PFAS - What's behind it all
ECHA proposes to restrict or completely ban the use of PFAS in a number of applications.
ECHA (European Chemicals Agency) published a dossier on March 7, 2023 for a total or restricted ban of more than 10,000 PFAS (perfluorinated and polyfluorinated alkyl substances) in the EU, which is still under discussion and review.
Most comprehensive restriction dossier in REACH history.
The proposal contains one of the most comprehensive restriction dossiers since REACH came into force, with a broad ban on more than 10,000 PFAS. Fluoropolymers will also be included unless there are transition periods or exemptions.
PFAS in many Industrial Processes and Products
Because of their resistance to extreme temperatures, water and oil repellency, and electrical insulation properties, PFASs are widely used in many industrial processes and products, including surface treatments, sealants, coolants, and firefighting foams. In addition to industrial uses, PFASs are also found in everyday products such as coated pans, rainproof clothing, baking paper, and many other products.
The resistance of PFAS chemicals is a strength that enhances the performance of products and enables their use in various industries. However, this resistance to degradation and decomposition is also a weakness because they are very persistent. This means that they can accumulate in the environment and enter the human body through the food chain, which is considered a health risk.
Public consultation on a REACH restriction proposal for PFAS since 22.03.2023
The consultation is open until 25.09.2023 and can be accessed online on the ECHA website. It is important for companies to review their individual impact and clearly state the impact of the restriction ban during the public consultation.
Please take the opportunity to participate in this consultation – it is not necessary to answer every question in the online consultation form. Early participation, based on as concrete and informed information as possible, will allow you to be involved at an early stage in the deliberations and opinion-forming of the relevant ECHA Committees.
On this page we have compiled answers to frequently asked questions and important information on PFAS.
FAQ
What exactly is PFAS?
PFAS is an acronym for Per- and Polyfluorinated Chemicals. The foundation for this group of substances was laid in the 1940s. Today, depending on the source, this group includes more than 10,000 different substances.
They are defined as fluorinated substances containing at least one fully fluorinated methyl or methylene carbon atom (with no H/Cl/Br/I atoms attached). With a few known exceptions, any substance with at least one perfluorinated methyl group (-CF3) or perfluorinated methylene group (-CF2-) is a PFAS. PFAS are divided into non-polymers and polymers (including fluoropolymers and polymers with a fluorinated side chain).
Where are PFAS used?
PFAS are characterized by their water-, grease- and dirt-repellent properties, as well as their chemical and thermal stability, which is unmatched by any other group of substances. As a result, they are found in countless products ranging from consumer goods to industrial applications.
How are we affected as a customer of Gummiwerk KRAIBURG?
All fluoropolymer compounds based on FKM.
Gummiwerk KRAIBURG Compound Code:
FKM = VA
FFKM = VF
FVMQ = (FF)
FEPM = VD
contains PFAS.
Why should PFAS be regulated/banned?
By their nature, PFAS do not break down naturally and therefore accumulate in the environment (soil, water, fish and ultimately in the human body). Some are suspected or confirmed to be reproductive toxicants, harm unborn children, cause cancer, or affect the human endocrine system. They are sometimes called “persistent chemicals” because they can take centuries to break down.
Are PFAS not yet regulated?
Over the years, individual representatives such as PFOS, PFOA and PFCA have been regulated in various regulations. These range from complete bans to temporary exemptions for certain applications. For some other substances (PFHxS, PFHxA) procedures are in progess.
Who and what is behind this dossier?
Due to the above mentioned situation, 2020 institutions from five countries (Germany, Netherlands, Sweden, Norway, Denmark) decided to work towards a regulation. On February 7, ECHA published the comprehensive dossier. It covers 15 sectors/application areas (transport, food, energy, etc.), for some of which temporary derogations (5 or 10 years) are proposed. Several stakeholders submitted a draft to ECHA to classify the group of fluoropolymers as a “Product of Low Concern (PLC)” and exempt them from a possible ban. This was not followed.
Does the publication mean a ban?
No, the publication does not yet mean a ban. Rather, it is the start of a process defined by EU regulations, which could lead to the publication of a “ban” directive in 2025/2026. The actual end for PFAS and related fluoropolymers will depend on transition periods and derogations.
What options do I have as a user of fluorinated polymers?
The European Chemical Agency ECHA started a public consultation on 22nd March 2023 to investigate a possible restriction of PFAS. Affected stakeholders – including industrial users – are granted six months to submit their assessment and objections on the following issues:
- Due to their properties, PFASs make a critical contribution to the achievement of policy goals such as the “green deal”, CO2 reduction, waste reduction, etc.
- Sometimes there are no real alternatives available at the moment. There have been many unsuccessful attempts in the past. Here it would be helpful if you could provide data/facts/specifications that, for example, the durability of an FPM seal cannot be matched by any other polymer.
- The long time lag from any development of alternatives to OEM release and the associated costs.
- Socio-economic factors (loss of sales/jobs/wealth, etc.).
Why is it important to participate in the consultation?
It is important that affected stakeholders share their concerns and information during consultations to ensure that all relevant aspects can be considered. In this way, an informed decision can be made by the responsible decision-makers.