Restricting PFAS means also restricting fluoropolymers

The EU restriction on PFAS includes the wide use of fluoropolymers found in the production of plastic and rubber, coatings, paints, lubricants, greases, and in the chemical industry as well as in consumer products such as textiles, electronics, cars, and non-stick coatings for cookware. Interest groups are lobbying for ‘a time-unlimited derogation for manufacturing and use of fluoropolymers in designated applications now and in the future arguing they will ensure responsible manufacturing of fluoropolymers and responsible life cycle management ¹

Can fluoropolymers be responsibly produced and managed at the end of life?  Facts prove otherwise.

Considering it was widespread contamination from the production of fluoropolymers that first alerted the global scientific community in 1992 ²to PFAS hazards, it’s essential having public data on PFAS emissions from all life cycle stages of fluoropolymers.

While data is often lacking, even with a call for input from ECHA, recent scientific assessments highlight PFAS emissions from fluoropolymer production, use and end of life waste management. A lifecycle perspective dispels the claim from the PFAS industry that fluoropolymers are polymers of low concern. 

A 2020 study points out that fluoropolymer producers switched out the long-chain PFAS in polymer production with shorter chain replacements with similar physical and chemical properties. ³ In their 2024 study, renown PFAS researchers summarize how a wide array of additional hazardous fluorinated organic substances are used, formed and emitted to air and water during the production of fluoropolymers. ⁴

“Based on the available data, it is clear that the emissions from fluoropolymer production plants to air and water are still significant and that the production of fluoropolymers continues to introduce persistent substances to the environment”

(Dalmijn et al. 2024)

Further, the application of fluoropolymers in many articles and industry sectors, can lead to emissions from product manufacturing sites, but the amount of information made available on emissions related to article manufacturing is very limited. ⁵ Yet the Fluoropolymer Product Group maintains claiming production to be safe.

The end-of-life stage of fluoropolymers perpetuates PFAS emissions.

The extreme persistence of fluoropolymers in the environment can lead to a wide array of issues, particularly with respect to disposal of fluoropolymer-containing wastes and products. The PFAS industry maintains that fluoropolymers can be safely separated from other waste streams and destroyed through incineration. ⁶In reality, the end-of-life stage/waste management of fluoropolymers can be an important secondary sources of PFAS emissions.

In landfills, PFASs are not destroyed and will eventually enter the environment via leachate and air ⁷while contributing to releases of PFAS microplastics. ⁸When incinerated, fluoropolymers are not fully destroyed and can decompose  to produce highly persistent ‘smaller’ PFAS substances such as Trifluoroacetic acids (TFA) and other compounds. ⁹TFA is highly persistent and potentially reprotoxic substance, that is the dominant PFAS found in Germany’s drinking water. ¹⁰

Because fluoropolymers are typically contaminated by other substances and fillers, the recycling of fluoropolymers in consumer articles is very difficult, the fractured waste streams are not economical and thus almost not practiced at all.

Given fluoropolymers’ extreme persistence, emissions associated with their production, use, and disposal, and high likelihood for human exposure to PFAS, fluoropolymers must be fully covered within the currently discussed universal restriction on PFAS. 

Can fluoropolymers be termed ‘polymers of low concern’? No. 

The PFAS industry claims that fluoropolymers should not be grouped with other PFAS because they meet the Organization for Economic Cooperation and Development (OECD) criteria for “polymers of low concern”. ¹¹The OECD draft criteria were established in 1990, new information, data and considerations have emerged leading them to advise ‘ that ‘the regulatory schemes of individual countries should be consulted.’ ¹²The OECD has not established an agreed set of criteria for polymers of low concern thus cannot confirm that  fluoropolymers should be considered polymers of low concern.

For more information, rewatch ChemSec’s webinar in the Beyond PFAS series on fluoropolymers
 -- Insights from the OECD, science updates and safer alternatives in focus --

Are fluoropolymers essential to the European Green Deal? No. Innovation is filling the market with PFAS-free alternatives.

An analysis by Chemsec points out that only about eight per cent of the total production volume of the fluoropolymer market in the EU goes towards the often-cited examples of renewable energy, semiconductors and pharmaceuticals. ¹³ Most of the production goes to the transport sector as well as coatings, paints and food contact material, but also into uses in the textile sector and consumer products like fishing lines and music strings. [DR1] [DR2] Yet, the industry states that fluoropolymers should have unrestricted use and are an indispensable driver of the European Green Deal – for example, across smart mobility, clean energy and sustainable industry – and are used within various components of renewable energy installations, such as hydrogen and PV panels and lithium-ion batteries. ¹⁴

Restricting PFAS will ramp up innovation

Many brands and retailers have already made great strides in researching and switching to safer PFAS-free solutions in refrigeration, heat pumps, semiconductors, ¹⁵hydrogen production ¹⁶ and EV batteries ¹⁷demonstrating the pace of change with more to come . solutions for PFAS-free lithium batteries have been in existence for over a decade. ¹⁸

Read further in ChemTrust’s FAQ briefing for more information about which PFAS chemicals are used in which applications and on the alternatives.

Industry front-runners recognize the importance of regulation in their efforts to remove substances of concern from their product line. Dozens of companies, including major players like H&M, joined the PFAS movement, expressing their support for the PFAS restriction and committing to transition towards PFAS-free alternatives. ¹⁹In Dec 2022, 3M announced they would discontinue manufacturing all fluoropolymers, fluorinated fluids, and PFAS-based additive products by the end of 2025, stating  ‘they are committing to innovate toward a world less dependent upon PFAS.’ ²⁰   

Read more on the positive impact of regulation for innovation here

The EU Restriction on PFAS gives companies adequate time to transition away from fluoropolymers.  Under the restriction proposal, companies will initially have 18 months to phase out PFAS alternatives by default. For uses where there is sufficiently strong evidence that more time is needed, or they are not yet available in sufficient quantities, a 6,5-year derogation is proposed. A 13,5-year timeframe is for cases where there are no alternatives yet available and the identification and development will take considerable time. 

              More answers to frequently asked questions on the PFAS restriction here

Brands, retailers and investors require regulatory certainty to reduce business and financial risks, and incentive innovation. ²¹ That is why the EU Restriction on PFAS must ensure fluoropolymers are within the scope of a comprehensive forward-looking restriction.

1. Fluoropolymer Advocacy Toolkit: How to engage in the Public Consultation process under REACH
   April 2023.  Chemours ↩︎
2. A Legal History of PFAS. https://waterfm.com/a-legal-history-of-pfas/ ↩︎
3. Lohmann et al. (2020) Are Fluoropolymers Really of Low Concern for Human and Environmental Health and Separate from Other PFAS? Environ. Sci. Technol. 2020, 54, 20, 12820–12828. 2020. ↩︎
4. Dalmijn et al. (2023)  Emission inventory of PFASs and other fluorinated organic substances for the fluoropolymer production industry in Europe.  Environmental Science Processes & Impacts. Royal Society of Chemistry. ↩︎
5. Wickersham et al. (2023) Characterization of PFAS air emissions from thermal application of fluoropolymer dispersions on fabrics ↩︎
6. What happens when fluoropolymers reach the end of their lifespan?. Fluoropolymer Product Group. FAQ. ↩︎
7. ANNEX XV RESTRICTION REPORT – Per- and polyfluoroalkyl substances (PFASs) ECHA. Page 42. ↩︎
8. Lohmann et al. (2020). ↩︎
9. Cui et al. (2019) The contribution of fluoropolymer thermolysis to trifluoroacetic acid (TFA) in environmental media.  Chemosphere. 2019 doi: 10.1016/j.chemosphere.2019.01.174 ↩︎
10. Neuwald et al. (2022) Ultra-Short-Chain PFASs in the Sources of German Drinking Water: Prevalent, Overlooked, Difficult to Remove, and Unregulated. Environ. Sci. Technol. 2022, 56, 10, 6380–6390. May 4, 2022. ↩︎
11. Fluoropolymers Product Group. FAQ. ↩︎
12. OECD. Polymers of Low Concern. ↩︎
13. ChemSec (25 May 2023) The top 12 PFAS producers in the world and the staggering societal costs of PFAS pollution.                 ↩︎
14. Fluoropolymers Product Group. Op cit. ↩︎
15. Sharma et al (2023) Safer and effective alternatives to perfluoroalkyl-based surfactants in etching solutions for the semiconductor industry. Journal of Cleaner Production, 415, 137879. ↩︎
16. (Hydrogen production) Fraunhofer IAP, July 2023. Novel anion-conducting membranes for electrolysis. ↩︎
17. The GM-Backed Company Ridding EV Batteries of Harmful ‘Forever Chemicals’ – Nanoramic Laboratories’ CEO Eric Kish. Aug 21 2023.  ↩︎
18. Leclanché ready for PFAS restrictions in Europe thanks to its water-based cell production. 20.10.2023. ↩︎
19. ChemSec. PFAS movement ↩︎
20. 3M to Exit PFAS Manufacturing by the End of 2025. 3M News Center.  Dec. 20, 2022  ↩︎
21. Why investors should support the transition to safe and sustainable chemicals. BNP Paribas Asset Management. Feb 27, 2024. ↩︎