The European Chemicals Agency (ECHA) has announced it is considering “alternative restriction options” after reviewing more than 5,600 “scientific and technical comments” submitted during the six-month public consultation period for the PFAS (per- and polyfluoroalkyl substances) restriction proposal.
The ECHA, an EU body, made the announcement as part of an update on the progress of the PFAS restriction proposal, also known as the “Universal Restriction Proposal.” Included in the more than 10,000 substances under review are several HFCs and HFOs, including HFC-125, HFC-134a, HFC-143a, HFO-1234yf, HFO-1234ze(E), HFO–1336mzz(Z) and HFO-1336mzz(E). Synthetic refrigerants are subject to restriction because the proposal uses a definition of PFAS formulated by the Organisation for Economic Co-operation and Development (OECD) that includes many f-gas refrigerants as well as TFA (trifluoroacetic acid), an atmospheric degradation product of HFO-1234yf (100% conversion) and HFC-134a (up to 20% conversion).
The proposal was submitted to the ECHA in early 2023 by national authorities from Denmark, Germany, the Netherlands, Norway and Sweden and seeks to restrict PFAS under REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals), the EU’s chemicals regulation. The public consultation was held in 2023.
Additional options: The current restriction options are a full ban or a ban with time-limited derogations. The countries that submitted the proposal are in favor of a ban with time-limited derogations “to allow for an orderly substitution process when alternatives have become available,” according to the ECHA. The ECHA did not say if the alternative restriction options would apply to the f-gases subject to restriction under the proposal.
- The ECHA said an example of an alternative restriction could “involve conditions allowing the continued manufacture, placing on the market or use of PFAS instead of a ban.”
- “These alternative options are being considered for uses including, but not limited to: batteries, fuel cells and electrolysers,” the organization said. “In addition, information has been submitted in the consultation that may form a basis for alternative restriction options for e.g. fluoropolymers in manufacturing, service life and end of life, while still adhering to the purpose of the proposal to minimise emissions to the environment.”
- The ECHA did not say if the alternative restriction options would apply to the f-gases subject to restriction under the proposal.
Fluoropolymers in the spotlight: The ECHA said feedback led to the identification of PFAS uses that were not specifically named in the initial restriction proposal, including fluoropolymers used in “sealing applications.”
- These applications include “a broad range of fluoropolymers” used in seals, pipe lining, gaskets and valve parts, all of which are common components found in HVAC&R equipment.
- “The consultation has brought further insight into the availability of alternatives for certain uses of these polymers, technical and organisational measures to minimise their emissions in the environment and potential socioeconomic impacts of a ban of their manufacture, placing on the market and use,” said the ECHA.
- Italian OEM OLAB recently debuted a line of components for CO2 (R744) systems that feature PFAS-free gaskets.
Next steps: The ECHA’s scientific committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) will continue developing their opinions on the PFAS restriction proposal in 2025.
- The RAC will issue an opinion while the SEAC will issue a draft opinion, with a public consultation to be held after its publication.
- To date, the RAC has reached a “provisional conclusion” on the hazard assessment of PFAS. The RAC and SEAC have also reached provisional conclusions in five sectors: consumer mixtures and miscellaneous consumer articles, cosmetics, ski wax, metal plating and manufacture of metal products and petroleum and mining.
Quotable: “The proportionality of each alternative option will be evaluated and compared to the initial two restriction options of a full ban or a ban with time-limited derogations,” said the ECHA.
This article has been updated with more information on the PFAS restriction proposal, the applicability of the alternative restriction options to f-gases and fluoropolymers.
