European seals manufacturers have been to the fore in warning about proposed EU restrictions on per- and polyfluoroalkyl substances (PFAS) and the damage such measures could do to many industries in the region.
In February, the European Chemicals Agency (ECHA) announced proposals, prepared by authorities in Denmark, Germany, The Netherlands, Norway and Sweden, to essentially ban all PFAS because they are “very persistent in the environment”.
“If their releases are not minimised, people, plants and animals will be increasingly exposed,” claimed the ECHA, launching a six-month consultation process to gather feedback from all stakeholders about the proposals, from 22 March.
Among many other potential impacts, the EU chemicals-safety watchdog’s move raised the possibility of a ban on fluorinated polymers including PTFE and FKM/FFKM elastomers being introduced as early as 2025.
In response to the chemicals agency’s move, the European Seals Association (ESA) started a process to gauge the impact of the proposed PFAS regulation across the many application areas covered by the industry.
Likewise, the UK Gasket & Sealing Association (UKGSA) alerted all member companies about the importance of participating in the ECHA consultation, pointing to the availability of an ‘advocacy toolkit’ and other resources to facilitate input into the process.
Seals manufacturers, such as UK-based James Walker, also urged downstream users “whose feedback is considered critical in presenting a valid case for derogation,” to participate in the process – a call echoed by fluoropolymer suppliers.
For Cedric Triquet, EMEA strategy and advocacy director, advanced performance materials at Chemours, a particularly surprising aspect of the dossier supporting the ECHA proposals was the broad definition of PFAS.
“This matters because the proposals do not differentiate between different families among PFAS or the fact that, for example, fluoropolymers are a really different type of substance,” Triquet said.
Therefore, more than 10,000 substances – daubed ‘forever chemicals’ by ECHA – could be eliminated after a transition period of 18 months, he explained in a recent webinar on the topic.
As the proposed restrictions cover the manufacture, production, import and use of PFAS in an article or as a raw material, Triquet said, for example, that even “the importation of microchips into the EU would no longer be possible.”
And, while a limited number of products might be derogated for five or 12 years, even such a “delayed ban” would undermine investment in the EU by many industries.
The Chemours official went on to detail how “fluoropolymers are currently essential in a huge number of essential industries and applications.”
For instance, he said, no other industry, or at least not many, would be able to continue to survive without the solutions that the chemicals industry brings.
“But chemicals manufacture needs [fluoropolymer] seals, gaskets, and many other products,such as linings and coatings, to operate safely and protect people and the environment.”
Similarly, automotive vehicles, including electric vehicles, rely heavily on fluoropolymers in a wide range of parts, said Triquet who also referenced the EU aerospace industry, asking: “who would want to fly in an aircraft without fire-resistant cables?”
To further illustrate the looming situation, he cited how recent microchip shortages had severely impacted the EU automotive industry and many other industries.
“This shows how critical this industry is for all other industries,” said Triquet. “But without fluoropolymers, there is no European semiconductor industry.”
The Chemours official cited an independent analysis showing that the total economic loss for the silicon industry of not being able to operate any longer in Europe would be over Ä63 billion and cost 21,000 jobs.
Green Deal threat
Ironically, also under threat from the PFAS ban is the EU’s own Green Deal programme, which relies on the development of new-mobility, hydrogen-fuel and other clean-energy technologies, all of which rely on fluoropolymers.
To avert such disastrous outcomes from the proposed EU ban, stakeholders throughout the fluorochemicals and fluoropolymers supply-chain are being urged to participate actively in the ECHA consultation process.
“For any market, any application, any use, where there is a clear necessity for feedback to the authorities, this has to happen during the public consultation,” said Triquet. “We cannot miss this [opportunity] as it is very critical for industry.
“Please submit information with data showing why this product is essential for your application, the social-economic impact if you have to exit and how European industry cannot afford this.”
Moreover, Triquet emphasised, “if companies do not spend time or resources now in contributing to the ECHA consultation, then the political case [against the proposed ban] is going to be much weaker.”
Following the consultation, ECHA’s two committees – for risk assessment (RAC) and socio-economic analysis (SEAC) – will study the different aspects of the submissions when developing their opinions on the proposal.
RAC will give its opinion on whether the proposed restriction is appropriate in reducing the risks to the environment and to people’s health. SEAC will give its opinion on the socio-economic impacts, i.e. benefits and costs to society, associated with the proposal.
Meanwhile, the uncertainties created by the PFAS proposals have triggered a search for alternatives – James Walker, for one launching an R&D programme to identify and develop materials to help industry comply with the threatened EU regulations.
The UK seals maker will carry out the study in partnership with the International Institute for Nanocomposites Manufacturing (IINM) – part of the Warwick Manufacturing Group (WMG).
The 24-month collaboration with WMG, based at the University of Warwick, will focus on high-performance sealing products that rely on fluoroelastomers for resistance to extreme temperatures and aggressive chemicals.
These materials “are critical to the semiconductor, aerospace, petrochemical, defence and nuclear industries, for example,” said James Walker, noting that currently, there are no suitable alternative materials available.
“Alternative sealing materials are urgently needed to replace PFAS,” emphasised the UK engineering group, which aims to leverage WMG’s “small-scale, advanced, mixing capability” and its own expertise in nano-fillers and polymer science.
The project will also tap the University of Warwick’s analysis capabilities, including a rubber process analyser, with wide temperature range capabilities, added research lead Dr Chaoying Wan.
“It is the only one in the UK, and one of only a few in the world with the capability to simulate dynamic elastomer performance at very low temperature,” she said.
The function will be “extremely useful” to compare differences in formulation design for applications such as high-pressure or low-temperature sealing.
James Walker’s role will be to rapidly design, manufacture and screen bench-scale test formulations. The combined R&D effort is expected to enable “rapid development and commercialisation of materials.”