Where Are PFAS in Your Electronics Supply Chain?

Article Highlights:

• PFAS have come under increasing public scrutiny for much of the 2020s, as local and federal governments have started taking steps to reduce their presence in everything from drinking water to fast food wrappers. 
• PFAS are a popular and hard-to-substitute substance in full material declarations (FMDs) for electronics manufacturers. This is in large part due to several unique properties possessed by forever chemicals, including chemical and thermal stability, low surface tension, and robust electrical insulation.
• PFAS are especially important to the manufacturing processes for semiconductors. PFA tubing is regularly used for its ability to withstand corrosive surfactants for longer periods of time than standard tubing. These tubes must often handle harsh chemicals, including hydrogen fluoride or hydrogen peroxide.

Once a celebrated class of synthetic substances that conferred durability and functionality on a wide range of consumer products, per- and polyfluoroalkyl substances have seen their reputation marred by serious health and environmental concerns. Also known as PFAS, these chemicals have come under increasing public scrutiny for much of the 2020s, as local and federal governments have started taking steps to reduce their presence in everything from drinking water to fast food wrappers. 

PFAS have a long and controversial history. More recently, their prevalence, long half-lives, and links to health diseases such as kidney cancer and pregnancy-induced hypertension have generated renewed attention from a health-conscious public. And while there may not be any new PFAS regulations at the federal level in the U.S. as of 2026, many states are moving toward implementing restrictions and product-specific bans on the use of these so-called forever chemicals in manufacturing and packaging.

Most of the current regulations around the chemicals are focused on select PFAS in food wrappers, cosmetics, and other products. However, following a 2023 proposal to outright ban or severely restrict PFAS across the European Union, other industries will also need to start considering the potential impact new PFAS regulation might cause to their supply chains. 

Why Developing PFAS Regulations Matter for the Electronics Industry

Modern PFAS regulations have approached restrictions from two angles:

1. Restricting a single specific substance or a range of related substances (e.g., PFOS).
2. Restricting an entire group of substances (with some exceptions).

For example, the Food and Drug Administration (FDA) currently limits the types of PFAS that can be used in food contact products, although it doesn’t limit the amount of PFAS in those products.

By contrast, a recent proposal by five European Union member states—Germany, Denmark, the Netherlands, Norway, and Sweden—aims for a more sweeping, comprehensive ban. The proposal has asked the European Chemicals Agency (ECHA) to consider two options:

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

But the challenge companies face doesn’t just come from the scope of a given ban. It also emerges from the complex thicket of responsibilities that arise out of multiple overlapping bans. For example, while the European Chemicals Agency (ECHA) and the Environmental Protection Agency (EPA) might both be interested in limiting the use of PFAS, they are not going to impose the exact same requirements and restrictions. These differences force businesses operating in both the U.S. and the EU to understand, distinguish between, and adhere to two different sets of regulatory responsibilities. 

Which PFAS Are Being Regulated

Getting a full list of PFAS is more complicated than you might think. The Center for Disease and Control Prevention identifies over 9,000 types of PFAS, while the EPA recognizes over 14,000 in total. Meanwhile, ECHA mentions over 10,000 potential PFAS that are at risk under the proposed regulation.

The range of different lists and regulatory agencies presiding over the impending limitations on them make it very difficult to understand which PFAS are regulated and where. However, as of right now there are a few key PFAS that would fall under the proposed ECHA ban:

1. Perfluorooctanoic acid (PFOA)
2. Perfluorooctane sulfonic acid (PFOS)
3. Polytetrafluoroethylene (PTFE)
4. Perfluorobutane sulfonic acid (PFBS)

This is where PFAS restrictions become important for electronics manufacturers. All of these chemicals are used in either electronics products or the manufacturing process for electronic components. 

Monitoring this ever-evolving landscape of environmental compliance can be a challenge. To address this challenge, the Z2 platform tracks all developing regulations, allowing companies to immediately assess a law’s impact on their products and components in real time. In the case of PFAS, this would include the full list of all chemicals mentioned in any new EU regulation. Learn more about how Z2Data keeps customers compliant here.  

Where Are the PFAS in Your Electronics Supply Chain?

Research from Z2 shows that four primary PFAS are used in the electronics industry:

Perfluorooctanoic acid (PFOA)‍

• Uses and Applications: Various electronic components, including cables and computer parts

Perfluorooctane sulfonic acid (PFOS)

• Uses and Applications: Electronic components like cables and computer parts

Polytetrafluoroethylene (PTFE)

Uses and Applications: 

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

Perfluorobutane sulfonic acid (PFBS)

Uses and Applications: 

• Surfactant
• Emulsifier
• Aerospace

These PFAS outlined above show up in a myriad of electronics components and manufacturing processes, including: 

• Semiconductors: PFAS are currently an essential ingredient in the manufacturing processes for semiconductors. High purity PFA tubing is regularly used for its ability to withstand corrosive surfactants for longer periods of time than standard tubing. These tubes must often handle harsh chemicals, including hydrogen fluoride or hydrogen peroxide.

• Printed Circuit Board Assembled (PCBA): PFAS are used as soldering agents in PCBAs.

• Printed Circuit Board (PCB) Laminates: PFAS are used as flame-retardants to reduce the risk of fire. 

• Cable Polyvinylidene Fluoride (PVDF) Coatings: PFAS are used to prevent electrical arcing. They leave PFOA residues and impurities. 

• Computer Hard Drives: PFAS are used as lubricants to reduce friction between moving parts. 

• Synthetic Rubbers and Fluoroelastomers: PTFE, in particular, is used as a processing aid to produce fluoroelastomers. As a result, they can remain as a residue in the final product. 

• PTFE Tapes: PTFE is often used as a coating on tapes. These can also leave unintentional residues of PFOA. 

• Mineral Oil: Mineral oil from refinement processes can contain PFAS in the form of impurities. 

Why Are PFAS So Prevalent in Electronics Manufacturing?

PFAS are a popular and hard-to-substitute substance in full material declarations (FMDs) for electronics manufacturers. This is in large part due to several unique properties possessed by forever chemicals:

• Chemical stability: PFAS are highly resistant to chemical reactions and degradations.

• Thermal stability: They can withstand high temperatures without degrading or releasing toxic by-products. 

• Low surface tension: They are highly repellant to liquids, which can help create non-stick surfaces (hence their popular use on non-stick pans).

• High thermal and electrical insulation: They are useful in electrical components and thermal insulation applications. 

• Hydrophobicity: They are highly water-repellent, which makes them useful for water-resistant coating or even firefighting foams.

• Lubricity: They are useful as release agents or lubricants. 

These qualities make PFAS a popular ingredient in formulations for electronics manufacturers looking to design and produce sustainable, high-performing components.

Where Do PFAS Show Up in Electronic Components?

Z2Data’s database indicates that PFAS appear in a large number of electronic components. The commodity group that included the most components with PFAS in them was tantalum capacitors. This was followed by flash memory and resistor trimmer potentiometers. Other commodity groups that contain FPAS include:

• Crystal Oscillators
• Rectangular connector headers and receptacles
• Tantalum polymer capacitors

To learn more about how Z2 sources its information—and if your products have measurable amounts of PFAS in them—try our free 14-day trial. Z2 will show you how to identify PFAS use in your supply chain, as well as how to source cross-references to reduce your overall environmental compliance risk.

Concerns About PFAS Regulation From Manufacturers

A few years ago, the ECHA allowed companies and individuals to add public commentary to the proposed PFAS ban. Several manufacturers in the electronics supply chain added their perspectives. These comments lend insight into just how embedded PFAS are in electronics manufacturing and the electronics supply chain—including and especially semiconductor manufacturing and its highly intricate processes. 

Here are three of these comments—all of which are related to the role and impact of PFAS in the semiconductor manufacturing process:

Comment One

“Our research clearly demonstrates that if the semiconductor industry’s proposed derogation does not fully cover the uses captured in the updated Table A.49, then the ability to manufacture or import semiconductors in the EU will stop following the entry into force (EiF) and the expiration of the 18 month transition period (≈ 2028 timeframe).

Rather than being hyperbole, this is the only foreseeable outcome based on the fact that essentially all equipment, and most chemicals, required for the semiconductor manufacturing process depend on the use of PFAS substances, mixtures, and articles for which replacements are not currently known.  Such an outcome will be nothing short of a catastrophe for the EU economy and its citizens given the criticality and strategic position the semiconductor industry holds in enabling so many devices and industries such as automotive, electronics, communications, data storage & analysis, legal & regulatory infrastructure, remote education, scientific (including materials) research, medicine & medical devices, clean technologies for green energy etc.” - SEMI Europe GmbH, Germany

Comment Two

“The lithography process is one of the most important processes in semiconductor production for the manufacturing of large scale integrated circuits (=LSI). Without this process, LSI cannot be made. We, Shin-Etsu, provide the photoresist materials, EB resist materials, middle layer materials and under layer materials to semiconductor manufacturers and photomask manufactures as our customers. PFAS are used for improving each and every performance.

If we cannot use PFAS, we will not be able to continue to provide lithography materials with the same level of performance.” - Shin-Etsu Chemical Co., Ltd., Japan

Comment Three

“PFAS possess various properties not found in other substances, such as heat resistance and chemical stability, and have therefore been used as essential materials in a wide range of applications, including energy (fuel cells, lithium-ion batteries, etc.), semiconductor manufacturing, automotive components, machinery and devices of all kinds, telecommunications, healthcare, construction, and household goods. If the manufacture, placing on the market, and use of PFAS were to be uniformly banned, economies and societies could be severely impacted.” - Keidanren (Japanese Business Federation), Japan

Respond to Regulatory Risk With Z2

A major part of preparing for impending PFAS regulations—whether it’s in the U.S., Europe, or other parts of the world—is gathering a more complete understanding of all the substances that go into your products. In many cases, that means initiating communications up the supply chain by reaching out to direct and sub-tier suppliers in order to obtain information on their full material declarations (FMDs). For many organizations, this can be a slow, laborious process, requiring a substantial amount of back and forth, documentation verification, and analysis to understand where a company’s PFAS vulnerabilities lie. 

Z2 offers an effective compliance tool that can help businesses carry out the due diligence necessary to pinpoint the PFAS in their supply chains. Z2 has a dedicated compliance team that reaches out to suppliers to obtain all the required compliance and regulatory information—whether it’s for emerging PFAS restrictions, REACH, RoHS, or ESG frameworks. 

Covering over 180 major global regulations, Z2 provides a single comprehensive solution to organizations’ compliance needs. 

To learn more about Z2 and how it can help companies prepare for the rapidly evolving PFAS regulatory landscape, schedule a free trial with one of our product experts.