Mar. 27, 2024
Dear Suppliers
FDK Corporation
Request to Our Suppliers：Reporting Scope of PFAS（Organofluorine compounds）
Thank you for your ongoing support for FDK Group Green procurement activities.
We would like to respond to the recent PFAS regulation with appropriate information in order toproperly assess the impact on FDK Group (hereafter called “our company”) products and toensure a replacement period for our suppliers.
PFAS is a generic name for chemical substances containing atoms of carbon and fluorine. PFAS
has many characteristics such as chemical resistance, flame resistance, and impervious toelectricity, and is used in various aspects of daily life and industry.
As you know, there are many types of PFAS, and each type has different properties. The scopeof substances covered by each law varies, and according to the U.S. Environmental Protection
Agency, there are approximately 12,000 different PFAS.
There is a concern that the PFAS listed in the list of chemical substances to be controlled bychemSHERPA, the Common Scheme for the Communication of Chemical Substance Information,
is not enough information.
Therefore, we would like to indicate the scope of PFAS that we would like our business partners
to report to us.
We would appreciate your cooperation in taking the following actions.
SincerelyDetails
1.

Reporting scope of “FDK Group Specified Chemical Substances List” Table 2
Reportable Substances No.203 ”Per - and polyfluoroalkyl substances”
Please survey and report based on the latest versions of the following substance lists, PFAS
definitions, and information tools.
Scope of Survey ①：list of chemical substances to be controlled by chemSHERPA
https://chemsherpa.net/tool#declarable

Scope of Survey ②：OECD（Organization for Economic Co-operation andDevelopment）
Substances falling under the following PFAS definitions.
PFASs are defined as fluorinated substances that contain at least one
fully fluorinated methyl or methylene carbon atom (without any H/Cl/Br/I
atom attached to it), i.e. with a few noted exceptions, any chemical withat least a perfluorinated methyl group (–CF3) or a perfluorinatedmethylene group (–CF2–) is a PFAS.
https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/terminology-per-and-polyfluoroalkyl-substances.pdf

Reference：Comprehensive Global Database of PFASs
https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/Substance list (xlsx) downloadable from "Comprehensive Global
Database of PFASs" in "Other publications" in the URL.
Refer to sheet “3_overview_with_CAS”

Scope of Survey ③：EPA（Environmental Protection Agency）
That structurally contains at least one of the following three substructures
https://www.ecfr.gov/current/title-40/part-705#p705.3(Per-%20and%20polyfluoroalkyl%20substances%20or%20PFAS)
Sub-structures① R-(CF2)-CF(R′)R″：

where both the CF2 and CF moieties are
saturated carbons.

② R-CF2OCF2-R′：where R and R′ can either be F, O, or saturated
carbons.

③ CF3C(CF3)R′R″：

where R′ and R″ can either be F or saturated
carbons.

Reference：Public List of TSCA PFAS for 8(a)(7) Rule
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tscasection-8a7-reporting-and-recordkeeping#additional-resources

Substance list (xlsx) downloadable from "Public List of TSCA PFAS for8(a)(7) Rule" under "Additional Resources" in the URL.
Refer to sheet “PFAS without CBI ID claims”

Reporting style：chemSHERPA
2.

supplement and notes on surveys and reports
About Scope of Survey ①
The URL is the website of JAMP（Joint Article Management Promotion-consortium), which
operates and manages chemSHERPA.
chemSHERPA is a scheme developed and promoted by the Ministry of Economy, Trade andIndustry (METI) to communicate information on chemical substances contained in products.
chemSHERPA list of substances to be managed covers major domestic and internationallaws and regulations and major industry standards. The latest version of the chemSHERPA
list can be downloaded from the URL.
Please report in chemSHERPA the relevant substance information.
About Scope of Survey ②
The URL is the website of OECD (Organization for Economic Cooperation and Development).
The OECD facilitating the exchange of information on PFAS and providing information tosupport safer alternative transitions worldwide. The OECD has published a "ReconcilingTerminology of the Universe of Per- and Polyfluoroalkyl Substances: Recommendations andPractical Guidance".
Please report in chemSHERPA the substance information that corresponds to the PFAS
definition in the blue box on page 8.
The list of PFASs (xlsx) published by the OECD is shown for reference. It can be downloadedfrom "Comprehensive Global Database of PFASs" under "Other publications".
Please refer to sheet “3_overview_with_CAS”*The reference list was published in 2018 and has not been updated since the PFAS
definition changed in 2021. When reporting, please report substances that fall under thePFAS definition.
About Scope of Survey ③
The URL shows the PFAS definition of the PFAS Data Reporting Rule in the U.S. Code ofFederal Regulations. The full text of the rule can be found in "Part 705".
Please report in chemSHERPA the substance information that corresponds to the PFAS
definition in the URL.
The list of PFASs (xlsx) published by the EPA (U.S. Environmental Protection Agency) isshown for reference.
Please refer to sheet "PFAS without CBI ID claims".
* The reference list includes PFASs that are generally identified in the TSCA inventory, but
not all substances that fall under the PFAS definitions are listed. Therefore, please report
substances that fall under the PFAS definition.
3.

Examples of Deliverables
PFAS has properties such as durability, stability, water and oil repellency, electrical insulation,and non-adhesiveness. As examples of delivered products, PFAS has been confirmed to becontained in various materials, insulating plates, tubes, ink, and electric wire coatings.
We request that our suppliers pay particular attention to the above parts and investigate andreport on them.

【For inquiries regarding this matter, please contact】
Quality Assurance Division, Quality Assurance Management Department
Person in charge：Kurata, Goto, Takizawa
E-mail：fdk_hcsm@fdk.co.jp
End of the document