On November 20, 2024, based on over 5600 scientific and technical opinions collected by the Risk Assessment Committee and the Socio Economic Analysis Committee during the 2023 public consultation period, the European Chemicals Agency (ECHA), together with authorities from Denmark, Germany, the Netherlands, Norway, and Sweden, released the latest progress on the process of restricting perfluoroalkyl and polyfluoroalkyl substances (PFAS) in Europe in Helsinki.
▶ The collected consultation opinions include:
Extensive information on the hazards and risks of PFAS;
The use of PFAS in the European Union and the European Economic Area (EEA);
And information on the availability and applicability of alternatives, as well as the socio-economic impact of proposed restrictions.
▶ Through scientific evaluation and analysis of these consulting opinions, the purposes that were not specifically stated in the initial PFAS restriction proposal have been identified and are being incorporated into existing industry evaluations or classified into new industries as needed, such as:
Sealing applications: Fluorinated polymers are widely used in consumer, professional, and industrial applications, including seals, pipeline liners, gaskets, valve components, etc.
Technical textiles: The use of PFAS in high-performance films, medical applications not covered in medical equipment, and outdoor technical textiles (such as waterproof fabrics).
Printing applications: Permanent components and consumables used for printing applications.
Other medical applications, such as packaging and excipients for drugs.
▶ In addition to a comprehensive ban or time limited exemption ban, ECHA is also considering other restriction options regarding PFAS, which may include allowing relevant industries and PFAS uses to continue producing, placing on the market, or using PFAS. This option is particularly important for applications and industries where there is evidence that the implementation of bans may result in disproportionate socio-economic consequences. We are considering the uses of these alternative solutions, including but not limited to:
Battery
fuel cell
Electrolytic cell
▶ Other opinions:
Fluorinated polymers are an example of a group of PFAS that stakeholders are highly concerned about. During the consultation, we further explored the availability of alternatives for certain uses of these polymers, technical and organizational measures to minimize their emissions in the environment, and the potential socio-economic impacts of banning their production, market release, and use.
The intention of the proposal submitter is to minimize the emission of PFAS as much as possible, in order to avoid further accumulation of PFAS in the environment and reduce subsequent exposure to humans and the environment. The initial PFAS restriction proposal included two restriction options: a complete ban or a time limited ban (alternative options have not yet been provided). The proposer suggests adopting the latter option. Other restriction options are also being considered. For example, an alternative option may involve conditions that allow for continued production, market release, or use of PFAS under specific conditions, rather than a complete ban. This consideration is particularly important for purposes and industries where there is evidence to suggest that bans may result in disproportionate socio-economic impacts. The applications being considered for these alternative solutions include but are not limited to: batteries, fuel cells, and electrolytic cells. ECHA will evaluate the proportion of each alternative and compare it with the initial two constraint options.
The development of opinions will be further promoted in 2025 and will generate draft opinions from RAC and SEAC. Subsequently, consultations will be held on the draft opinions of the advisory committee. This will provide opportunities for all interested third parties to access relevant socio-economic information for SEAC's reference.
▶ Response suggestions
With the continuous update of PFAS controlled substances, enterprises are facing more and more control requirements. It is recommended that companies conduct an early investigation into their supply chain to cope with regulatory changes with ease.
