Ban on PFAS: Assessing the Impact - Exploring Alternatives

The proposed EU-wide PFAS ban, presented by the European Chemical Agency (ECHA) on February 7th, 2023 has prompted many discussions. We wanted to give you some background information on this proposal. Some ERIKS customers have been asking questions such as, ‘’can we oppose this ban proposal?’’, ‘’are PFAS-free alternatives available? ’or ‘’what will happen if the ban proposal will be put in place?" 

Here at ERIKS, we understand that the PFAS topic raises many questions and concerns. That's why we've put together this FAQ to explore the topic and give you some answers.

If you have any further questions or concerns about the proposed restriction, don't hesitate to reach out to us. We're here to help you navigate these changes.

The EU ban proposal contains a list of around 10,000 man-made per- and polyfluoroalkyl substances, abbreviated as PFAS.   ECHA, the European Chemical Agency, defines PFAS as any substance that contains at least one fully fluorinated methyl (-CF3) or methylene (-CF2) carbon atom (without any H/Cl/Br/I attached to it)

The proposed restriction is a joint effort by Germany, the Netherlands, Denmark, Norway, and Sweden and might become the most significant chemical restriction in the EU's history. It is referred to as a ‘universal restriction’ proposal due to its broad scope, aiming to ban the manufacture, placing on the market, and the use of PFAS as such, but also PFAS contained as constituents in other substances, mixtures, and products

PFAS substances are used worldwide in a variety of products and materials due to their outstanding chemical, thermal and low-friction properties. They can be found in many consumer goods among others, in textiles, fire extinguishers, cooking equipment, toothpaste, as well as in industrial, or non-consumer applications.

At ERIKS, PFAS substances are related to ERIKS products predominantly found in products composed of, or containting, materials like PTFE, FKM, FFKM, PVDF, FEPM, FEP, and PFA. These can be found in certain seals, hoses, valves, gaskets, plastic parts, power transmission, lubricants, PPE, etc. At this moment, it remains is still too soon to draw exact regulatory conclusions regarding the future of these products and materials. Important to know is that all the products ERIKS supplies in the European Union comply with  PFAS regulations as prescribed by the EU REACH and EU POP regulations.

Currently, there are no 1-on-1 PFAS-free alternatives available, with the same properties as PFAS containing products.

PFAS-free materials exist, of course, but:

• they have other properties and therefore might not work or have a shorter lifetime
• for certain products (e.g., valve seats, hoses) they are not (easily) available
   

It is expected that the market for PFAS-free materials with exceptional properties will grow, but that’s a process of years. At ERIKS, we are actively exploring PFAS-free solutions with outstanding properties.

The  public consultation round, which ended in September 2023, resulted in a large reaction from end-users and manufacturers. More than 5,600 socio-economical impact assessment where sent to ECHA. It will take a serious amount of time to evaluate all these studies.  

The latest updates by ECHA do not provide detailed information.  

There is a lot of speculation at the moment, from both environmental groups and manufacturers. It is currently not possible to say which PFAS, for which products or industries, will be banned in the short term, in the long term or which exemptions will be put into place. The proposal gives an indication, but it's not said that the submission will be adopted in the proposed way.

For latest information on the ECHA timeline and next steps, please view ECHA’s website.

At ERIKS, we are actively involved in the ongoing PFAS debate in different industry groups, but first steps in new material developments will predominantly come from the big chemical companies who produces monomers and polymers.  

For a few products and applications, we have started to work on developing alternatives. This process requires involvement of the entire supply chain, from chemical producers, who manufacture the new raw materials, to processors, developers and end-users to validate and approve new options. These developments often take years.  

If a full ban will be implemented by ECHA according to the initial proposal, then this will have a large impact for all users of materials that contain PFAS.  

3M announced to stop producing and using all PFAS in their portfolio by the end of 2025. ERIKS investigated the  impact, and changed to other raw material suppliers, and in some cases also working with customers to revalidate.  

The future of PFAS and its alternatives is still uncertain, but ERIKS is proactively working to address potential challenges and find solutions for our customers. Together with our manufacturers, we must use this as an opportunity for innovation and the development of new, more sustainable, products and materials.

Process steps Since 2019:

• In 2019, the European Commission drafted the PFAS Action Plan, which laid the groundwork for the current restriction proposal. 
  
  
• In 2020, the PFAS Action Plan became part of the European Green Deal's Chemical Strategy for Sustainability. Some PFAS chemicals have since then been restricted under the EU POP regulation. 
  
  
• On February 7th, 2023, ECHA announced the proposed PFAS restriction under the European Union's REACH regulation. 
  
  
• In March 2023, the ECHA started a public consultation on the proposal, open until September 2023, giving stakeholders, like you, the chance to share your thoughts. 
  
  
• Keep informed of the next steps on the ECHA website.

Authors:

Harrie Vangangelt, Quality and Compliance Manager, Sealing & Polymer Europe

Stijn De Cnop, Global Product Compliance Manager