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AGC Chemicals Europe

AGCCE

AGCCE is a subsidiary of AGC Inc, Japan.

Lobbying Activity

Response to Persistent organic pollutants: long-chain perfluorocarboxylic acids, their salts and related compounds.

19 Dec 2025

AGC welcomes the opportunity to provide feedback to the proposed amendment to Regulation (EU) 2019/1021 concerning long-chain perfluorocarboxylic acids (LC PFCAs), their salts, and related substances. Unintentional Trace Contaminant (UTC) Levels & derogation: AGC supports FPGs request for the proposed independent UTC levels for two distinct groups: C9-C14 LC PFCAs and C15C21 LC PFCAs, including derogation for PTFE micropowders produced by ionising irradiation and thermal degradation. These levels should also apply to mixtures and articles. 1. Missing analytical methods Currently there are no analytical standards for measuring C15, C17, C19, C20, C21 PFCAs making proof of compliance and the enforcement an issue for any of the fluoropolymers supplied to the EU market. To our knowledge, 19F NMR can currently quantify organic fluorides, but with much higher detection limits comparing to LC-MS/MS which, for the sum of C15-C21 necessitates a threshold at 15 ppm. The method for measuring PFCAs by 19F NMR will need to be developed which could take considerable amount of time. 2. PTFE micropowders derogation AGC Chemicals Europe, Ltd.s PTFE micropowders, supplied to EU market, are mainly manufactured at the UK plant. This can be done via the irradiation (off-site) or may be performed using thermal degradation. During these processes, C9-C21 PFCAs are generated as unintentional trace contaminant and may persist in the final product. PTFE micropowders are incorporated in various products, mixtures and articles by our customers. Concentrations vary depending on the product and application and may reach levels that exceed the proposed concentration limit. Therefore, not only PTFE micropowders, but the mixtures and articles in which they are incorporated, need the same concentration limit. The extension of the derogation to mixtures and articles containing PTFE micropowders is suitable from a compliance and enforcement standpoint. 3. Entry into force The effective date of the proposed EU POPs Regulations should not be earlier than 12 months after the Stockholm Decision SC-12/12 comes into force. Conclusion AGC therefore requests that the EU POPs Regulation: (i) sets separate UTC limits for C9C14 and C15C21 LC PFCAs aligned with the FPG proposal; (ii) provides the requested derogation for PTFE micropowders produced by ionised irradiation or thermal degradation, recognising that for proof of compliance for the sum of C9C21 PFCAs, current limitations with existing analytical method necessitates an elevated concentration limit and that more time for development of analytical method is needed; and (iii) sets an entryintoforce date that is no earlier than 12 months after the Stockholm Convention decision becomes legally effective, to advance development and validation of robust analytical methods. This would ensure that regulatory limits are technically measurable and enforceable, reflect the current state of analytical science, and avoid disproportionate impacts on critical fluoropolymer applications, while still supporting the overall objective of minimising LC PFCA emissions. Please find our comments in the attachment. Thank you for your consideration.
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