Poly/perfluoroalkyl substances (PFAS) are a broad group of man-made compounds that have been receiving increased attention in recent years. Though extremely useful in many industries, these compounds have a growing list of reported health and environmental impacts. Additionally, they degrade extremely slowly if they enter the environment, and are thus referred to as ‘forever chemicals.’ The United States and many other countries have been banning select compounds from this group as health effects are documented, but the European Union recently proposed a more encompassing and disruptive regulatory approach.
Rather than a compound-by-compound approach, the EU has proposed a complete ban on manufacturing and using all compounds within a broad definition of PFAS. Importantly, they have defined PFAS to include fluoropolymers such as PTFE (Teflon™), as well as water-insoluble compounds such as those used in refrigeration and industrial manufacturing.
Though 5- and 12-year exceptions are proposed for some PFAS applications, the general impact of the regulation, if approved, will be a substantial and global effort to replace many widely used chemicals and materials that are used in or supplied by countries of the European Union.
PFAS types and their hazards
With regulations tightening globally, it is important to understand the different classes of PFAS in determining the scope of future supply chain disruptions.
Water-soluble PFAS compounds have been widely used for decades in surface treatments. Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) both fall within this class and were widely used in the past. These two compounds have proven to be very pervasive in the environment and have well-documented health effects (immune system, cholesterol, liver damage, cancer).
Along with a few similar compounds, PFOA and PFOS are now regulated by many countries. Other water-soluble PFAS are being watched closely by regulators throughout the globe as health risks continue to emerge for other compounds in this class.
Water-insoluble PFAS compounds contain only the water- and oil-repellant portion of the molecule but lack the portion of the molecule necessary to dissolve in water. This includes hydrofluorocarbons (HFCs) and hydrofluoroolefins (HFOs), which are common refrigerants, as well as fluids such as perfluorohexane.
These PFAS compounds are not particularly hazardous in their pure form. They are not found in water, but can partition to the atmosphere if released. Though not considered a health hazard in the vapor-phase, EU regulators point to studies that suggest these compounds degrade in the atmosphere to form trifluoroacetic acid (TFA) and other water-soluble PFAS, which then enter water supplies via precipitation.
PTFE and other fluoropolymers behave similarly to other polymers in that they are not soluble in water and are not capable of crossing cell membranes. This negates their ability to cause the negative health impacts or environmental pervasiveness associated with water-soluble PFAS. While they are considered safe within their intended use, EU regulators point to their end-of-life when they may be incinerated and have potential to form water-soluble PFAS compounds and bring the associated problems.
Potential impacts of the proposed EU regulation
The regulatory approach of the U.S. and several other countries thus far has been minimally disruptive to supply chains. Specific water-soluble PFAS compounds are being regulated as soon as health risks become clear, but those compounds are often replaced with similar PFAS alternatives. The approach may eventually change, as critics argue that this leads to continued use of materials that will eventually be labeled as hazardous.
A ban on all water-soluble PFAS would be very disruptive. It is challenging to know the full extent to which these compounds are used throughout industry, but the EPA suspects water-soluble PFAS compounds are used at more than 120,000 U.S. sites. The full extent of water-soluble PFAS use in the EU is challenging to estimate, but it is expected that an encompassing regulation of these compounds would be very disruptive to supply chains.
A ban on water-insoluble PFAS compounds would also be very disruptive to supply chains. Various combinations of HFCs and HFOs are used in most refrigerants. HFOs are a more recent development, and are considered by many to be a more sustainable alternative to HFCs due to their lower global warming potential.
A ban on the manufacture and use of fluoropolymers as proposed by the EU would also be very disruptive to supply chains. Fluoropolymers are already widely used and have growing roles such as components in electric vehicle batteries. PTFE, the most widely used fluoropolymer, is commonly used in medical devices, food packaging, laboratory equipment, and many other applications.
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