On 22 September 2023 COCIR submitted its Second Report to the public consultation on the PFAS restriction.
PART II includes new analysis and expand some already presented in Part I.

• Analysis of uses in medical imaging and radiotherapy devices and other devices used in imaging or radiotherapy suites
• Analysis of alternatives
• Expanded socio-economic impact assessment
• Economic negative impact on industry
• Extended analysis of emissions of PFAS in the environment during the life cycle of devices

COCIR new estimate of PFAS use is around 23 tonnes per year in Europe for medical imaging and radiotherapy devices, almost all fluoropolymers, around 0,0025% of the estimated total usage of PFAS in EU and 0,04% of the total usage estimated for the medical devices sector in the restriction proposal.
In case a derogation is not granted for at least 13,5 years, with the possibility to extend it for specific applications, COCIR estimates a severe impact on both access to healthcare, with tens of millions of patients being potentially affected and on companies, with a loss in revenue in the order of 10 billions per year.