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Answer (EN)
The entry included in Part A of Annex I to Regulation (EU) 2019/1021 on Persistent Organic Pollutants addressing perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds applies to PFOA-related compounds which, for the purpose of the Stockholm Convention, mean any substances that degrade to PFOA, including any substances (including salts and polymers) having a linear or branched perfluoroheptyl group with the moiety (C7F15)C as one of the structural elements. The following compounds are excluded: (i) C8F17-X, where X = F, Cl, Br; (ii) fluoropolymers that are covered by CF3[CF2]n-R’, where R’=any group, n> 16; (iii) perfluoroalkyl carboxylic acids (including their salts, esters, halides and anhydrides) with ≥ 8 perfluorinated carbons; (iv) perfluoroalkane sulfonic acids and perfluoro phosphonic acids (including their salts, esters, halides and anhydrides) with ≥ 9 perfluorinated carbons; (v) perfluorooctane sulfonic acid and its derivatives (PFOS), as listed in this Annex.The restriction included in entry 68 in Annex XVII to REACH for C9-C14 PFCAs, their salts and C9-C14 PFCA-related substances. Entry 68 applies to the following C9-C14 PFCA-related substances:Substances having a perfluoro group with the formula CnF2n+1- (a) directly attached to another carbon atom, where n = 8, 9, 10, 11, 12, or 13, including their salts and any combinations thereof; (b) that it is not directly attached to another carbon atom, where n = 9, 10, 11, 12, 13 or 14 as one of the structural elements, including their salts and any combinations thereof.The following substances are excluded from this designation:-CnF2n+1-X, where X = F, Cl, or Br, where n = 9, 10, 11, 12, 13 or 14, including any combinations thereof, and -CnF2n+1-C(= O)OX' where n> 13 and X'=any group, including salts.The entry defines, for its purposes, C9-C14 PFCA-related substances as substances that, based on their molecular structure, are considered to have the potential to degrade or be transformed to C9-C14 PFCAs.More information on What are the PFCA and PFCA-related substances in the scope of Entry 68 of Annex XVII to REACH and what substances are excluded? can be found in Q&A 1906.Substances, such as 8:2 Fluorotelomer acrylate (CAS No27905-45-9), show structural elements that are described in both entries: the entry included in Part A of Annex I to Regulation (EU) 2019/1021 for perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds and entry 68 in Annex XVII to REACH. As a consequence, both entries apply to the substance.For determining which are the relevant regulatory obligations for these substances both entries should be considered. For practical purposes, the most restrictive obligations described in the two entries should be applied, including concentration limits.