PFAS Area of Application - Current Status

Dear Sir or Madam,

On 13^th June 2024, the two REACh committees RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee) announced their preliminary conclusions for the sectors:

• Consumer mixtures, cosmetics and ski wax (already discussed at the March plenary session)
• Metal coating and manufacture of metal products (discussion in June).

In addition, the RAC Committee reached a preliminary conclusion on the scope of the proposal and the hazards of PFAS. The main concern of PFAS, according to the committee, is their persistence, which means that PFAS can remain in the environment for a very long time. In addition, some PFAS may also be of concern for the environment and human health. The RAC also considered that the exclusion of certain PFAS from the scope of the restriction is not sufficiently justified due to their potential harm to the environment.

The conclusions agreed at the RAC and SEAC meetings are provisional until the committees have finalised the assessment of the entire restriction proposal (including all sectors of use) and adopted their opinions. These opinions will then be communicated to the public.

The committees also announced the sectors they will assess in the next meetings. In September, they will focus on the following topics:

• Textiles, upholstery, leather, apparel, carpets (TULAC)
• Food contact materials and packaging
• Petroleum and mining.

The following areas will be discussed in December:

• Applications of fluorinated gases
• Transport
• Construction products
  
  In addition, the 5 submitting countries will revise their original proposal again.

The aim is:

• To identify uses that were not assessed in the original restriction dossier. These will either be integrated into assessments of existing sectors or, if necessary, additional areas of use will be created.
• To evaluate the information on possible PFAS alternatives
• To examine the impact of changes to other relevant EU regulations implemented since the submission of the restriction dossier was submitted on the latter or how they interact with it, e.g. the revised F-Gas Regulation.
• Evaluate the information submitted on PFAS alternatives and use it to review the appropriateness of the proposed exemptions and transition periods. Exemptions can be added, revised or deleted, while transition periods can be maintained, extended or shortened.
• To examine whether restriction options other than a ban are suitable for addressing the risks identified in connection with PFAS (across the entire life cycle). This examination will be carried out if corresponding proposals have been submitted in the consultation that have not yet been taken into account.
• Revise the socio-economic impact assessment with a view to clearly presenting the trade-offs between the different restrictions options considered. This should help policy makers to make informed decisions.
• In addition, the five authorities will also consider the information submitted in the consultation on the hazards and risks of PFAS over the entire life cycle.

These reviews will result in a revised version of the proposal. All 5 states have announced that these reviews will take a reasonable amount of time.

The ECHA is making every effort to progress the opinion following the updates of the proposal by the five national authorities. The opinions will then be communicated to the European Commission as soon as possible.

Further information can be found on the ECHA website:

https://echa.europa.eu/documents/10162/67348133/news_annex_rac_seac_june_2024_en.pdf/df1ded2a-58a9-8d76-f57c-80f344886efd?t=1718261484827

https://echa.europa.eu/documents/10162/2166400/RAC-69_draft_minutes_en.pdf/0e8d5c3d-db98-ff67-9f98-25067b6d12e9?t=1718369752818

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 will continue to use FKM, FFKM, PTFE and FVMQ materials. In close cooperation with production partners and compound suppliers, however, possible alternatives are still being analysed for their equivalence.

For certain areas, 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.

i.V. Eckhard Lück
ULMAN Dichtungstechnik GmbH
Leiter integr. Managementsysteme
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