A future without PFAS? Between regulation and innovation.

Current discussions and regulatory developments  #

At the industry summit of chemical and pharmaceutical companies, which took place in Berlin in mid-September, Olaf Scholz spoke out against a total ban on PFAS in the EU. Although this is important for the industry in the short term, a final solution has yet to be found. 

Meanwhile, ECHA's Committees for Risk Assessment [RAC] and Socio-Economic Analysis [SEAC] reached preliminary conclusions on the proposed restriction of PFAS in the petroleum and mining sectors at their September meetings.

The discussions on the other two sectors - textiles, upholstery, leather, apparel and carpets [TULAC] as well as food contact materials and packaging - will be continued at the next meetings in November. 

The RAC agreed to revise the calculation of PFAS emissions in different sectors with a focus on the waste phase, e.g. emissions from waste disposal and incineration. The revised approach emphasizes the need to distinguish between PFAS particulate emissions [solid] and those leaching from materials. This distinction is important because the concerns related to fluoropolymer particles are different from those related to non-polymer PFAS.  

We have prepared a summary of the PFAS discussion from the minutes of the September meeting for you. Further information and current developments on the PFAS restriction procedure can be found on the PFAS topic page of ECHA or in the monthly newsletter of the Fluoropolymer Product Group of Plastics Europe. 

Shortages and lack of alternatives  #

The closure of fluoropolymer production at 3M/Dyneon and Solvay means that more than 50 percent of production capacity for fluoropolymers will be lost in Europe in a very short space of time. Plastics and elastomers based on fluoropolymers in the chemical industry affect you and us. 

There are currently no proven alternatives to PTFE. PFAS-free PTFE is not possible. Alternative plastics do not work for many applications.

Task Force High Performance Plastics#

In 2023, we founded the “High Performance Plastics in the Chemical Industry”. There, we develop solutions together with representatives of the chemical industry. On availability bottlenecks, alternative materials, efficient material testing or release scenarios for new materials.

As part of our work, we were able to win over the Federal Institute for Occupational Safety and Health [BAuA] for a PFAS dialog in April 2024 and provide decisive impetus. The aim was to enable the BAuA to better understand the consequences of a universal PFAS restriction and to find practicable solutions for the industry.

In addition, the Task Force is conducting tests with around 20 alternative materials to TFM 1600 for use in static and dynamic applications. Initial results show that in static applications the tests according to DIN EN 13555 show hardly any differences in material performance. In dynamic applications, however, considerable differences become apparent, which make further investigations necessary.

Events and knowledge transfer #

Jörg Skoda, Head of Applications Engineering at IDT, talks about the results from the Task Force’s test series and the latest findings on PFAS in a podcast with Industriearmaturen und Dichtungstechnik in mid-November.  

At our symposium, which will take place on November 19 in Frankfurt, Dr. Michael Schlipf, CEO of pro-K, and Martin Säckl from Daikin will speak about the PFAS problem from different perspectives.

News on the restriction process

Summary of the PFAS discussion from the minutes of the September meeting, pages 15-18.

At the September meeting of the Risk Assessment Committee [RAC], various sectors were discussed in connection with the restriction of per- and polyfluorinated alkyl substances [PFAS]. The focus was on:

1. Waste emissions and waste treatment
2. Textiles, upholstery, leather, apparel and carpets [TULAC]
3. Food contact materials and packaging
4. Oil and mining

Findings from the discussions#

1. Emissions and waste treatment 
   • Fluoropolymers emit both particulates and non-polymeric PFAS during their life cycle, especially during processing and combustion. It is important to distinguish between particulate emissions and leaching substances, as the associated risks are different. 
   • Incineration at high temperatures [above 1100 °C] is considered to be the most effective method of destroying PFAS, while lower temperatures can lead to the formation of more stable, short-chain PFAS. 
   • Landfilling is considered a significant source of PFAS emissions to the environment. A conservative emission factor for the release from landfills was determined. 
2. Textiles, upholstery, leather, apparel and carpets [TULAC] 
   • The assessments of emissions and possible alternatives have largely been completed, although specific issues relating to protective equipment still need to be clarified. 
3. Food contact materials and packaging 
   • Preliminary agreements have been reached on the volumes, emissions and risks of the alternatives, but work is continuing on detailed issues. 
4. Oil and mining 
   • Some alternatives for PFAS, e.g. in foam inhibitors, are considered safer, while others have significant risks. The proposed alternatives for oil and gas tracers have similar or even more severe hazard profiles.

Next steps#

A revised RAC statement is being prepared based on the comments and discussions received.

• Further sector-specific analyses and discussions are planned for the next meetings, particularly in the areas of textiles, food contact materials, packaging and construction products.
• Specific risk mitigation measures [RMMs] are being further developed, particularly in relation to emissions in the oil and mining industry.

Other sectors#

1. Building products [not yet conclusively discussed]
2. Fluorinated gases
3. Transportation and energy

Involved parties#

In addition to the dossier submitters from Denmark, Germany, the Netherlands, Norway and Sweden, numerous interest groups from various industries and NGOs were involved, including PlasticsEurope, ClientEarth, CONCAWE, EFPIA, MedTech, Other representatives of the textile, chemical, energy and food packaging industries.

The summary of the minutes was generated with AI.

Schedule#

The next meeting of the RAC is planned for November 2024. At this meeting, discussions on textiles, food contact materials, packaging and construction products will be continued. It is expected that specific information on fluorinated gases, transportation and energy will be discussed in subsequent plenary meetings after November.

The table below provides an overview of the current status of the assessment and the upcoming plans of the Committees to assess the potential impact of the restriction in different sectors using PFAS.

The conclusions agreed at the RAC and SEAC meetings are provisional until the committees have completed their assessment of the entire restriction proposal [including all areas of application] and adopted their opinions. These opinions will then be made public.

The final decision on the restriction will be taken by the European Commission together with the EU Member States.

1. Oil and mining

   RAC & SEAC:

   • Discussion: September 2024
   • Preliminary conclusions: September 2024
2. Textiles, upholstered furniture, leather, apparel, carpets [TULAC]

   RAC & SEAC:

   • Discussion: September 2024, November 2024
3. Food contact materials and packaging

   RAC & SEAC:

   • Discussion: September 2024, November 2024
4. Building products

   RAC & SEAC:

   • Discussion: planned for November 2024
5. Applications of fluorinated gases

   RAC & SEAC:

   • Discussion: planned for the next meetings in 2025
6. Transportation

   RAC & SEAC:

   • Discussion: planned for the next meetings in 2025
7. Energy

   RAC & SEAC:

   • Discussion: planned for the next meetings in 2025