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UKGSA object to proposed total ban of PFAS

The UK Gasket & Sealing Association, which represents the interests of companies who engage in the conversion of materials into gaskets and seals for all types of industry use, does not believe that fluoropolymers should be considered in a proposed restriction or total ban of PFAS. They are vital across a wide spectrum of industries, offer unique combinations of properties, and are safe for their intended use.

What are PFAS?

PFAS are a large, complex, and ever-expanding group of manufactured chemicals that are widely used to make various types of everyday products. For example, they keep food from sticking to cookware, make clothes and carpets resistant to stains, and create firefighting foam that is more effective. PFAS are used in industries such as aerospace, automotive, construction, electronics, and military.

PFAS include PFOA, PFOS and GenX compounds many of which have been phased out of use in most western economies but continue to be used extensively elsewhere in the world. As PFAS do not break down and can accumulate in the human body over time, there is evidence that sustained exposure to PFAS can lead to adverse human health effects.

Fluoropolymers are one specific subset of PFAS that possess a unique combination of properties that make them essential to modern life and a wide variety of industries. Their properties include fire resistance, weather resistance, temperature resistance, chemical resistance, non-wetting and non-sticking properties, and high-performance dielectric properties.

Proposed Restriction of PFAS

The use of PFAS result in emissions into the environment. In July 2021, the competent authorities for REACH of the Netherlands, Germany, Denmark, Sweden and Norway submitted a REACH Annex XV Restriction Dossier for the group of PFAS and any chemical with at least one perfluorinated methyl group or at least one perfluorinated methylene group, and are planning to submit the restriction dossier in January 2023. The ECHA opinion development phase will start immediately after, including a 6-month public consultation on the content of the restriction dossier.

The proposed PFAS Restriction under REACH is to potentially restrict or ban the use of PFAS in non-essential applications across the EU by 2025, with allowance for a transition period. Essential uses of PFAS would be exempt from the scope, but currently there is no formal definition of what constitutes ‘essential use’.

Chemours, as one of the major global manufactures of Fluoropolymer materials, maintains that the expanded definition of PFAS being applied by REACH is too broad to enable effective, science-based assessment and regulation of chemical compounds. They state that “Fluoropolymers and F-gases are critical for nearly every major sector of the economy, offer unique combinations of properties, and are safe for their intended uses. Furthermore, no universal alternatives exist that offer the same unique combination of properties, uses and societal benefits that F-gases and fluoropolymers provide.”

Next Steps

Now that a PFAS restriction process has been formally initiated in Europe and in the US through the EPA, Chemours and its partner organisations are committed to working with the appropriate competent authorities to help fill any data gaps or to provide additional information about the safety and socio-economic value of fluoropolymers and F-gases.

Furthermore, through collaborative industry engagement across the value chain, we are all confident that a constructive regulatory outcome can be achieved for all stakeholders.