DIGITALEUROPE's Views on Spare Parts Provision in SEAC Opinion regarding PFOA Restriction

DIGITALEUROPE, the association representing the digital technology industry in Europe, welcomes the opportunity to provide further comments on the spare parts provision as currently contemplated by SEAC in its final opinion on the restriction of Perfluorooctanoic acid (PFOA), PFO-salts and PFO-related substances, adopted on 4 December 2015 and discussed during the stakeholder meeting organized by DG GROW on March 15th.

DIGITALEUROPE has been actively involved as a stakeholder in the process by providing regular feedback on the restriction dossier. Therefore, we would like to further comment on the spare parts provision now that the EU Commission is in the process of drafting the final proposal for amending REACH Annex XVII, in order to ensure that the proposal fully reflects the ‘repair as produced’ principle.

As a reminder, OEMs of electronic products do not use PFOA directly for the manufacturing of electrotechnical products. Fluoropolymer is a key base material used in electronics and in various applications, yet we don’t have a direct influence on the upstream process of chemical used for its manufacturing.