PFAS Ban Proposal Sparks Over 5,600 Public Comments

Since our last post, the window for public commentary on the proposed PFAS ban in the European Union has closed. The window closed at the end of September, with over 5,600 comments submitted to the European Chemicals Agency (ECHA). 

More than 4,400 businesses, organizations, and individuals submitted remarks around the proposal, which was submitted earlier this year by five national authorities from Germany, Sweden, Denmark, Norway, and the Netherlands. 

Background on the PFAS ban proposal in the EU

The proposal came after a sweeping three-year study by authorities from the aforementioned countries, which found PFAS posed health risks to humans and the environment. The proposal suggested two types of restrictions: 

1. A full ban, with an 18-month grace period for companies to transition 
2. A ban with use-specific, time-limited derogations

Who submitted commentary on the PFAS proposal?

Most comments came from Sweden, Germany, Japan, and Belgium. Companies made up the bulk of commentary submitted (58%), with individuals making up for approximately half that (27%). 

Based on our initial look through the comments, fluoropolymers like PTFE were frequently mentioned in the comments, especially in their relation to manufacturing. One such comment from Dennis Olschowka, Technical Sales at ESZ Wilfried Becker GmbH, a German company, wrote: “Fluoroplastics such as PTFE, FEP, PFA and the 35 other materials in this group are unfortunately indispensable and irreplaceable due to their properties.”

What’s the next step for the PFAS proposal?

ECHA’s committees for risk assessment (RAC) and socio-economic analysis (SEAC) will now review the comments, after which the ECHA “will deliver the final opinions to the European Commission “in the shortest possible time frame, while ensuring proper scrutiny by the scientific committees”.

What’s the next step for electronics manufacturers?

If you’re looking to understand where PFAS might be in your electronics supply chain, here’s a good resource on the topic: Where are PFAS in your electronics supply chain?

PFAS are used in a variety of ways but show up more commonly in four main forms: 

‍Perfluorooctanoic acid (PFOA)‍

• Electronic components like cables and computer parts

Perfluorooctane sulfonic acid (PFOS)

• Electronic components like cables and computer parts

Polytetrafluoroethylene (PTFE)

• Electrical insulation
• Medical Devices
• Aerospace
• Seals and gaskets
• Textile coatings

Perfluorobutane sulfonic acid (PFBS)

• Surfactant
• Emulsifier
• Aerospace

PFAS are a popular choice in manufacturing due to their unique chemical properties that make them incredibly stable as well as resistant to heat, water, and degradation. 

According to Z2Data’s research, PFAS appear commonly in parts like tantalum capacitors, followed by flash memories, and resistor trimmer potentiometers.

For companies looking to understand the scope of their potential risk, they’ll need to better understand where PFAS are in their products, and what parts of the manufacturing process they are used in. This can mean starting with a full materials disclosure as well as talking to suppliers. Companies can also utilize tools like Z2Data to quickly evaluate their PFAS use over their entire BOM.

Want to learn more about PFAS regulations and their risk to you?

Join us on November 9, 2023 for a free webinar on PFAS. This webinar will take a close look at the latest updates on PFAS regulations in the United States and Europe, including the recent proposed 10,000+ PFAS ban in the EU. We’ll also explore where PFAS are in the manufacturing process and what parts of the supply chain could be affected by new and far-reaching regulations.

Webinar - PFAS Restrictions in Electronics: What You Need to Know

Thursday November 9, 2023 @ 11 am PDT (2 pm EDT)

Register here: https://tinyurl.com/2653wzm2

The webinar will be led by Mike Kirschner, a product environmental compliance expert with 20 years of engineering and engineering management experience at companies like Intel, Tandem Computers, and Compaq.