Dear Sir or Madam
On 20th November 2024, the two committees (RAC and SEAC) of ECHA and the 5 countries submitting the dossier gave an update on the current steps.
After evaluating more than 5,600 technical and scientific comments, new applications that have not yet been considered were identified.
One of these is sealing applications, in which a large number of fluoropolymers are used as materials. These are industrial applications such as O-rings, moulded seals or diaphragms made of FKM, FFKM, FVMQ or PTFE.
Fluoropolymers in particular are a group of materials for which technically equivalent alternatives are usually not available. They are therefore of great importance to the interested parties.
New findings on technical and organisational measures to minimise their emissions into the environment and on the socio-economic effects of a complete ban were identified as part of the consultation.
Based on this, this group of substances and their applications will now receive special attention from all actors in the opinion development process.
Furthermore, the aim of the submitters of the dossier is to minimise emissions of all types of PFAS in order to prevent further accumulation of PFAS in the environment and in living organisms of all kinds.
Originally, there were therefore only two options:
- Complete ban
- Ban with temporary exemptions (in the absence of alternatives)
The latter option should be preferred above all because it would enable an orderly replacement process as soon as alternatives become available. This would ensure the availability of sensitive uses, such as the green energy transition.
All the information gathered through the feedback received during the consultation phase in 2023 led to considerations as to whether other restrictions, rather than a complete ban, together with the time-limited exemptions, could achieve the goal of significantly reducing PFAS emissions over the entire life cycle.
These considerations are particularly important for applications and sectors that have submitted information revealing that the socio-economic impact of a complete ban would be disproportionate due to the lack of alternatives.
In the course of 2025, the statement will be further elaborated and will result in a statement by the RAC and a draft statement by the SEAC. A further consultation phase on the draft SEAC opinion will give interested parties the opportunity to put forward important socio-economic aspects to be taken into account in the final draft of the SEAC.
ECHA and the 5 submitting countries are commited to submit a meaningful, independent and transparent opinion from RAC and SEAC to the European Commission as soon as possible.
Ultimately, it will be the task of the European Commission to decide on restrictions together with the EU Member States.
The committees have announced which other sectors will be considered in the upcoming meetings.
In March, applications with fluorinated gases, transport and energy will be considered for the first time.
This will be followed after March:
- Lubricants
- Medical applications
- Electronics and semiconductor applications
Further information can be found on the ECHA website: https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas
ULMAN Dichtungstechnik GmbH will monitor further decisions by the ECHA on the planned ban and take appropriate steps if necessary.
However, as suitable substitutes with comparable properties are not yet available, Ulman Dichtungstechnik GmbH continues to use FKM, FFKM, PTFE and FVMQ materials.
However, possible alternatives will continue to be analysed for their equivalence in close cooperation with production partners and material suppliers.
For certain applications, it is also possible to use other high-quality materials that do not contain PFAS. Our technical department will be happy to support you in your selection.
Please do not hesitate to contact us if you have any questions.
On behalf of Eckard Lück
ULMAN Dichtungstechnik GmbH
Head of Integrated Management Systems / Data Protection Officer / PSC
