.225 So, 457 00:19:14.345 --> 00:19:14.926 for instance, 458 00:19:14.946 --> 00:19:16.527 here we're talking about cosmetics, 459 00:19:16.707 --> 00:19:17.288 ski wax, 460 00:19:17.608 --> 00:19:18.308 that type of thing. 461 00:19:19.309 --> 00:19:22.232 We concluded that no derogations are needed and... 462 00:19:22.812 --> 00:19:24.393 In some cases here, 463 00:19:24.513 --> 00:19:24.773 you know, 464 00:19:24.793 --> 00:19:25.693 we were quite firm, 465 00:19:25.853 --> 00:19:27.234 definitely not justified. 466 00:19:27.314 --> 00:19:28.054 In some cases, 467 00:19:28.214 --> 00:19:29.355 likely not justified. 468 00:19:29.395 --> 00:19:31.556 So there's all sorts of gradations there. 469 00:19:32.496 --> 00:19:33.376 For some uses, 470 00:19:34.037 --> 00:19:35.797 we say that derogations are needed. 471 00:19:36.158 --> 00:19:37.638 Here we can mention, 472 00:19:37.698 --> 00:19:38.178 for instance, 473 00:19:38.198 --> 00:19:39.819 several kinds of medical devices. 474 00:19:41.260 --> 00:19:41.700 For those, 475 00:19:41.720 --> 00:19:43.501 we concluded more unambiguously. 476 00:19:43.661 --> 00:19:46.202 But there are also many uses where we concluded, 477 00:19:46.282 --> 00:19:46.882 for instance, 478 00:19:47.222 --> 00:19:48.242 likely justified, 479 00:19:48.363 --> 00:19:49.303 maybe justified. 480 00:19:49.563 --> 00:19:51.704 So what we were trying to do there is to avoid... 481 00:19:52.104 --> 00:19:59.047 They cannot conclude a conclusion as much as possible to give the decision maker as much as we could in terms of guidance. 482 00:19:59.507 --> 00:20:00.148 But of course, 483 00:20:00.208 --> 00:20:01.948 for some of the of the uses, 484 00:20:02.749 --> 00:20:04.410 we were not able to conclude at all. 485 00:20:05.770 --> 00:20:07.131 Or maybe in some cases, 486 00:20:07.251 --> 00:20:08.211 it may be that there's, 487 00:20:09.052 --> 00:20:09.272 you know, 488 00:20:09.312 --> 00:20:10.612 there was not enough information. 489 00:20:10.833 --> 00:20:11.433 In some cases, 490 00:20:11.473 --> 00:20:15.975 it may be that the conclusion would need to be based on aspects that are not for SEAC to decide. 491 00:20:15.976 --> 00:20:16.315 Of course, 492 00:20:16.335 --> 00:20:17.415 we're a scientific committee. 493 00:20:17.576 --> 00:20:18.236 when it comes to 494 00:20:18.692 --> 00:20:20.958 Policy preference for some things over others, 495 00:20:21.159 --> 00:20:22.402 we cannot say that. 496 00:20:25.162 --> 00:20:30.485 The other thing to mention is that we have some difference to the derogations proposed by the dossier submitter. 497 00:20:31.526 --> 00:20:40.412 So there is a big table near the end of the general aspects part of the opinion where we list all the derogations that were proposed by the dossier submitter and what SEAC's conclusion was. 498 00:20:41.032 --> 00:20:41.712 In some cases, 499 00:20:41.752 --> 00:20:45.335 we did not agree with the availability of alternatives conclusion. 500 00:20:45.355 --> 00:20:46.495 In some cases we did, 501 00:20:46.576 --> 00:20:48.217 but then the cost and benefits, 502 00:20:48.237 --> 00:20:50.178 we were not able to balance them out. 503 00:20:51.190 --> 00:20:51.610 But yeah, 504 00:20:51.630 --> 00:20:52.731 all the information is there, 505 00:20:52.751 --> 00:20:54.752 including some notes to the decision maker. 506 00:20:54.772 --> 00:20:57.694 So it's quite useful to see at a glance. 507 00:20:58.854 --> 00:21:10.821 Maybe the other thing to mention as well is that we note quite strongly in the opinion that the derogations that we consider justified should be regarded as necessary to ensure proportionality, 508 00:21:11.141 --> 00:21:12.041 but not sufficient. 509 00:21:12.082 --> 00:21:12.722 So basically, 510 00:21:13.222 --> 00:21:20.146 we cannot say whether or not there may be some additional derogations required for certain sub-uses for... 511 00:21:20.446 --> 00:21:21.687 to make a restriction proportion. 512 00:21:21.727 --> 00:21:23.649 It's a very broad one that applies to everything, 513 00:21:23.689 --> 00:21:24.309 basically. 514 00:21:24.830 --> 00:21:25.050 I mean, 515 00:21:25.070 --> 00:21:31.095 we have identified a couple of derogations that the dossier submitter was not proposing and that we are proposing that they are needed, 516 00:21:31.615 --> 00:21:32.316 but there may be more. 517 00:21:32.396 --> 00:21:32.756 Basically, 518 00:21:32.776 --> 00:21:36.719 there is lack of data to be able to come up with more examples. 519 00:21:37.600 --> 00:21:44.366 The other thing to mention is for the eight additional sectors where Roberto mentioned that in RAC they had not been able to come to specific conclusions. 520 00:21:44.367 --> 00:21:44.706 Of course, 521 00:21:44.726 --> 00:21:47.328 SEAC wasn't able to come to specific conclusions either. 522 00:21:48.049 --> 00:21:48.849 But for those... 523 00:21:49.690 --> 00:21:52.972 we still are able to make some recommendations. 524 00:21:52.973 --> 00:21:57.656 We cannot conclude whether the derogations proposed within are justified, 525 00:21:58.556 --> 00:22:02.279 nor whether we may need some more derogations there. 526 00:22:02.639 --> 00:22:08.223 But what we're recommending is that an evaluation of all these uses is done as soon as possible. 527 00:22:08.483 --> 00:22:09.404 And in the interim, 528 00:22:09.864 --> 00:22:13.047 we are recommending a time-limited derogation for all the users' 529 00:22:13.067 --> 00:22:15.088 applications within the scope of those sectors, 530 00:22:15.089 --> 00:22:17.550 so not just the ones proposed by the dossier submitter. 531 00:22:17.930 --> 00:22:19.271 And when we say time limited, 532 00:22:19.591 --> 00:22:23.432 we don't mean for the periods that are being proposed by the dossier submitter, 533 00:22:23.873 --> 00:22:25.834 but until an evaluation is performed. 534 00:22:25.874 --> 00:22:33.957 So we're hoping that that provides maybe a little bit of information to the decision maker as to what we feel that should be done with those. 535 00:22:35.478 --> 00:22:36.078 And finally, 536 00:22:36.178 --> 00:22:42.141 Roberto mentioned the recommendations by RAC to implement additional risk management measures. 537 00:22:42.461 --> 00:22:43.882 We also have a conclusion on that, 538 00:22:43.902 --> 00:22:44.402 of course. 539 00:22:45.002 --> 00:22:45.242 You know, 540 00:22:45.403 --> 00:22:50.647 RAC's view is the main one in terms of the impact of those on risk reduction. 541 00:22:51.568 --> 00:22:54.650 But we're looking at basically the proportionality of such measures, 542 00:22:54.670 --> 00:22:55.251 for instance. 543 00:22:55.711 --> 00:22:56.452 And there, 544 00:22:56.492 --> 00:22:57.092 unfortunately, 545 00:22:57.112 --> 00:23:00.075 we don't have information on the costs and benefits associated. 546 00:23:00.175 --> 00:23:02.096 We don't know how much it would cost to implement. 547 00:23:02.737 --> 00:23:06.280 And although RAC considers that it would reduce the risk, 548 00:23:06.420 --> 00:23:07.481 we don't know by how much. 549 00:23:07.581 --> 00:23:09.542 So we're not able to say whether it's proportional. 550 00:23:09.622 --> 00:23:12.585 Is it something that you expect to get more information on in the consultation? 551 00:23:12.705 --> 00:23:13.546 So the cost of these... 552 00:23:14.062 --> 00:23:15.123 risk mitigation measures. 553 00:23:15.704 --> 00:23:16.144 Exactly. 554 00:23:16.204 --> 00:23:18.646 That's where we hope that we can get that information. 555 00:23:18.686 --> 00:23:20.448 This was a RAC recommendation, 556 00:23:20.508 --> 00:23:24.291 so it wasn't part of the initial consultation on the Annex 15 dossier. 557 00:23:24.331 --> 00:23:31.557 So this will be the first time when people will be able to give us some information about what the implications are, 558 00:23:31.597 --> 00:23:32.378 not just the cost, 559 00:23:32.438 --> 00:23:35.700 but also how practical it is to implement these things. 560 00:23:35.701 --> 00:23:36.501 Is it possible? 561 00:23:36.581 --> 00:23:37.562 How long will it take? 562 00:23:38.443 --> 00:23:42.026 We also have some concerns about the enforceability. 563 00:23:42.638 --> 00:23:43.759 We support them in general, 564 00:23:43.879 --> 00:23:45.380 but with the specific ones, 565 00:23:45.381 --> 00:23:51.465 we consider that we may need some guidance to really allow things to be enforced. 566 00:23:52.405 --> 00:23:52.786 And yes, 567 00:23:52.866 --> 00:23:55.708 I think that that was a good reminder that you made, 568 00:23:55.728 --> 00:23:55.928 Adam. 569 00:23:55.968 --> 00:23:57.389 This is not the final opinion. 570 00:23:57.429 --> 00:24:02.473 We launched a consultation and I think we'll talk about that later on a little bit more very soon. 571 00:24:02.533 --> 00:24:02.673 Well, 572 00:24:02.713 --> 00:24:05.235 I think by the time this podcast is released, 573 00:24:05.236 --> 00:24:09.378 the consultation will already be out there and we're expecting to receive. 574 00:24:09.558 --> 00:24:12.659 very valuable information there that will allow us to finalize the opinion. 575 00:24:13.519 --> 00:24:13.839 Okay, 576 00:24:13.959 --> 00:24:14.500 thanks a lot. 577 00:24:14.580 --> 00:24:15.580 Very detailed overview. 578 00:24:15.620 --> 00:24:20.101 And people can also find that out then in the draft opinion that will be published together with the podcast. 579 00:24:20.102 --> 00:24:20.321 Yes, 580 00:24:20.361 --> 00:24:20.741 and indeed, 581 00:24:21.062 --> 00:24:21.842 maybe to mention, 582 00:24:21.902 --> 00:24:25.883 there are some very useful summary sections at the beginning summary of the opinion. 583 00:24:25.983 --> 00:24:30.004 So I really suggest people to have a look at that in the opinion. 584 00:24:30.005 --> 00:24:32.945 We try to actually summarize the whole thing for Rack and Fusayak. 585 00:24:33.545 --> 00:24:35.226 So based on what you've seen, 586 00:24:35.566 --> 00:24:38.647 In which sectors are PFAS alternatives already available? 587 00:24:38.927 --> 00:24:42.669 And where do we see the kind of the toughest challenges in finding substitutes? 588 00:24:42.670 --> 00:24:44.049 You mentioned a few examples. 589 00:24:44.050 --> 00:24:45.510 You mentioned medical devices, 590 00:24:45.511 --> 00:24:45.990 for example, 591 00:24:46.250 --> 00:24:49.552 at least needing a derogation because they might not be that easily replaced. 592 00:24:49.553 --> 00:24:52.213 So can you give us another feeling of other areas? 593 00:24:52.533 --> 00:24:52.713 Yeah, 594 00:24:52.833 --> 00:24:53.113 I mean, 595 00:24:53.173 --> 00:24:56.795 the derogation there is not just because of the conclusion on analysis of alternatives. 596 00:24:56.815 --> 00:25:00.276 It was also because of the potential impact of not having the medical devices. 597 00:25:00.656 --> 00:25:02.037 So that's important to remember. 598 00:25:02.337 --> 00:25:05.098 while the dossier submitter recommended the derogations. 599 00:25:05.218 --> 00:25:07.379 purely based on the availability of alternatives. 600 00:25:08.380 --> 00:25:11.181 SEAC said that that was an important element, 601 00:25:11.221 --> 00:25:12.142 but not the only one. 602 00:25:12.143 --> 00:25:14.543 So that's an important clarification to make. 603 00:25:14.544 --> 00:25:16.624 We also have to take account of the cost and benefits. 604 00:25:17.464 --> 00:25:17.985 But yeah, 605 00:25:18.145 --> 00:25:18.825 to your question. 606 00:25:19.445 --> 00:25:21.206 In some consumer applications, 607 00:25:21.246 --> 00:25:22.727 so some textiles, 608 00:25:22.787 --> 00:25:23.608 cosmetics, 609 00:25:23.728 --> 00:25:24.408 ski wax, 610 00:25:25.048 --> 00:25:25.309 you know, 611 00:25:25.789 --> 00:25:26.409 that kind of thing, 612 00:25:26.449 --> 00:25:27.830 alternatives already exist. 613 00:25:28.395 --> 00:25:29.595 So that is quite clear. 614 00:25:29.655 --> 00:25:30.936 There's a lot of evidence there. 615 00:25:30.937 --> 00:25:34.057 The conclusions that SEA can reach can be quite certain. 616 00:25:35.297 --> 00:25:40.939 But there are greater challenges basically in the highly technical applications. 617 00:25:40.959 --> 00:25:42.399 That's where we tend to find them. 618 00:25:42.479 --> 00:25:45.720 Things like uses within electronics and semiconductors, 619 00:25:45.840 --> 00:25:47.120 some medical devices, 620 00:25:47.280 --> 00:25:48.761 some industrial processes. 621 00:25:49.221 --> 00:25:52.242 And it's particularly where performance and safety requirements are very, 622 00:25:52.282 --> 00:25:53.082 very stringent, 623 00:25:53.462 --> 00:25:55.303 either because of the consequences to, 624 00:25:55.523 --> 00:25:56.183 for instance, 625 00:25:56.323 --> 00:25:56.903 people's health. 626 00:25:57.463 --> 00:25:59.785 or because of consequences to safety. 627 00:25:59.825 --> 00:26:00.565 So for instance, 628 00:26:00.885 --> 00:26:02.967 in some applications, 629 00:26:03.027 --> 00:26:08.391 there are very strict regulations as to what performance must be reached to protect safety. 630 00:26:08.471 --> 00:26:10.532 So I think that that is very important. 631 00:26:10.533 --> 00:26:15.376 So there is where we're finding that the alternatives are more difficult to find, 632 00:26:15.416 --> 00:26:15.776 let's say. 633 00:26:16.176 --> 00:26:16.656 And of course, 634 00:26:16.676 --> 00:26:17.257 as we mentioned, 635 00:26:17.258 --> 00:26:17.977 the consultation, 636 00:26:18.017 --> 00:26:21.100 that's the opportunity to get more information on all of this. 637 00:26:22.320 --> 00:26:22.441 Now, 638 00:26:22.581 --> 00:26:25.823 with some sectors ready to move away from PFAS and others facing... 639 00:26:26.083 --> 00:26:27.164 real technical barriers. 640 00:26:27.504 --> 00:26:30.627 How does the committee decide what transition periods are realistic, 641 00:26:30.707 --> 00:26:31.708 but also proportionate? 642 00:26:32.588 --> 00:26:32.769 Well, 643 00:26:33.009 --> 00:26:33.649 in general, 644 00:26:33.689 --> 00:26:41.976 the goal is always to allow sufficient time to transition away from the substance while avoiding unnecessary delays in reducing emissions. 645 00:26:41.977 --> 00:26:43.337 So it's a bit of a balancing act. 646 00:26:43.878 --> 00:26:50.443 And normally the recommendations on the length of the derogations would look at very specific aspects of each use and consider in detail, 647 00:26:50.523 --> 00:26:50.743 okay, 648 00:26:50.843 --> 00:26:52.725 what will actually be needed to substitute, 649 00:26:53.185 --> 00:26:54.506 where are we the alternatives? 650 00:26:55.507 --> 00:26:55.907 Ideally, 651 00:26:55.947 --> 00:26:57.529 we would come up with bespoke lengths, 652 00:26:58.089 --> 00:27:00.951 but as you may be able to tell by the fact I'm talking about ideally, 653 00:27:01.572 --> 00:27:02.272 in this case, 654 00:27:02.312 --> 00:27:07.276 with so many different specific uses and quite a lot of lack of specific information, 655 00:27:08.076 --> 00:27:11.058 the dossier submitter took a bit of a different approach. 656 00:27:11.339 --> 00:27:13.720 They came up with two general derogation lengths, 657 00:27:14.501 --> 00:27:18.544 and those were five and 12 years after entry into force, 658 00:27:18.545 --> 00:27:19.324 so after the 659 00:27:19.745 --> 00:27:22.527 18-month transition period that is in general for the whole proposal. 660 00:27:23.347 --> 00:27:30.571 So they decided that they would recommend five years where there were no alternatives at the point of entry into force, 661 00:27:31.832 --> 00:27:33.773 or no alternatives were expected to be available. 662 00:27:34.013 --> 00:27:35.814 Some have been identified already, 663 00:27:36.634 --> 00:27:39.116 or maybe there are some alternatives identified, 664 00:27:39.216 --> 00:27:41.577 but they're not available in sufficient quantities. 665 00:27:42.217 --> 00:27:45.259 So there may need to be some steps taken before they may be implemented, 666 00:27:45.319 --> 00:27:47.100 like some approvals and that sort of thing. 667 00:27:47.980 --> 00:27:51.743 Twelve years they recommended where no alternatives had been identified yet. 668 00:27:51.763 --> 00:27:52.483 So it's likely. 669 00:27:52.703 --> 00:27:54.624 They won't become available in the near future. 670 00:27:55.605 --> 00:28:01.670 Or there are situations where the certifications or regulatory improvements cannot be achieved with a five-year derogation. 671 00:28:01.690 --> 00:28:02.710 They take longer than that. 672 00:28:03.091 --> 00:28:05.693 And there are some sectors where we know that that tends to be the case, 673 00:28:05.733 --> 00:28:06.853 like some medical sectors, 674 00:28:06.893 --> 00:28:07.494 for instance. 675 00:28:08.074 --> 00:28:09.055 And in general, 676 00:28:09.135 --> 00:28:10.776 SEAC endorsed this approach. 677 00:28:10.836 --> 00:28:11.076 I mean, 678 00:28:11.096 --> 00:28:13.278 we did note that the lengths were a little bit arbitrary, 679 00:28:13.418 --> 00:28:14.339 but in general, 680 00:28:14.839 --> 00:28:18.742 we think this is the right way to go in this type of very, 681 00:28:18.802 --> 00:28:19.763 very broad restriction. 682 00:28:20.299 --> 00:28:22.360 And we applied it in our analysis as well. 683 00:28:22.420 --> 00:28:26.461 So our recommendations will be also about the 5 and 12 years. 684 00:28:27.161 --> 00:28:28.081 In some cases, 685 00:28:28.662 --> 00:28:33.203 when we are recommending our own derogations that the assessor method didn't propose, 686 00:28:33.223 --> 00:28:34.563 we see if we can say something, 687 00:28:34.603 --> 00:28:36.524 but it may be that there isn't enough information. 688 00:28:37.104 --> 00:28:37.384 Okay. 689 00:28:37.544 --> 00:28:37.824 All right. 690 00:28:37.844 --> 00:28:38.064 Thank you. 691 00:28:38.065 --> 00:28:43.046 And I suppose one kind of consequence of all this is that there will be a push to develop those alternatives, 692 00:28:43.166 --> 00:28:44.966 essentially a much more bigger push, 693 00:28:45.026 --> 00:28:46.927 because there is now a set time limit to get them. 694 00:28:47.655 --> 00:28:48.036 applied. 695 00:28:48.096 --> 00:28:50.638 So I guess that's a positive outcome also of this restriction. 696 00:28:51.118 --> 00:28:51.298 Yeah, 697 00:28:51.418 --> 00:28:51.839 basically, 698 00:28:51.879 --> 00:28:54.301 when you have derogations that are time limited, 699 00:28:54.761 --> 00:28:59.685 we all know what is going to happen at the end of the derogation period. 700 00:28:59.765 --> 00:29:00.546 So of course, 701 00:29:00.566 --> 00:29:02.107 there's going to be a lot of work happening. 702 00:29:02.347 --> 00:29:02.587 I mean, 703 00:29:02.688 --> 00:29:03.148 to be fair, 704 00:29:03.188 --> 00:29:04.949 there is a lot of work happening already now. 705 00:29:05.210 --> 00:29:05.430 I mean, 706 00:29:05.450 --> 00:29:07.872 we see a lot of activity to develop alternatives. 707 00:29:07.952 --> 00:29:12.135 And I think this is a positive impact that the restriction proposal is already having. 708 00:29:12.956 --> 00:29:14.977 Given kind of all those moving pieces, 709 00:29:15.018 --> 00:29:16.359 so technical feasibility, 710 00:29:17.448 --> 00:29:18.630 supply chain readiness, 711 00:29:18.850 --> 00:29:20.072 essential uses. 712 00:29:20.552 --> 00:29:24.057 Where does the committee still see the biggest uncertainties in the draft opinion? 713 00:29:25.319 --> 00:29:27.703 I will talk mainly about types of uncertainty, 714 00:29:27.863 --> 00:29:29.486 not about specific uses. 715 00:29:30.427 --> 00:29:32.149 One of them is this covers... 716 00:29:33.156 --> 00:29:33.977 all the uses, 717 00:29:34.617 --> 00:29:39.802 but not all of them were assessed by the dossier submitter and evaluated by SEAC. 718 00:29:40.403 --> 00:29:41.924 So that is one uncertainty. 719 00:29:41.964 --> 00:29:44.807 There's maybe a lot of uses that we don't even know about, 720 00:29:44.927 --> 00:29:48.390 or that didn't pop up in the information that was received. 721 00:29:48.770 --> 00:29:49.111 Of course, 722 00:29:49.112 --> 00:29:51.012 we may get something in the consultation still. 723 00:29:51.733 --> 00:29:53.615 And the other one is the lack of data. 724 00:29:53.616 --> 00:29:53.835 I mean, 725 00:29:53.875 --> 00:29:55.777 the dossier submitter did a huge job. 726 00:29:56.177 --> 00:29:58.719 They put in a lot of work to try to get the information, 727 00:29:58.820 --> 00:29:59.000 but 728 00:29:59.620 --> 00:30:01.742 There are still some areas where this is lacking, 729 00:30:01.822 --> 00:30:04.924 and this should be very clear when people look at the opinion. 730 00:30:04.964 --> 00:30:07.566 I mentioned the table with all the derogations earlier, 731 00:30:07.986 --> 00:30:10.988 but please remember that that table shouldn't be read in isolation. 732 00:30:11.668 --> 00:30:17.753 Each of the conclusions that we talk about there on derogations should be read in conjunction with the sector-specific documents. 733 00:30:18.153 --> 00:30:20.975 There is a lot of information there about what we know, 734 00:30:21.055 --> 00:30:21.675 what we don't, 735 00:30:21.715 --> 00:30:22.636 what we would need to know. 736 00:30:22.756 --> 00:30:25.018 So people should read all of that. 737 00:30:25.138 --> 00:30:25.338 Okay, 738 00:30:25.358 --> 00:30:28.060 an important tip for anyone participating in the consultation. 739 00:30:28.456 --> 00:30:28.576 Well, 740 00:30:28.696 --> 00:30:29.016 thank you. 741 00:30:29.036 --> 00:30:31.377 That helps put the uncertainties into perspective. 742 00:30:31.857 --> 00:30:34.918 Maybe then moving to the next step that we've referred to already many times, 743 00:30:34.938 --> 00:30:36.138 the 60-day consultation. 744 00:30:36.498 --> 00:30:38.319 So when is that expected to begin? 745 00:30:39.139 --> 00:30:39.299 Well, 746 00:30:39.359 --> 00:30:42.000 we are launching the consultation on the 26th of March. 747 00:30:42.140 --> 00:30:44.521 So it's closing 60 days later in late May. 748 00:30:45.261 --> 00:30:49.062 And we've informed our audience since really early about the upcoming consultation. 749 00:30:49.122 --> 00:30:52.103 We've told them what questions we'll be asking so that they can start preparing. 750 00:30:52.123 --> 00:30:55.064 I've talked about this in previous podcasts in quite a lot of detail. 751 00:30:55.912 --> 00:31:01.196 There is a webinar that we did some time ago that is still relevant and it's still available for people to see. 752 00:31:01.456 --> 00:31:03.357 And there is a lot of guidance as well. 753 00:31:04.158 --> 00:31:06.139 There's also a mapping of the PFAS uses, 754 00:31:06.199 --> 00:31:09.862 which may be useful so that people understand where they need to respond. 755 00:31:11.083 --> 00:31:12.083 I should mention as well, 756 00:31:12.123 --> 00:31:14.225 this is done in a survey format, 757 00:31:14.325 --> 00:31:17.067 so we are not allowing attachments to be provided. 758 00:31:17.127 --> 00:31:17.867 People need to... 759 00:31:19.168 --> 00:31:24.652 do a little bit of work in trying to draw out the exact information at the level of aggregation, 760 00:31:24.692 --> 00:31:25.013 let's say, 761 00:31:25.053 --> 00:31:28.075 that SEAC needs it and in the type of format that we need it. 762 00:31:28.435 --> 00:31:34.680 That will allow us to really process things as effectively as possible and to actually have an impact on the opinion. 763 00:31:35.661 --> 00:31:36.221 And yeah, 764 00:31:36.281 --> 00:31:36.662 basically, 765 00:31:36.682 --> 00:31:40.505 we encourage everyone who has relevant information to provide, 766 00:31:40.585 --> 00:31:44.428 to engage really early in this consultation and to provide us that data. 767 00:31:44.828 --> 00:31:46.129 Because we will be looking at it, 768 00:31:46.149 --> 00:31:47.390 we will be considering it, 769 00:31:47.550 --> 00:31:49.291 and the opinion may change as a result. 770 00:31:50.412 --> 00:31:50.612 Okay, 771 00:31:50.652 --> 00:31:54.454 then what about for listeners who may want to take part in the consultation? 772 00:31:55.755 --> 00:31:56.956 What does it actually focus on? 773 00:31:57.036 --> 00:31:59.817 So kind of what sort of input are you hoping people will provide? 774 00:32:01.318 --> 00:32:01.438 Well, 775 00:32:01.439 --> 00:32:05.181 the scope is basically the SEAC draft opinion that was just agreed in March. 776 00:32:05.881 --> 00:32:10.024 And it includes all 23 sectors and uses within those sectors. 777 00:32:10.856 --> 00:32:11.077 I mean, 778 00:32:11.117 --> 00:32:14.540 there will be detailed questions on the sectors that SEAC has evaluated. 779 00:32:14.560 --> 00:32:20.985 So these are 15 sectors and there will not be any detailed questions for the eight sectors where we haven't, 780 00:32:20.986 --> 00:32:27.731 but information can be provided as part of the general aspects and they can be provided on any topics related to anything. 781 00:32:27.811 --> 00:32:28.271 Basically, 782 00:32:28.311 --> 00:32:29.913 that's covered in the opinion. 783 00:32:31.574 --> 00:32:32.014 Basically, 784 00:32:32.395 --> 00:32:33.436 the relevant information, 785 00:32:33.456 --> 00:32:34.036 as I mentioned, 786 00:32:34.076 --> 00:32:38.160 will be assessed to either confirm or change if necessary. 787 00:32:38.720 --> 00:32:41.643 CEAC conclusions that are presented in the CEAC draft opinion. 788 00:32:42.163 --> 00:32:49.610 And maybe the other thing that I would like to mention is that we're not looking here to hear about whether you like the proposal or not. 789 00:32:50.011 --> 00:32:52.353 We're looking for technical evidence-based information. 790 00:32:52.393 --> 00:32:53.994 So it's not so much about your opinion. 791 00:32:54.054 --> 00:32:56.757 It's about things that can be substantiated. 792 00:32:56.797 --> 00:32:57.978 That's what we're really looking for. 793 00:32:58.459 --> 00:32:58.699 Okay. 794 00:32:58.719 --> 00:32:58.979 All right. 795 00:32:59.019 --> 00:33:00.761 And after the consultation phase, 796 00:33:00.762 --> 00:33:02.462 then how does the process move forward? 797 00:33:02.522 --> 00:33:04.044 What can stakeholders expect next? 798 00:33:04.540 --> 00:33:04.680 Well, 799 00:33:04.920 --> 00:33:05.961 as information comes in, 800 00:33:05.981 --> 00:33:09.262 we will be analysing and not just after the consultation closes, 801 00:33:09.302 --> 00:33:11.343 but as soon as we start receiving information. 802 00:33:11.844 --> 00:33:17.667 And we will be analysing it and considering whether there would need to be any reviews made to the opinion. 803 00:33:17.707 --> 00:33:24.490 So the idea is that we will adopt the final opinion by the end of 2026 and send to the Commission. 804 00:33:24.990 --> 00:33:28.612 And then the Commission will decide on the restriction in consultation with the member states. 805 00:33:29.328 --> 00:33:29.528 Okay, 806 00:33:29.588 --> 00:33:32.149 reading between the lines and knowing when the committee meetings are. 807 00:33:32.189 --> 00:33:33.289 So we're skipping the June, 808 00:33:33.349 --> 00:33:34.189 the September meeting, 809 00:33:34.190 --> 00:33:35.190 but then there's one in November, 810 00:33:35.250 --> 00:33:35.650 December. 811 00:33:35.690 --> 00:33:36.810 So would that be around the time, 812 00:33:36.811 --> 00:33:39.671 if everything goes as planned and all timelines match? 813 00:33:39.951 --> 00:33:40.171 Yeah, 814 00:33:40.191 --> 00:33:43.692 we haven't decided yet exactly what we will be doing on each of those meetings. 815 00:33:43.732 --> 00:33:45.353 I would expect that probably in June, 816 00:33:45.354 --> 00:33:46.933 we would have some information about the, 817 00:33:47.273 --> 00:33:47.573 you know, 818 00:33:48.294 --> 00:33:51.535 informing the committee about the consultation comments, 819 00:33:51.615 --> 00:33:52.555 what was received, 820 00:33:52.615 --> 00:33:53.835 maybe some initial views. 821 00:33:54.796 --> 00:33:55.156 But yeah, 822 00:33:55.216 --> 00:33:55.736 it will be. 823 00:33:56.496 --> 00:34:01.159 basically the last plenary of the year where the timing is still to be fully confirmed. 824 00:34:02.019 --> 00:34:06.622 We need to finalize it with enough time to then be able to send things to the commission. 825 00:34:07.562 --> 00:34:07.722 Now, 826 00:34:08.202 --> 00:34:10.784 moving aside from the kind of the PFAS topic today, 827 00:34:11.644 --> 00:34:12.385 can you talk us through, 828 00:34:12.425 --> 00:34:12.785 Roberto, 829 00:34:12.845 --> 00:34:13.706 about the CLH, 830 00:34:13.726 --> 00:34:18.068 so the Harmonized Classification and Labeling opinion on cannabidiol that was mentioned earlier? 831 00:34:18.967 --> 00:34:21.349 So that's used actually in several sectors, 832 00:34:21.549 --> 00:34:23.570 apparently in vaping products, 833 00:34:23.730 --> 00:34:26.733 so in electronic cigarettes or possible inhalation, 834 00:34:27.253 --> 00:34:31.876 or even in cosmetic products or food ingredients or supplements for human and animals. 835 00:34:32.297 --> 00:34:38.481 And apparently there is also even a medication against epilepsy that has been actually authorized in Europe. 836 00:34:39.082 --> 00:34:46.667 So what RAC found was that there is enough evidence to recommend a quite severe hazard classification related to... 837 00:34:46.707 --> 00:34:50.528 to category 1b in terms of reproductive toxicants, 838 00:34:50.588 --> 00:34:54.669 so able to damage fertility or damage the unborn child, 839 00:34:55.149 --> 00:34:57.510 and even hazardous to the breastfed child. 840 00:34:58.010 --> 00:35:01.291 So that's something that will be published in a few weeks, 841 00:35:01.351 --> 00:35:02.711 couple of months maximum. 842 00:35:03.152 --> 00:35:06.132 And this opinion will then be transmitted to the European Commission. 843 00:35:06.272 --> 00:35:06.893 And as usual, 844 00:35:07.293 --> 00:35:14.855 the European Commission in conjunction with member states will decide whether an harmonized classification is needed actually for this specific substance. 845 00:35:15.275 --> 00:35:16.376 And if this happens, 846 00:35:16.596 --> 00:35:22.598 this classification could also trigger what we call downstream effects in other regulations. 847 00:35:22.818 --> 00:35:23.379 Just to mention, 848 00:35:23.419 --> 00:35:23.879 for instance, 849 00:35:23.880 --> 00:35:25.399 the cosmetic products regulation, 850 00:35:25.960 --> 00:35:30.321 where possible exemption could be needed in case this would go forward. 851 00:35:31.002 --> 00:35:38.865 Also to mention that we have coordinated with EFSA because there are also discussions on food uses that are taking place. 852 00:35:38.885 --> 00:35:43.127 So we ensure that we are aligned with our agency in charge of food. 853 00:35:44.087 --> 00:35:44.347 Thanks. 854 00:35:44.427 --> 00:35:46.729 So that's actually a significant development. 855 00:35:46.749 --> 00:35:46.929 I mean, 856 00:35:46.969 --> 00:35:54.755 CBD is used in such a wide range of products that a harmonized classification like this could have major implications across several sectors. 857 00:35:55.456 --> 00:35:58.398 What about the chromium-6 restriction proposal that was also mentioned? 858 00:35:58.399 --> 00:35:59.759 Can you share any details on that? 859 00:36:00.531 --> 00:36:00.651 Yeah, 860 00:36:00.671 --> 00:36:01.552 I can say a few words. 861 00:36:01.553 --> 00:36:01.792 I mean, 862 00:36:01.852 --> 00:36:04.333 we're making significant progress on that. 863 00:36:04.373 --> 00:36:08.155 That was discussed in the March plenary in SEAC and in RAC. 864 00:36:08.215 --> 00:36:10.176 I think it was done in the working group before, 865 00:36:10.177 --> 00:36:11.397 but there was a lot of discussion. 866 00:36:11.417 --> 00:36:11.957 I followed that. 867 00:36:11.958 --> 00:36:15.579 There was a whole day of discussions and quite a lot of discussion in SEAC as well. 868 00:36:16.080 --> 00:36:16.640 So basically, 869 00:36:17.100 --> 00:36:28.647 the consultation ended a couple of months ago and the dossier submitter has updated their proposal based on the consultation comments that were submitted to the committees. 870 00:36:29.451 --> 00:36:30.271 by the end of 871 00:36:30.612 --> 00:36:34.573 February. So not in time to be able to be considered in March, 872 00:36:34.713 --> 00:36:36.134 but it will be considered in June. 873 00:36:36.454 --> 00:36:43.717 And the plan is for RAC to conclude in June and for SEAC to come to an agreement of the opinion and launch its consultation. 874 00:36:43.777 --> 00:36:46.958 So the plan there is also to finish by the end of 2026. 875 00:36:47.078 --> 00:36:49.419 It's going to be a busy second half of 2026. 876 00:36:49.420 --> 00:36:50.100 Sounds like it. 877 00:36:50.140 --> 00:36:50.400 Yes. 878 00:36:50.460 --> 00:36:54.261 And Chromium 6 is yet another big file with far-reaching implications. 879 00:36:54.262 --> 00:36:56.742 So it's good to hear that the evaluation is progressing on schedule. 880 00:36:57.202 --> 00:36:58.423 And it'll be interesting to see how 881 00:36:58.883 --> 00:37:01.765 the consultation input shapes the next steps on that one. 882 00:37:02.225 --> 00:37:02.345 Yeah, 883 00:37:02.445 --> 00:37:02.805 of course, 884 00:37:02.825 --> 00:37:05.287 the committees will also consider the consultation comments. 885 00:37:05.288 --> 00:37:06.508 They are considering them already. 886 00:37:06.828 --> 00:37:07.008 Right. 887 00:37:07.188 --> 00:37:07.368 Okay, 888 00:37:07.388 --> 00:37:07.668 good. 889 00:37:07.969 --> 00:37:08.889 Thanks for clarifying. 890 00:37:11.210 --> 00:37:11.371 Well, 891 00:37:11.471 --> 00:37:13.252 that brings us to the end of today's episode. 892 00:37:13.612 --> 00:37:19.715 So we've covered a huge amount of ground from the science behind PFAS persistence to the committee's proposed approaches on grouping, 893 00:37:19.916 --> 00:37:21.036 non-threshold treatment, 894 00:37:21.156 --> 00:37:22.097 fluoropolymers, 895 00:37:22.217 --> 00:37:23.137 volatile PFAS, 896 00:37:23.638 --> 00:37:25.739 and the scale of PFAS emissions across Europe. 897 00:37:27.027 --> 00:37:30.908 What really came through today is just how complex this restriction proposal is, 898 00:37:31.128 --> 00:37:34.829 touching everything from textiles and cookware to medical devices, 899 00:37:34.949 --> 00:37:36.030 industrial processes, 900 00:37:36.490 --> 00:37:37.530 fluorinated gases, 901 00:37:37.630 --> 00:37:40.451 and even the question of how enforcement will work in practice. 902 00:37:41.111 --> 00:37:42.611 We also looked ahead at the next steps, 903 00:37:42.671 --> 00:37:44.152 so the 60-day consultation, 904 00:37:44.392 --> 00:37:47.413 which will be the key moment for stakeholders to contribute evidence, 905 00:37:47.813 --> 00:37:48.913 clarify uncertainties, 906 00:37:49.193 --> 00:37:51.214 and help shape the committee's final opinion. 907 00:37:51.974 --> 00:37:52.494 As we heard, 908 00:37:52.654 --> 00:37:54.075 this input is essential, 909 00:37:54.215 --> 00:37:55.695 especially in uses where the committee 910 00:37:56.063 --> 00:37:58.365 hasn't been able to reach very firm conclusions. 911 00:37:59.026 --> 00:38:00.107 So thank you for joining us. 912 00:38:00.147 --> 00:38:00.848 And thank you again, 913 00:38:01.128 --> 00:38:01.909 Roberto and Maria, 914 00:38:01.989 --> 00:38:03.030 for sharing your insights. 915 00:38:03.070 --> 00:38:03.470 Thank you. 916 00:38:03.590 --> 00:38:03.710 Oh, 917 00:38:03.750 --> 00:38:04.111 bye-bye. 918 00:38:04.992 --> 00:38:06.673 We'll continue following this process closely, 919 00:38:06.733 --> 00:38:07.294 as always, 920 00:38:07.394 --> 00:38:08.355 in future episodes. 921 00:38:08.615 --> 00:38:09.176 Until then, 922 00:38:09.516 --> 00:38:10.717 take care and stay safe. 923 00:38:12.338 --> 00:38:14.040 Safer Chemicals Podcast. 924 00:38:14.761 --> 00:38:16.883 Sound science on harmful chemicals.