You may not be aware of the current initiative of five European countries - Germany, the Netherlands, Denmark, Sweden and Norway in coordination with the European Chemicals Agency (ECHA) - to restrict the manufacture and use of per- and polyfluoroalkyl substances (PFAS), a diverse group of over 4,700 chemicals that contain carbon-fluorine bonds.
What are PFAS ?
PFAS are a large, complex, and ever-expanding group of manufactured chemicals that are widely used to make various types of everyday products. For example, they keep food from sticking to cookware, make clothes and carpets resistant to stains, and create firefighting foam that is more effective. PFAS are used in industries such as aerospace, automotive, construction, electronics, and military.
PFAS include PFOA, PFOS and GenX compounds many of which have been phased out of use in most western economies but continue to be used extensively elsewhere in the world.
As PFAS do not break down and can accumulate in the human body over time, there is evidence that sustained exposure to PFAS can lead to adverse human health effects.
Fluoropolymers are one specific class of PFAS that possess a unique combination of properties that make them essential to modern life and a wide variety of industries. Their properties include fire resistance, weather resistance, temperature resistance, chemical resistance, non-wetting and non-sticking properties, and high-performance dielectric properties.
The proposed PFAS Restriction under REACH is to potentially restrict or ban the use of PFAS in non-essential applications across the EU by 2025, with allowance for a transition period.
These national REACH authorities are considering regulating all PFAS as one group simply based on structural characteristics, ignoring safety, societal benefits, and existing regulatory frameworks governing such substances. Essential uses of PFAS would be exempt from the scope but currently there is no formal definition of what constitutes an ‘essential use.’
Chemours as one of the major global manufactures of Fluoropolymer materials maintains that the expanded definition of PFAS being applied by REACH is too broad to enable effective, science-based assessment and regulation of chemical compounds. They state that ‘Fluoropolymers and F-gases are critical for nearly every major sector of the economy, offer unique combinations of properties, and are safe for their intended uses. Furthermore, no universal alternatives exist that offer the same unique combination of properties, uses, and societal benefits that F-gases and fluoropolymers provide.’
What will happen now ?
It is important to note that this is the first of many official steps in a Restriction procedure and the formal process envisages at least two opportunities to incorporate stakeholder feedback and adapt the final regulation. Chemours is following the progress of this Restriction closely and will continue to engage with the relevant authorities as well as trade partners, including MacLellan Rubber, and associations to provide information and relevant data.
MacLellan Rubber does not believe that fluoropolymers should be considered in this Restriction. They are vital across a wide spectrum of industries, offer unique combinations of properties, and are safe for their intended use.
There will be opportunities to participate in this Restriction process, for example through an upcoming questionnaire which will be published by the Competent Authorities after the publication of the ROI. We would like to urge everyone using Fluoropolymer based products including Viton’s to consider engaging in this questionnaire to raise awareness of this potential Restriction and the impact it could have on the gasket and sealing industry.