As businesses face increasing scrutiny over the environmental and health impacts of chemicals, understanding PFAS (Per- and Polyfluorinated Alkyl Substances) and the uncertainty of the regulatory landscape around them is essential. PFAS compounds have been used for decades across various industries due to their unique properties, but growing concerns over their persistence in the environment have led to calls for tighter controls.
As of September 2024, there is currently no UK or EU legislation specifically governing the use of PFAS products. However, regulatory changes are possibly on the horizon. In January 2023, five European countries (Norway, Germany, Netherlands, Denmark, and Sweden) submitted a proposal to the European Chemicals Agency (ECHA) to restrict and regulate the use of PFAS chemicals.
The proposal is still under review, and its future remains uncertain. Even if it is approved, there is no clear timeline for its implementation. Delays are mounting due to the extensive number of public comments submitted during ECHA’s consultation process. As a result, any final proposal may take considerable time before being submitted, followed by a gradual implementation period.
Given the global reliance on PFAS in critical industries, immediate legislation banning their use is unlikely. Any future regulations would likely be phased in, focusing first on the most harmful substances—particularly those with hydrophobic and polar head groups—and targeting public end-users. Fraser Technologies remains committed to helping clients stay ahead of these regulatory developments.
This article delves into what PFAS are, the environmental risks they pose, and considers the of future regulations. It also explores alternative solutions for businesses seeking to navigate potential restrictions while maintaining efficiency in their cleaning processes. Fraser Technologies, with over 55 years of experience, stands ready to guide clients through this evolving landscape, offering tailored, compliant, and future-proof solutions.
Understanding PFAS: What You Need to Know
PFAS (Per- and Polyfluorinated Alkyl Substances) are man-made chemicals that have multiple fluorine atoms attached to a carbon chain. They were originally developed in the 1950s and there are now >5,000 different PFAS molecules.
The European Chemicals Association (ECHA), an agency of the European Union (EU) defines Per- and Polyfluorinated Alkyl Substances (PFAS) to be the following:
“Any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it)”.
The Environmental Impact and Variability of PFAS Substances
PFAS substances are highly diverse, with significant variation in both their uses and environmental impacts. These chemicals are found in many industries, including cookware, food packaging, fire-fighting foam, and outdoor clothing. Each PFAS compound behaves differently in the environment, depending on factors like its fluorination level, degradation pathways, and potential for bioaccumulation. Understanding the specific properties of each substance is essential for assessing its environmental risks.
So, not all PFAS substances are the same, or have a similar environmental impact.
As mentioned, there are >5,000 different PFAS molecules which have incredibly varying uses and environmental impact.
It is important to understand the characteristics of your solvent, as well as its composition. It is easy to try and write-off a solvent by calling it ‘PFAS’, but the reality of the situation is that the answer is much more nuanced.
There are many factors to consider when determining the impact of your solvent:
- How does is breakdown in the atmosphere?
- What % of your solvent is fluorinated?
- LD 50 Classification
- GWP
- Bioaccumulation and Soil Mobility
- Solvent Usage
- Are your losses to air, drain, or abatement system?
The European Environment Agency state – “It is currently not possible to perform in-depth environmental and health risk assessments of all chemical substances in use in Europe because of the great variety of chemicals and their diverse uses.”
The Current State of PFAS Legislation in 2024
As of September 2024, there is still no formal legislation in place regarding PFAS products in the UK or EU. However, a regulatory proposal from five European nations (Norway, Germany, the Netherlands, Denmark, and Sweden) seeks to impose restrictions on PFAS usage. Despite being under review since January 2023, no laws have been approved thus far, adding to the uncertainty surrounding the future regulation of PFAS.
Future PFAS Regulations: What to Expect
The proposal is still under review (As of 10th September 2024) and there is no guarantee it will pass. Also, if it does pass, noone knows how it will be implemented.
A large number of comments submitted as part of ECHA’s public consideration is
causing increasing delays. It is unlikely that a final dossier/ proposal will be submitted for some time, and then there would be a gradual implementation period.
Given the global reliance on PFAS substances across critical industries, the risk of imminent legislation to halt the use of PFAS products is minimal. Any potential regulation would likely begin in a phased manner, targeting the more toxic substances (hydrophobic and polar head groups specifically), and focus on public end-users.
Therefore the regulatory landscape for PFAS is still evolving. Although the proposal to restrict PFAS is still under review, public feedback has slowed progress. Even if passed, future regulations will likely be phased in gradually, starting with the most toxic PFAS compounds. Businesses that rely on PFAS should stay informed about upcoming regulatory changes and plan for a gradual shift.
Exploring PFAS-Free Alternatives
There are fluorinated solvents on the market that currently fall just outside of the EU definition of PFAS.
These “PFAS-Free” alternatives are new to the market and were not around during the creation of the restriction proposal. Given the ‘closeness’ to molecules deemed to be PFAS, these molecules may well be annexed into any future regulation. As they are so ‘new’, they have not been tested as extensively as the Chemours products which undergo rigorous testing from a performance, toxicological, and environmental stand point.
it is important to understand exactly what your solvent is and not jump to conclusions based on the current EU definition. For example:
As can be seen from the above images, two incredibly similar molecules can have a different PFAS designation.
Every process and application is different, so the correct solvent for your process will have to be determined after an evaluation is completed. With over 55 years expertise in navigating legislative change and working in partnership with our clients through testing and trials, Fraser Technologies is confident that we can assist you in navigating this change, which may take years to come into effect.
If you have a serious concern regarding the use of fluorinated solvents, you may want to assess alternative technologies all together. Fraser Technologies can provide non-biased, process evaluations. We can critically assess your process options and provide a report outlining options. We evaluate based on performance, volume requirements, cost of ownership, sustainability, environmental impact, and much more.
Careful consideration of your solvent's composition and impact is essential when exploring PFAS-free options to ensure both compliance and optimal performance.
Taking Time to Evaluate Your Process
With uncertainty surrounding future PFAS regulations, businesses have time to evaluate their processes before making changes. Rather than rushing into decisions, it’s important to wait for clearer guidance on which PFAS compounds will be restricted and whether specific industries may receive exemptions. A thoughtful approach will help businesses avoid unnecessary disruptions.
Fraser Technologies: Your Partner in Navigating PFAS Regulations
With over 55 years of expertise, Fraser Technologies is committed to helping businesses navigate the complexities of PFAS regulations. We offer in-depth process evaluations, alternative technology assessments, and tailored solutions designed to ensure compliance while maintaining performance and sustainability. Whether you're considering a switch to PFAS-free solvents or optimising your current system, Fraser Technologies is here to guide you through every step.
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