Proposed restriction on per- and polyfluorinated chemicals (PFAS)

ECHA published an EU REACH restriction proposal for PFAS on 7 February as one of the most extensive regulatory measures for a group of substances ever. We have been working intensively on this issue and in August we made a submission to ECHA with various well-founded requests.

Per- and polyfluorinated chemicals (PFAS) are a group of synthetic chemicals that are used in a variety of products due to their water-, grease- and stain-repellent properties. These include food packaging, water repellent clothing, detergents, Teflon pans, lubricants and also in our fluoropolymer coatings (FEVE, PVDF and PTFE). Although PFASs have beneficial properties, there are concerns about their potentially harmful effects on health and the environment.

The European Chemicals Agency ECHA writes on its website:

“… They all contain carbon-fluorine bonds, which are among the strongest chemical bonds in organic chemistry. This means they are difficult to break down, both in their use and in the environment. Most PFASs are also easily transported in the environment, traveling long distances from the source of their release. PFASs are often found to contaminate groundwater, surface waters, and soils. Cleaning up contaminated sites is technically difficult and costly. If releases continue, PFAS will continue to accumulate in the environment, drinking water, and food. …”

On Feb. 7, 2023, ECHA published an EU REACH restriction proposal for PFAS, the most extensive regulatory action ever for a group of substances. With this proposal, more than 10,000 different PFAS uses would be affected and only a few would be exempt from a ban. A six-month consultation period began on March 22, meaning comments can be submitted to ECHA until September 25.

We have worked intensively on this issue and made a submission to ECHA in August. As you can see from the attached submission, we have been able to substantiate,

• that our applications generate virtually no emissions during the product life cycle (production at Monopol, production at our customers, use and subsequent recycling)
• and there are no alternatives for high-quality architectural applications as well as bridge and steel construction.

Our conclusion and request to ECHA is:

Safe: Fluoropolymers for architectural applications are safe and, despite their persistence, do not pose an unacceptable risk to human health or the environment.

Sustainable: By extending renovation or refurbishment intervals, fluoropolymers help conserve resources and are sustainable. Less frequent renovations mean less resource consumption and CO2 emissions.

Lack of alternatives: Currently, there are no comparable alternatives to fluoropolymers for protecting buildings or bridges against sun and weathering for more than 50 years.

For this reason, we request that fluoropolymers be excluded from the proposed restriction on PFAS chemicals.

If ECHA decides to leave fluoropolymers in the proposed restriction, we request that a 12-year derogation be granted for these fluoropolymer applications. This derogation should be reviewed every five years from inception to determine if industry has been able to develop new PFAS-free systems that meet the technical performance of current fluoropolymer products.