Dear Sir or Madam,
The topic of PFAS is a highly relevant issue that also has implications for the products of Ulman Dichtungstechnik GmbH, Ulman Produktion GmbH & Co. KG, and Titan Industriebedarf Vertriebsges.m.b.H.
On January 13, 2023, the five countries Germany, the Netherlands, Denmark, Sweden, and Norway submitted a restriction proposal to ECHA with the aim of reducing PFAS emissions.
On February 7, 2023, ECHA published this restriction proposal, which prohibits the use of all fluorinated substances that contain or release PFAS, including fluoropolymers (FKM, FFKM, PTFE, TFM, etc.).
During the meetings in March 2023, the two REACH committees, RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee), will assess whether this restriction proposal meets the legal requirements of REACH. If these requirements are met, the 6-month consultation phase is expected to begin on March 22, 2023.
The aim of this consultation phase is to provide polymer manufacturers, mixture suppliers, and manufacturers and users of products with the opportunity to seek further exemptions based on risk-based and socio-economic justifications.
From September 22 onwards, a Risk Assessment Committee will convene to evaluate the collected information and determine the further course of action. There are three possible scenarios for fluoropolymers:
- Fluoropolymers remain on the immediate ban list.
- Fluoropolymers receive a transitional period, which still needs to be defined.
- Fluoropolymers are completely removed from the ban list.
However, by the expected implementation of the amended REACH directive in 2025, the fate of fluoropolymers will be determined.
Depending on the decision, deadlines for the substitution of fluoropolymers will range from 18 months to 12 years.
Research for suitable substitutes has begun, but often these substitutes do not yet possess the outstanding properties of fluoropolymers.
Therefore, April 5, 2023, is the next important day as it will determine the further course of action.
In close collaboration with our production partners and mixture suppliers, we will assess which materials can be replaced using appropriate alternatives and which need to be withdrawn from the market after a transition period.
If you have any questions, please feel free to contact us.
Yours sincerely,
Eckard Lück
ULMAN Dichtungstechnik GmbH
Head of Integrated Management Systems
Data Protection Officer PSCR
