PFAS

What Are PFAS?

Often abbreviated as PFAS, per- and polyfluorinated alkyl substances are a group of over 15,000 synthetic chemicals known for their beneficial properties. PFAS are often waterproof, stain-repellant, and grease-resistant, among other advantageous qualities, making them useful components in a wide range of everyday products ranging from furniture and apparel to food packaging, electronics, and cosmetics. Over the past two-plus decades, however, a succession of lawsuits and scientific studies have shown that the chemical family persists in human beings and ecosystems for many years, leading to significant health and environmental concerns. Research has established probable links between exposure to these chemicals and several types of cancer, developmental delays in children and adolescents, and adverse immunological effects. Efforts to regulate these chemicals’ widespread use and address PFAS contamination worldwide are ongoing. 

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When Did We Start Synthesizing PFAS, and Why Did They Become So Popular?

The first PFAS compound, polytetrafluorethylene, was synthesized by the chemical company DuPont at its Jackson Laboratory in Deepwater, New Jersey in 1938. Eight years later, it was introduced to the world as the durable, nonstick, heat-resistant resin known as Teflon. DuPoint competitor 3M followed suit by debuting the PFAS-containing finish Scotchgard in the 1950s, and before long the American public was awash in adaptable, stain-resistant products that were manufactured with one of a burgeoning number of so-called forever chemicals. Within just a few decades, fluorocarbons were making dozens of products more resilient and versatile. In the process, they became an essential compound for manufacturers all over the world, firmly embedding themselves in global supply chains in a way that remains difficult to reverse to this day. 

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The Current State of PFAS Regulations in the U.S. 

Years of revelations about fluorocarbons’ pernicious effects on human health and the environment have prompted a series of major U.S. regulations at the national level. The Environmental Protection Agency (EPA) has been actively working to address the growing challenge of PFAS contamination, including by establishing new reporting requirements in the Toxic Substances Control Act (TSCA) that aim to gather critical data on PFAS production volumes, use information, and exposure levels. A raft of U.S. states have taken regulatory measures into their own hands, too, proposing ambitious legislation seeking to significantly curb PFAS use and phase out the compounds in product categories like cookware, cosmetics, and carpets and rugs. 

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What Is the EPA’s PFAS Reporting Mandate?

In October 2023, the EPA published a final rule under the Toxic Substances Control Act Section 8(a)(7), titled Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances. The new rule requires all in-scope businesses manufacturing or importing one of around 1,400 specific PFAS compounds to submit a comprehensive, onetime report to the EPA detailing their use of PFAS between January 1, 2011 and December 31, 2022. Businesses covered by the reporting mandate must submit a variety of information related to their PFAS use to the agency, including the total volume of the fluorocarbon being manufactured or processed and maximum concentration levels of the compound in their products(s). As of September 2024, the deadline for submitting reports has been pushed back to January 2026 for most companies. 

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How to Identify PFAS in Your Supply Chain

With regulations restricting the use of PFAS on the rise worldwide, manufacturers, importers, and other companies should be aware of which of their products contain these toxic compounds. In order to determine whether and where fluorocarbons are incorporated into their goods, companies may want to familiarize themselves with the characteristics that often suggest the use of PFAS, including thermal and chemical stability, stain-resistance, and water-repellency. In addition, organizations can examine their bills of materials (BOMs), as well as any accompanying drawings and figures, to identify the presence of PFAS. Companies that source many of their components and subassemblies from supply chains will likely have to reach out to their suppliers to pinpoint the precise location of the chemical compounds. 

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Why Electronic Manufacturers Should Be Concerned About PFAS

Because PFAS rose to prominence in the form of Teflon and Scotchgard, the compounds are most closely associated with the products those brand-name chemicals have been historically used on, including furniture, cookware, clothing, carpets, and rugs. Less widely-known, however, is the fact that fluorocarbons are now an essential material in electronics manufacturing, too. A study conducted by Z2Data identified nearly 40,000 electronic parts in its databases that are known to contain PFAS. 

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What Electronic Products and Components Contain PFAS?

Because of their extraordinary versatility and the uncanny resilience and longevity they can confer on materials and products, PFAS are found throughout the electronic component supply chain. Research from Z2Data has identified four primary fluorocarbons in the electronics industry: perfluorooctanoic acid (PFOA)‍; perfluorooctane sulfonic acid (PFOS); polytetrafluoroethylene (PTFE); and perfluorobutane sulfonic acid (PFBS). These PFAS are incorporated into a myriad of parts, among them cables, capacitors, printed circuit boards (PCBs), and computer hard drives. 

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How Are PFAS Used in Semiconductor Manufacturing?

Forever chemicals have long played an integral role in the worldwide chip ecosystem and the delicate, painstaking process of semiconductor manufacturing. To this day, PFAS remain essential to manufacturing steps like photolithography; packaging materials and substrates; and the high performance requirements for semiconductor manufacturing equipment and lubricants. 

While the industry has begun transitioning away from long-chain PFAS—generally understood to be perfluoroalkyl sulfonic acids (PFSAs) with six or more carbon atoms and perfluoroalkyl carboxylic acids (PFCAs) with seven or more carbon atoms—manufacturers are still heavily reliant on their shorter-chain counterparts. While this transition is based on the premise that shorter carbon backbones will lead to shorter half-lives, and thus lower levels of bioaccumulation and environmental persistence, no unequivocal evidence has yet emerged demonstrating that short-chain PFAS are any less harmful than their predecessors. Trade groups continue to argue that these chemicals are irreplaceable to chipmaking, with some going so far as to say that semiconductor manufacturing would be outright impossible without unfettered access to PFAS throughout the supply chain. 

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The Challenge of Obtaining PFAS Information From Suppliers

Many of the PFAS regulations in the process of being implemented by governments and regulatory agencies around the world will require businesses to work with their suppliers to identify how the chemical compounds are being incorporated into their products. This is especially true of the EPA’s PFAS reporting rule, which compels manufacturers and importers to meticulously measure their PFAS use over the course of a 12-year window. 

Suffice it to say, these efforts are not always going to be seamless, uncomplicated affairs, as suppliers will have to navigate their own stumbling blocks in tracking and disclosing PFAS use data. Such challenges include a lack of personnel experienced in managing and measuring chemical use; shortfalls in recordkeeping (manufactures are being asked to procure data from over a decade ago); and proprietary concerns surrounding the sharing of full material disclosures (FMDs), which might otherwise serve as critical documentation for inquiring businesses. 

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