The report highlights that this feedback has helped ECHA continually enrich the background material related to PFAS and has identified a number of uses that were not specifically mentioned in the initial draft of the bans:
- Sealing Applications: Fluoropolymers have a wide range of uses in consumer, commercial and industrial applications, including seals, pipe linings, gaskets, valve parts, etc.
- Technical textiles: for example, high-performance membranes, use of PFAS in medical applications not involving medical devices, outdoor technical textiles (such as tarps).
- Printing Applications: Permanent parts and consumables for printing applications.
- Other medical applications (eg, packaging and excipients for pharmaceuticals)
Fluoropolymers, a class of PFAS that has attracted significant attention from stakeholders, were discussed next. The consultation process provided information on the availability of alternatives to these polymers, technical and organisational measures to reduce their environmental emissions, and the potential socio-economic impacts of banning their production, marketing and use. During the opinion formation process, all participants paid particular attention to these compounds.
Further restriction options
The initial ban document was primarily a phased ban (when alternatives were not yet available) in order to systematically transition to alternatives when they become available. During the public consultation, additional information provided by stakeholders led to the feasibility of other ban options beyond a complete ban to achieve regulatory goals - significantly reducing PFAS emissions throughout their life cycle. Particularly for those uses and industries where a complete ban may have disproportionate socio-economic impacts (for example, where alternative technologies are not predictable), new ban options may improve the practicality of ban proposals in specific applications.
Potential restriction options will be compared to the two proposed alternatives (complete ban/phased ban depending on availability of alternatives), and alternative approaches other than a ban in some uses may be suggested. These alternatives may include conditions that allow the continued production, marketing or use of PFAS rather than an outright ban; or conditions that must be met before alternatives are available for the production, marketing or use of PFAS.
This assessment, currently underway, covers the use of PFAS in certain industrial applications, such as batteries, fuel cells and electrolysers . The same assessment will be conducted for other industries, such as medical devices and semiconductors provided this information is raised during the public consultation. Additionally, the information presented during the public consultation may provide the basis for the production of fluoropolymers and alternative restriction options throughout their lifecycle. Of course, the objective of the ban proposal, to reduce environmental emissions, will remain.
Next Steps
Opinion development work will proceed during 2025 and will result in a RAC Opinion and a draft SEAC Opinion. A subsequent consultation will be held on the draft SEAC Opinion. This will provide an opportunity for all interested third parties to provide relevant inputs on the socioeconomic aspects to be considered in the final SEAC Opinion
