PFAS: Light at the End of the Tunnel? Outlook for 2026

Simone Wilson

Transition periods, exemptions, sector-specific solutions. Will the PFAS discussion, which is being and must be conducted at EU level as part of the restriction process, become a never-ending story, or is there light at the end of the tunnel? The ECHA committees met in December. The Committee for Risk Assessment plans to adopt its opinion in March, while the Committee for Socioeconomic Analysis intends to present a draft for a second public consultation by then. PFAS, what now? With this question in mind, today we look at what is coming in 2026 and what would be desirable, taking into account progress and environmental aspects. Welcome to the IDT podcast, which provides new perspectives and fresh ideas for industry and sealing technology. Today, I am pleased to welcome Dr. Gudrun Lücke-Brunk, Head of Chemical Legislation Issues at Covestro, to the discussion.

Dr. Gudrun Lücke-Brunk

Good afternoon, hello.

Simone Wilson

My colleague Jörg Skoda, Technical Director at IDT, who has been following the PFAS discussion from the industry perspective from the very beginning, is also here with us today.

Jörg Skoda

Hello Simone.

Simone Wilson

Hello Jörg. My name is Simone Wilson. I am the CEO of sealing specialist IDT and am delighted to be hosting our podcast for the second year running, guiding listeners through the exciting topics we cover. Ms. Lücke-Brunk, you have a doctorate in chemistry and have been responsible for regulatory issues in chemical law at Covestro for almost 20 years. This makes you a key authority on requirements in the areas of health, environment, and sustainability of materials. At school, I felt more at home with biology than chemistry, so my first question is: how can I visualize your area of responsibility in concrete terms?

Dr. Gudrun Lücke-Brunk

My name and my job title, Head of Chemicals Legislation, say it all. I support chemical legislation processes through associations, through Covestro itself, and above all, the REACH regulation is my main area of responsibility. I have also registered some of our substances myself, and the registrations have to be reviewed and updated on a regular basis. It's a never-ending story, if you will. But my area of expertise is also authorization and restriction, especially the restriction process. And accordingly, I have the honor of leading the PFAS task force for Covestro, which brings us nicely to the topic at hand.

Simone Wilson

And when you say restriction proceedings, in your career, which is not exactly short, how many restriction proceedings have there been?

Dr. Gudrun Lücke-Brunk

There are some where we are affected to a greater extent and others where we are affected to a lesser extent. Naturally, where Covestro is affected, information must be provided so that the restriction procedures can be designed in a practical manner. but also information must be provided to the legislator, because the legislator does not have some of the industry information that is available in the industry in order to be able to work in a practical manner and, at the end of such a procedure, to have an enforceable restriction that can then also be monitored and implemented in companies.

Simone Wilson

Mhm, and how do I imagine that in concrete terms? So, you represent Covestro's interests in such proceedings or look specifically at what that would mean for Covestro and how we should position ourselves there?

Dr. Gudrun Lücke-Brunk

Yes, I don't have the information myself, but the information is provided to me by our business units, which are right there in the market and also know the supply chain inside out. And this information is also very, very important and must be entered into public consultations. In order to then also include a specific restriction procedure in a specific, it is not lobbying and it is also not advocacy, in this case it is simply a transmission of information that is available in the industry and that could be useful for the restriction procedure.

Simone Wilson

And that means you are then the central point where this information from the, I.

Dr. Gudrun Lücke-Brunk

Collect the information, exactly. There are always specific questions that need to be answered, which of course are not readily available. Many people think we just pull out a drawer and know everything. Of course, that's not the case. Many questions have to be worked out first, which of course also means that a certain amount of time is needed to make the information available.

Simone Wilson

Mhm, OK, let me just ask you, have you ever been caught off guard? I mean, when it comes to time, I imagine that it simply takes a lot of time to gather this information and then present it.

Dr. Gudrun Lücke-Brunk

Yes, you try to start quite early, but you know from experience that with certain things, like writing a paper for university or even a thesis, you always end up running out of time, that's usually the case. Or pressure, or pressure, exactly.

Simone Wilson

Then I would be interested to know how the regulatory issues you deal with have changed over the last 20 years.

Dr. Gudrun Lücke-Brunk

They have changed in the sense that in the past, only individual substances were ever looked at. Yes, now we are moving towards a group approach. PFAS is a very good example of this, where over 10,000 substances are to be regulated at once without looking at each individual substance separately or forming subgroups, for example. This makes it very comprehensive and also makes it difficult to gather information on over 10,000 substances, which can then be dealt with accordingly in the restriction procedure.

Simone Wilson

Yes, I can well imagine. Jörg, you have been with I. D. T. for more than a quarter of a century and became technical director this year, which I am particularly pleased about. How have the issues and topics in sealing technology changed?

Jörg Skoda

Yes, when I started, things were relatively chaotic. People weren't trying to work together, including our competitors, I would say. They tended to work against each other rather than with each other. A lot has changed since then. Now, people try to solve technical problems together, as can be seen with the TA-Luft and PFAS issues. So we try to speak with one voice. Of course, there are always exceptions, but I believe that people are actually trying to take this problem seriously. That was already the case with T. H. Luft, and it's no different with PFAS. In my opinion, working together to find solutions is the only way to do it, no matter what you're doing.

Simone Wilson

Hmm, when I think about sealing technology, asbestos substitutes, TA-Luft, and PFAS come to mind. So, are those the three big ones?

Jörg Skoda

Those are three big ones, for example, but there are also many other smaller ones, such as TRGSN, which are technical rules for flowing gases, so you have to say that the portfolio of good cheer is relatively large. It's interesting that you mentioned these three points, because when asbestos was banned, the Federal Environment Agency made a recommendation. Chlorinated polymers and PFAS, and the document is from 1984. The advantage back then, compared to the current procedure, was that there was a solution. No, the authorities were ready to say, we'll test this externally and we won't just say we're banning something like asbestos, but you have the alternatives. And that's exactly the problem we often have with PFAS, that we don't have any or only have very few.

Simone Wilson

Mhm, and that brings us to the heart of the matter. In this context, between user-related, i.e., specifically related to a product and its function, Ms. Lücke-Brunk, addressing both of you, how can the ongoing PFAS restriction procedure be classified in this context?

Dr. Gudrun Lücke-Brunk

Yes, as I said, on the one hand, there is the group approach, which is very extensive. Yes, we also see that, let's say, the dossier submitters, and especially Ecker, were overwhelmed by the flood of information that was available, with many people entering information that they believed was important for the restriction procedure. Ecker received over 5460 or so contributions to the public consultation, and these had to be processed first. Unfortunately, what I am now seeing is that, contrary to the actual requirements or provisions or announcements, some sectors are no longer being looked at by the ECA committees. These are, in particular, the applications in machinery, which are very, very important to us, and, of course, the sealing applications. Unfortunately, these are not being dealt with by the ECA committees, and it is questionable what the Commission will do with these sectors. Yes, and accordingly, it is still dragging on. Yes, we will have the Ecker Opinion in 2026, which will then be handed over to the Commission. But then it will be the Commission's turn to consider what regulatory text it will formulate at the end of 2026 based on all the information, including the Eckerdraft Opinion or the Ecker Opinion, which will then be submitted to the Beach Committee for a vote.

Simone Wilson

But do you have such a procedure, or something similar, in this dimension, or perhaps with such possible consequences in the past?

Dr. Gudrun Lücke-Brunk

Yes, restriction procedures can take many forms. They can prescribe how a substance is to be used. A prominent example is the restriction on isocyanates. Here, training is a prerequisite for the products to be further processed. But a restriction procedure can also be very, very strict and prohibit certain manufacturing processes or even placing products on the market. Yes, there is a wide range of things that can be done with a restriction procedure. Transition periods can also be set, which are the subject of heated debate here, including at Pifas. This also has to be specified and, um, yes, and you can also say how a substance must or can be handled or used in a restriction procedure. It's a wide range, and the regulator should actually look at all the possibilities that such a restriction procedure offers and not, from the outset, work toward a complete ban in a short period of time, so to speak.

Simone Wilson

And that is the key difference you see in the PAPERS process.

Dr. Gudrun Lücke-Brunk

I see that because it's so diverse and because so many applications are also affected by PFAS, by PFAS-related issues. Theoretically, you would have to look at the pro-substance and application combination, you would have to look at everything, but as I said, then you probably wouldn't be finished for another 10 years. Yes, and there is a certain amount of political pressure to bring this PFAS process to an end.

Simone Wilson

So that means that the procedure itself, or a restriction procedure itself, is ultimately part of your day-to-day business, but on the scale of the PEFAS restriction procedure, where everything is lumped together, you consider that to be rather unusual.

Dr. Gudrun Lücke-Brunk

As extraordinary, but also as critical, yes, because it can certainly affect applications that haven't been looked at very closely, which of course are value-adding and add value for the business and perhaps also for, let's say, not, I come from a company that is relatively at the beginning of the supply chain, but at the end of the supply chain there are companies that are very, very specialized, and for some of them, the elimination of a substance can also mean that they have to give up their business.

Simone Wilson

Yes, indeed. Jörg, you just said that I made the connection between asbestos and PFAS and left out a few things in the middle, namely that the recommended replacement material was PTFE, or fluoropolymers. And now we're faced with the challenge that they're no longer supposed to be used. That means that the classification of PFAS in this context has very specific implications.

Jörg Skoda

Definitely, but of course we have to say that we are human beings and we are always learning new things. It's not as if what we say today will be completely different in 10 years' time. Maybe in 20 years' time we'll say that the PFAS issue has been blown out of proportion and that we've already found so many substitutes that we didn't really need to talk about it at all. But that's not the case at the moment. PFAS, if you describe the whole thing a little bit from our point of view, then it's like this: we learned about the issue. My initial technical assessment was, yes, how can anyone have such an attitude? But then you realize, and we as IDT sought discussions with the authorities, that you can exchange ideas, and for me that's the be-all and end-all You can think about a lot of things, you can look at the dossier for the first time and simply realize that some areas have been overlooked. In January last year, there were eight new sectors that weren't necessarily described very well by the BAuA. For example, sealing refers to chemistry, not just sealing, it has to be said, or pressure equipment, which doesn't mean pressure equipment, but rather 3D printers. Nevertheless, it says they have identified eight sectors that were originally forgotten, and once you know that they have been forgotten, you should take them into account. And when you hear now that these eight sectors that were left out are not to be taken into account, you can lodge an objection, and I think Ms. Lücke Buckler has something to say about that, but ultimately we are really at this point right now and we are saying, yes, we are actually back at square one, back to the original, because if the eight things that are important, these eight sectors, are not taken into account, we have a problem and, in my opinion, there is still a lack of communication. We are in close contact with the BAuA, and I would like to thank the BAuA once again for sitting down with us and listening to our arguments. But if Europe decides to ban it completely, then we will have a massive problem, not a small one.

Simone Wilson

Mhm, well, you mentioned that. They just mentioned it too. Last year, I thought there was a hint of euphoria in the air when new sectors and applications were included in the PFAS restriction proposal and it finally seemed that some differentiation was possible. Now, exactly that is in danger of disappearing again. In the second consultation, the additional areas are once again being ignored, and how this will be decided is completely unclear. I would describe it as a state between hope and fear, which is why I would be really interested to know what will actually happen if the proposal is adopted as it currently stands. In other words, what would this mean in the short term and in practical terms for companies and applications?

Dr. Gudrun Lücke-Brunk

So first of all, you have to see that you fit in. There will be a second public consultation, which will start after the publication of the SEAG Draft Opinions, probably in March, and there will be two different types of questions. On the one hand, there will be relatively specific questions, which are already available, for the sectors that have taken a close look at the corner. And there will be general questions for those who have not taken a close look at the corner. It is advisable to start preparing now and to prepare the questions. And not only, let's say, for sealing applications or, let's say, the applications, but for all affected companies, the call is once again: participate in the next consultation and prepare the questions that are already available. The corner has published guidance. On December 17, there is an appeal: prepare the questions now. The consultation period is only 60 days, which is very, very short to gather information. Then we have to see what the SEAG, which is the committee for socioeconomic analysis, does with these questions and how this will influence the socioeconomic analysis for the restriction procedure, which will ultimately result in the SEAG's opinion. Unfortunately, there is little we can do for the RAK. At the beginning, the focus was always on emissions, and the focus is still on emissions, which of course must be reduced if exemptions are to be considered or if exemptions are desired and if the exemptions are to be implemented. Then emissions must also be reduced, and it must also be demonstrated that emissions are being reduced. That costs money, it costs investment, for example investment in wastewater treatment plants to reduce PFAS in wastewater, if necessary, including in production processes. Accordingly, planning is already underway to determine what the situation will be like and what a company will have to do once the restriction procedure comes into force, including the corresponding transition periods.

Simone Wilson

Hmm, but as I understand it from the December meetings, risk assessment has been completed. So now it's just about socio, just socio-economic analysis. But I'd like to come back to that point. I understand from what you've said that nothing has been finalized yet, but if we were to say that it had been finalized and the world looked the way it does now, what would that mean in concrete terms?

Dr. Gudrun Lücke-Brunk

Well, we are sitting here as sealant users, so what does that mean in concrete terms at the moment? PFAS may continue to be used in plants and also for spare parts until the end of the service life of the existing plants. However, if you want to build a new plant 13.5 years after the regulation comes into force, which is the transition period at the moment, this plant may no longer have any PFAS components. And knowing full well that we don't currently have, let's say, a substitute for PFAS materials in other parts. Yes, work is being done on this, which is a good thing. And we also say that where we can replace PFAS and where there are technically feasible alternatives, and also, let's say, economically viable ones, that also ensure the safety of the systems. Of course, we are then happy to replace PFAS, especially since PFAS is not the cheapest material available. Yes, but if there are no substitutes, even in 13.5 years, then we will run into a big problem, especially with new investments. Because no one wants to say in 13.5 years, "I still don't have a substitute and I'm not allowed to build any more plants because I absolutely need PFAS and without PFAS material I may not be able to operate the plant safely anymore." And that is, of course, also a reason why we want to protect the environment. We want to protect people and, of course, we want to operate our plants safely.

Jörg Skoda

Yes, I'd like to have a glass of wine, but that's exactly the point that many people don't want to admit. Many people always say that the industry doesn't want to do anything. I myself am involved with both the authorities and the industry, and I can see that the industry is already doing what it can. For example, we have a customer who uses, let's say, seals in P.T.W. and graphite. If we were to describe the seal savings he has as 100%, he could replace 70% of them with other known materials. That leaves 30% for which there is no alternative. The search based on cost and durability takes time, and even though I always hear, "Yes, we have a substitute for PFAS," and various manufacturers make these marketing claims, when you question it, it's for a very specific application, for a system. You often hear that polyethylene is the material you can use. Yes, if I have 80-degree water, that might work, and it might work for other things, but it doesn't work in chemistry, and I think that's the thing. There's a nice example you once gave with the berries, and I still think it makes sense. We see rowan berries, which are poisonous, and we don't want them, and what we're actually doing with this whole process now is, OK, we have rowan berries, we have strawberries, we have chickens, they're all berries, and we ban them, regardless of whether the others are good or not, because there's one group that's bad. If you look at the numbers, I tried to find numbers, to research, what are we even talking about, we're always talking about 10,000. If you read up on it, yes, but of the 10,000, only 7,000 are supposedly needed. Please note that the numbers should be taken with a grain of salt because they fluctuate quite a bit. If you then ask how many of them are really critical, at least the BAuA gave me a rough estimate, we're talking about 350, which is still too many, and we, the industry and the authorities, want the same thing, they want to reduce, but they want to reduce sensibly, and that's what I thought in January, through the eight sectors, they realized that something was missing, and now things are moving in a completely different direction. If I were allowed to decide for Europe, I would have to say that the Europeans, i.e., those who will ultimately decide or process it further, are refusing to work. So, to be perfectly clear, it's a refusal to work, because they've seen that if you have 5,400 objections, it takes time, so you just work overtime. No, but that's just a side note, I thought.

Dr. Gudrun Lücke-Brunk

For me, or else you say from the outset, I am in favor of the ECA concluding this in 2026 as a political target, but rather say that the ECA should look at everything closely, that the committees should really look at the information they have received.

Simone Wilson

But the uncertainty at this point is not going away. So what struck me a little bit when I listened to you is that thirteen and a half years—we're actually talking about old plants, because everything you're planning now has to be planned with these Damocles' swords hanging over you.

Dr. Gudrun Lücke-Brunk

Lead time is planned, which means 13.5 years for the application itself, but planning starts much, much earlier and certain investment decisions are made. Do I prefer to invest as a global company that operates globally, do I invest in the European region with certain uncertainties, or do I invest in another region of the world where there may be less regulatory pressure, or where there may also be better economic conditions, energy prices are also an issue, these are definitely strategic decisions that such a company has to make.

Simone Wilson

Yes, and what you said again, Jörg, that also came up with them, namely that there should be no PFAS in a new plant, so to speak. That sounds like 100%, and I then asked myself how I could guarantee that 100%. So your 7030 rule is already a reduction where possible, certainly yes, but I think it would be very, very difficult to achieve a 100% solution.

Dr. Gudrun Lücke-Brunk

Even now, no revision clause is actually enshrined in the legal text after a certain period of time. It is always pointed out that the Commission can review any restriction at any time and also look at how far the development of substitutes has progressed. Yes, but at the moment, the legal text does not contain a revision clause stating that, for example, after one or two years, whether it is realistic to expect to have substitute materials in 13.5 years that can be used and implemented safely in the plants, that also protect the environment better, and that also ensure safe operation, because our plants are already very safe and require safe operation.

Simone Wilson

The Federal Institute for Occupational Safety and Health recently held two online webinars to provide information on the current status of the restriction procedure and give an outlook on the public consultation in the spring. Around 1,000 participants tuned in to both webinars, meaning that both events were sold out, so to speak. This clearly indicates that the issue is by no means off the table for the industry. That has also become clear here. You already gave an outlook earlier on how we can prepare now or what lies ahead, but perhaps you could repeat what you are doing specifically at the moment. Looking at Covestro, how are you preparing specifically?

Dr. Gudrun Lücke-Brunk

We will look at the questions in the ECA guidance, even though they may still change slightly. We will try to prepare the questions and put them together in a document that is not part of the survey, but in a separate document, so that we are ready when the public consultation starts. You now also need EU access with an EU account to access the survey. U. account to access the survey, so that we can then use the 60 days as quickly as possible to provide the information that we now have to deliver in a bundled form. We will not have the opportunity to submit further annexes or links or further information or papers or studies, but will have to summarize everything and often only have very, very few characters available, i.e., letters and spaces. And there is a limit of 2000 or even 5000 characters, and we have to try to bundle our information, which we then have to make available to the competent authorities or the SEAG, into this form. And of course, it's also a matter of wording, how to phrase it well so that it is understood. We often see that we in the industry use different language than those who receive the information and then classify it differently or understand something different from what we understand. It's also a matter of communication.

Simone Wilson

So ultimately, we shouldn't kid ourselves. It's being sold to us as something that's okay, that it's better structured now and we can get through it faster. But ultimately, compared to the first consultation, what you can communicate now is very restrictive. So very limited.

Dr. Gudrun Lücke-Brunk

It's very limited, and you have to be careful about what you communicate. You don't have much space, and you have to be careful about how you do it.

Simone Wilson

Now I know that there are different assumptions about this, right? So you still have to resubmit what you've already submitted. So how can you achieve the greatest added value for yourself, so to speak, or for the cause you're promoting, for the information you want to share?

Dr. Gudrun Lücke-Brunk

These are now mostly socioeconomic questions, where business figures are also asked for. For example, how much business would you lose if this application were no longer available is one of the questions that is answered, and there are fewer, let's say, risk-based questions, because the Risk Assessment Committee has already finalized its opinion and it can no longer be commented on. Yes, if you look at it now, the whole thing started in 2023 and the many comments came in September 2023. More than two years have passed since then, and of course a lot has happened in the industry, not only in the industry, but also in the entire environment of people who use PFAS. Unfortunately, there is now no way to describe what has happened in the last two years, but instead we are relatively restricted to socio-economic issues. And I think that's a shame, because we can't describe what has happened, we can't describe the developments that have taken place over the last two years.

Simone Wilson

Just asking spontaneously, you're the expert, if you had a hack, is there any great tip for those who have to participate in this consultation on how to really get the most out of it with such a strict limit on the number of characters and information that can be included?

Dr. Gudrun Lücke-Brunk

Yes, not really a hack. Think about what you really want to communicate to the socioeconomic committee. I wouldn't say that you should communicate to the relevant authorities what was already submitted in the first consultation. However, there are also other voices from the industry who say that if it's socio-economic facts, then you can certainly consider bringing them up again to, let's say, emphasize them once more. Yes, so take a look at the questions that are there and try to answer them as briefly and concisely as possible to the best of your knowledge and belief. Or, where there are free text lines and you have a little more space, enter your information in a very targeted and well-formulated manner to say, "I disagree with this" or "You see, this is currently misrepresented in the document," and try to correct it.

Simone Wilson

And perhaps we should also clarify that just because these sectors have now been dropped, that doesn't mean you can't comment on them. You just have to see where you fit in or where you can best engage with the issue, but it's not the case that those who don't specifically identify with these additional sectors are not participating in the public consultation.

Dr. Gudrun Lücke-Brunk

Exactly, the first difficulty is its application, and it's not just sealing applications that a large company has, but also other applications that need to be identified in the sectors. Under which sector has my application been described and reviewed, so to speak? Yes, and there, if you find yourself in the sectors, yes, try to answer the questions that are there, which are relatively specific, in a targeted manner. For sectors where you don't find yourself, and there are quite a few of them because they go into the smallest ramifications, you should then take the opportunity to use these general questions for the sectors that have not been looked at and also include the information you want to tell the Socio-Economic Committee there.

Simone Wilson

OK, Jörg, now I'm curious, because I was wondering the same thing: what is the mood in the market like, is it despair or cautious, cautious optimism?

Jörg Skoda

It was up and down. In January, the mood was really high. People recognized the important sectors that had been forgotten and put them down on paper. They are now included in the dossier. But then the information came that they would not be taken into account, which is not entirely true. You can find them under "General," which is more specific, but people are not looking at them specifically, so the mood went down again. It's really difficult, to clarify once again, people want it and they are desperately looking for alternative substances, and they also want us to have a substance that can replace PFAS, and if PFAS, we're talking about the substance group again, so we're actually talking about 27 fluoropolymers in our directional technology, then we wouldn't be sitting here discussing it, but it doesn't exist, so we are currently facing a major dilemma, with no reasonable planning security. How will this continue? There are companies that will be standing in front of the building, which will not affect us in terms of strength, but there are companies that do nothing else but work with polymers, and they will then close down, which will cost jobs, and there are quite a few companies, it has to be said. The environment always comes first, everyone, no matter who, whether industry, authorities, or every individual, wants us all to live safely and healthily, and we are all in favor of a restriction procedure. But I now have the feeling that this is no longer about an exchange at a technical level to find solutions, but rather that we are currently talking about a political issue. This is my personal opinion, which may not be correct, but I believe we are talking about a political issue and no longer about finding a reasonable solution.

Simone Wilson

Yes, but Ms. Lücke-Bunker just said that the process has been going on for a long time now, since 2023, and there was this initial impetus that everyone, or at least a great many people, got involved. Now we ultimately have to, or should we say, generate the same momentum again, and I'm a little concerned about that because it's so protracted that many companies, or many people, yes. Yes, many voices from the market may not even be heard because they say, yes, it's not going to happen anyway, or someone else is dealing with it, or we can't do anything about it anyway. How do you assess that?

Jörg Skoda

I think the time pressure they are currently under is not without reason, meaning they have to get it done. If the authorities were fair, they would say, let's see, there are issues, we don't need it for a frying pan, we don't need it for toilet paper, so we'll ban it immediately. We know the sections that already exist in the requirements document, but we've realized that we've forgotten some. Either we take them out and create a new procedure for them and say, OK, we'll do what we can directly, and that's a big part of the story, and we'll go ahead with that and say, OK, it fits or it doesn't fit, but that's not what you do, so you put pressure on to have everything ready by the end of 226, and we have one factor that we should never underestimate, and that is the human factor, and we can't influence that, we can only hope that the people who make the decisions there say, we'll approach this neutrally with expertise, I personally have a bit of a problem with that, because I don't believe that's the case. I believe the thing is really politically driven, and I think, please look at the eight sectors separately, which makes sense, because you know what's behind them and the other sectors that are clear, so I don't need to go over it again, but that's how it is now.

Simone Wilson

The work that takes place in the committee at the BAuA and elsewhere, but perhaps I'll ask you again, Ms. Lückebrunk, do you think participation in the second consultation will be just as extensive, or do you think there is a bit of PFAS fatigue?

Dr. Gudrun Lücke-Brunk

So my personal assessment is that there will be high participation again, because the topic—and you can see this from the participation in these two BAuA seminars, which were both sold out, so to speak—is high on the agenda, and if there is an opportunity to provide information again, then it will probably be taken up in many places. However, I doubt that there will really be more than 5,000 submissions again. My personal assessment is that the number of submissions will be lower than that.

Jörg Skoda

Yes, OK, well, perhaps I should add that many people believe that, since I am in the VDMA example, it is sufficient for the VDMA to submit the application, but that is not the case. Every company that is affected should address this issue. Incidentally, 60 days sounds like a long time, but Easter is in between, as are the vacation periods, and it's May with its many vacation days, so that quickly reduces the 60 days to perhaps 23 weeks. So you have to deal with it now. There is a team at the VDMA that you can ask. there is a team within the VCI that you can ask, we are currently dealing with this in sealing technology, I can only recommend that everyone not rely on the VDMA and VCI, they are important, but everyone has to speak up for themselves, because otherwise the information won't get through, and if you can't find it under General, it always works.

Simone Wilson

Exactly, and the other thing is that it's not yet clear whether it will take place in March or not. So I think it's very, very clear that this public consultation will start in March, or at the latest in early April, right?

Dr. Gudrun Lücke-Brunk

Exactly, at least that's what the regulators are predicting.

Jörg Skoda

Yes, perhaps one more addition to the topic, yes, I took part in the second meeting, the second BAuA meeting, and you got the feeling that even the BAuA people weren't entirely happy with what's happening in Europe at the moment. They had taken the trouble to describe the section properly and put a lot of time into it, and then suddenly they said, let's sweep it under the carpet. So, I don't know how they saw it, they were there too, I guess they felt the same way, exactly, saying, no, we don't want that, we think it's a shame, we don't think it's right, we've found some more points here and you're just sweeping them under the carpet.

Simone Wilson

But well, yes, but then that would be yet another sign that the second consultation should be used.

Dr. Gudrun Lücke-Brunk

Exactly, yes, yes, that's also my appeal, please participate and also participate as an individual company. If you look at the questions, they are quite general questions that can also be asked via an association. However, some of them go into specific matters and are confidential, which should of course be marked as such, such as business figures and so on for an individual company, which of course cannot be discussed in the association due to antitrust regulations. So my advice is, please provide this information and then mark it as confidential, also so that, let's say, outsiders cannot access it. Provide this information, but mark it as confidential. Yes, O.

Simone Wilson

K., that's another important point: you don't say, "I'm not sharing these because they're confidential," but rather, "I'm marking these so that they don't appear publicly." Very good. Now I would like to shift gears a little, moving away from the problem-centered view and toward a brighter future, and I'll admit that I'm a big fan of Markus Steilemann, your CEO, Ms. Lückebrunk, and current VCI president. He recently said that innovation is the heaviest, sharpest sword, did I say that correctly, the sharpest sword that Europe has at its disposal in global competition, and described innovative strength as an often underestimated traditional strength of the European chemical industry. Ms. Lückebrohm, can you imagine that this tug-of-war over meaningful paper restrictions could become a driver of innovation for Germany and Europe, and what do you think would need to happen for that to occur?

Dr. Gudrun Lücke-Brunk

So, as I said, there are innovations, and there are always innovations, whether with restrictions or without restrictions, or whether with regulations or without regulations. Innovative strength is actually the purpose of a company: to develop or offer innovative solutions for customers. And when you have such innovative solutions, they must always be accepted by the customer. Otherwise, you can develop whatever you want. That's why, as Mr. Skoda said, it's so important to work together on product code. Then things run smoothly and you can serve your customers according to their requirements and develop specific products. Yes, but if you no longer have certain substances available to bring about this innovation and can no longer bring it to market, then this naturally inhibits innovation because you no longer have the entire chemical toolbox at your disposal to develop certain products, quite simply. And if you overshoot the mark, as I think has happened here with PFAS, then you inhibit innovation. But if you allow some leeway, a certain amount of freedom for developers and researchers, then you have better opportunities, such as think tanks or something similar, that think about how to arrive at a solution and what you can use to arrive at that solution. But if you only have very, very few tools at your disposal, then it becomes really difficult.

Simone Wilson

And if it's handled so restrictively, well, I mean, right now there's an impulse, you could say, from outside, because you have to think innovatively about how this substance, this group of substances, can be replaced, but that certainly ties up resources in the innovation process, and then I might no longer be able to think about how to produce the most sustainable, best product, right? So I see it the same way, Jörg. which made me wonder again how realistic the use of fluoropolymers is in certain technical applications. There are already a few initiatives, such as the Fraunhofer project on fluorine-free high-performance elastomer compounds, which was launched just under a year ago.

Jörg Skoda

We always end up coming back to the same problem: we have 10,000 substances and we need to decide which one to talk about. So when you say you're looking for alternatives and you talk to the people at Fraunhofer and all the other institutions that are involved in development, they always say, "We have an application and we can now offer a PFAS-free material for this application." If we do that ten thousand times, it just takes ten thousand times as long. That's the problem with chemistry. The fluoropolymers we use have the advantage that they can be used in all applications, are always chemically resistant, and we now have to differentiate. No, in one case I have chlorine, in the next I have the medium, and that's what makes it so difficult. So that was, as we always say here in the Ruhr area, finding the egg-laying wool-nothing pig, namely a substance that replaces PTW 1:1. I think that's unlikely at the moment, but at least it shows that the market is currently open to development. We need time; thirteen and a half years go by quickly, and they always sound like a long time, but you know yourself how long our projects take. So I think it's unlikely at the moment that we'll be able to say in thirteen and a half years that it works. But we're not the right people to ask. We don't manufacture the raw materials. For me, companies like Daikin, which manufactures powders, for example, or Covestro, which also makes plastics, are needed here. Maybe they have an idea where they can say, we have something great, but only those who can completely replace it will earn a golden scar at some point.

Dr. Gudrun Lücke-Brunk

Yes, I would like to add that substitution processes are often underestimated in terms of their complexity. Often there is no 1:1 replacement, but there may be a good alternative with a good alternative material for a specific application, but this cannot be generalized to the overall application. And then it is also important to find solutions for those who fall behind and for whom there is no substitution option with an alternative material, so that they can also be served. And that is what makes it so difficult and so complex. The complexity of such a substitution process is often greatly underestimated when one wants or, in this case, needs to substitute something and wants to achieve this in practice.

Simone Wilson

And I think that Covestro is particularly affected by this dilemma that we have with PFA, namely that it is durable and cannot be broken down or decomposed, so it is there forever. We naturally see this as a disadvantage in such a restriction procedure. The advantage, of course, especially when we talk about the circular economy, is that longevity and the circular economy are also a major issue for Covestro, a central issue.

Jörg Skoda

Exactly, yes, although it must be said that we are talking about PFAS, but durable and persistent, that's not the term that always comes up. According to the EU, polyethylene is also persistent, so ultimately we're not doing ourselves any favors by only looking at persistence. No, we have to We know ourselves how much plastic we have out there in the sea, so it's not surprising, and it doesn't decompose within two hours like edible paper. It's easy to forget that, and the problem is actually testing. I already know that many customers are currently testing, and it often doesn't go well. We can be glad that these are test facilities that can be controlled. Mhm, and that's going to be fun.

Simone Wilson

Yes, then I would say let's come full circle and perhaps take another look at what we said at the beginning and what we can learn from this process for future chemicals policy. Ms. Lücke-Brunck, do you think the PFAS restriction process is a model that will set a precedent?

Dr. Gudrun Lücke-Brunk

So there are announcements that these restriction procedures will continue to be carried out in groups. Of course, this has the disadvantage that it is difficult for companies to find themselves in these groups. The substances here at PFAS over 10,000 cannot be properly identified with CAS and EC numbers, as is the case, for example, in the inventories of many companies. And it is difficult to find your way around and see whether you are affected at all. That is one thing. Secondly, regulating 10,000 substances at once, with an infinite number of substance application combinations, naturally means that it is not possible to look at every application combination in detail. So you cluster them, and it may be that certain applications are then also regulated. That's the example of berries, yes, that then, let's say, all berries are banned, even though you really only want to ban rowan berries because they are poisonous. And we see exactly the same principle here. Secondly, I think that legislators are also learning here that PFAS is far too big. It is far too complex, and we are now seeing that. People are dissatisfied with how long the process is taking. They are living in uncertainty, and perhaps we can learn from this that if we want to regulate in groups in the future, these groups need to be very well defined, grouped according to specific criteria, and that there should also be, let's say, subgroups within the groups that can be precisely described and where the substance identity is also clear.

Simone Wilson

Jörg, I remember when we had Ms. Haberbeck on the podcast, she said that it is now the official responsibility of the BAuA to initiate such proceedings. Yes, of course, but you also said, why can't they talk to us first? So now I have the feeling that they could, of course, seek expertise beforehand, not with more than 5,000 comments or however many there were, but by specifically approaching people with expertise in the industry and then considering, on the part of the authorities, how to perhaps initiate such a procedure.

Dr. Gudrun Lücke-Brunk

Yes, and that's very conceivable. The BAuA naturally attempted this in its call for evidence, but many did not identify with it and many did not feel affected in these sectors. That only came about when the drum was beaten, so to speak, and it was announced that something big was coming, and then of course there was an outcry, yes, and what that entailed. And of course, before you even start a regulatory process, and such a regulatory process always arises when there is a concern, it would be very good to consider where to get information in the first place. That means engaging in dialogue and not just sending out a questionnaire with a survey, but simply seeking dialogue with people who might be affected, who could then give you a little bit of information before you even start thinking about how to regulate it. Yes, to then see how I can best address this concern with the regulatory tools I have at my disposal, so to speak, how I can tackle it, and that includes not only REACH, it would also include environmental legislation, such as water legislation and soil legislation, and waste would also be included, in order to then have a comprehensive picture and be able to decide as a regulator what is the best regulatory framework, what is the best legal framework with which I can tackle this concern?

Simone Wilson

Mhm, and that would be something. So, once the process is complete, perhaps we shouldn't break off contact immediately, but maybe invite the BAuA to participate in a review so that we can prepare future processes differently. Jörg, so I'll ask you again: you were in contact with the BAuA from the beginning and have a close relationship with the people in charge there. We all know that both the dossier submitter and ECHA were surprised by this flood of comments. Do you think the BAuA will do the same thing again?

Jörg Skoda

No, I think that, I think that we learned or realized that they didn't anticipate the flood. I think that with the normal standard odor detection method, we have 80 objections, and 5,600 is a completely different ball game. People also realized that they had simply forgotten things, and I think for them it was the first shot with a group ban like this. I don't think they'll do it on this scale again. And we've also noticed in recent months that there is a willingness to talk, both on the part of the authorities and on the part of industry. I think that has been incredibly beneficial, and Pifas deserves praise for that. It was a positive side effect that we finally managed to talk to each other, and that can only be the way forward.

Dr. Gudrun Lücke-Brunk

Exactly, that's also a piece of advice: please contact the dosing submitters, regardless of which country they are from, and pass on the information you have so that it can be processed. If you don't provide any information, you just have to live with what's there. You complain, yes, but you've missed an opportunity, so to speak, to make the regulations a little more practical and to improve them a little, because the regulator doesn't know that. They can't know everything, and that's why the information provided by various parties is so important for ensuring that regulations are designed sensibly.

Simone Wilson

Actually, Ms. Lücke-Brunk, I imagine the regulator to be a bit like you, namely what you said at the beginning, that you couldn't do your job either if the specialist departments didn't provide the information.

Dr. Gudrun Lücke-Brunk

That's exactly right.

Simone Wilson

Yes, yes, yes, today's discussion has shown how much is at stake. It's not just about individual substances, but about how Europe reconciles regulation, technological performance, and future goals. PFAS are therefore less of a special case than a yardstick for dealing with complex industrial realities. Anyone who joins us on the podcast always gets to make a wish at the end. However, we can't guarantee that it will come true. Jörg, if you could make a wish for the rest of this process, what would it be?

Jörg Skoda

My wish would be for people to continue communicating and trying to come up with a clean technical solution with very good regulation, because we have to regulate—these things don't belong in the environment—but please talk to each other, think about it, be aware of it. In my opinion, a total ban would be a disaster at this point.

Simone Wilson

I see differentiation there. Yes, Ms. Lücke-Brunk, you too will be granted a wish.

Dr. Gudrun Lücke-Brunk

Yes, I too would like to see a distinction made so that applications continue to be assessed on the basis of risk, and that they are evaluated according to risk rather than hazard or exposure alone, but solely on the basis of a risk assessment, and that this assessment is scientific rather than political. On the other hand, I would like to see PFAS applications continue to be used where there are no substitutes available and are unlikely to be available in the future, and where they are, of course, necessary for the operation of these facilities. Yes, I would very much like to see them granted an exemption, and an exemption for an indefinite period. Of course, the Commission could then say, for example, that it will review the restriction again in 5 to 10 years and see how things stand with finding substitutes, whether this is realistic or not. And you can also revise it, and here it would then be an exception for a longer period of time, so to speak, i.e., RO 3, which is here and which also has to be newly introduced, i.e., the indefinite exception and then a revision clause after a few years to see what has happened. Because, as I said, we want to substitute where possible, where it is technically possible, and where substitutes are also available for certain applications. That would be my wish.

Simone Wilson

This brings us to the end of our discussion. The PFAS debate remains challenging and will continue to accompany us both regulatorily and technologically. Ms. Lücke-Brunk, thank you very much for your nuanced assessment and your open view of the opportunities and limitations of the current process. Jörg, thank you very much for your perspective and your clear assessment based on practical experience. If I could make one final wish, it would be for more discussions like this one. And above all, strong voices from industry who have the courage to take a stand. And who knows, maybe Marcus Steilemann will even be persuaded to take a seat on our podcast couch at some point. That would certainly be an exciting prospect. An episode on the topic of PFAS is still on our agenda this year, immediately before the consultation in March. After that, we will deliberately take a step back from the topic and broaden our perspective, for example, to the role of sealing technology in the hydrogen industry and other future fields in our industry. Thank you for listening. Stay tuned until next time on the IDT podcast for new perspectives and fresh ideas in industry and sealing technology.