The EU Commission is planning a blanket ban on the PFAS group of substances, i.e. the perfluorinated and polyfluorinated alkyl substances sometimes also dubbed eternity chemicals. Non-specialists associate PFAS mainly with Teflon pans. But the importance of this group of substances extends far beyond cooking. They are used as refrigerants, for example in heat pumps, as protective coatings for microelectronics - for example in cell phones, and modern solar cell production also relies on them. As things stand today, PFASs cannot be replaced in many areas without significant functional and economic disadvantages. This is very evident in the electronics industry, as will be shown in a detailed article in the next issue of Surface Technology Magazine (11/2023) and shortly also on oberflaeche.de. Although considerable efforts are being made to replace PFASs in this area as far as possible, it is clear that this will only be partially successful in the foreseeable future.
Over 10,000 substances
The PFAS group of substances includes industrially manufactured organic compounds in which any number of hydrogen atoms have been replaced by fluorine atoms. According to the definition of the EU Commission, a substance with at least one CF2 or CF3 group counts as part of the PFAS group, but also if all hydrogen molecules have been replaced. According to the OECD list, this includes at least 4700 compounds. The properties vary accordingly. Fluoropolymers do not occur naturally and, depending on the variant, are extremely resistant and chemically inert. A property that is very important for the chemical industry. According to Wikipedia, more than 10,000 solid, liquid and gaseous PFAS compounds with a wide variety of chemical properties are known.
Because these substances are so enormously robust, resistant and versatile, they have made quite a few technological advances possible in the first place. To actually restrict such an extensive group of substances without any differentiation would, according to experts, trigger a domino effect in industry that could hardly be calculated. There are also indirect consequences.
Valuable by-products
It is little known, for example, that caustic soda is a by-product of PFAS production. If PFAS production in Europe were to cease or be severely curtailed, the price of caustic soda could rise to eight times its current level. Also, when working with aggressive chemicals, such as in electroplating operations, sumps are lined with PFAS material, otherwise the sumps would have to be replaced much more regularly and disposed of properly. Pumps would also lose much of their service life under chemically or mechanically demanding conditions without PFAS. This would be a clear own goal in terms of sustainability, resource conservation, but also economic efficiency.
It is particularly problematic that a large group of substances is to be lumped together. Certainly, there are PFASs that are more problematic than others and for which regulation or restriction could be effective. But there are also many that have no demonstrable health or environmental consequences. For example, the BDI also rejects the EU Commission's intended broad regulation of several thousand substances, regardless of their actual risk. The emissions generated by modern industrial production and processing are minimal, and the industry is working hard to reduce them further. In this context, environmental contamination is not a valid argument for a restriction.
Discussion at the ZVO Surface Days
The fact that this topic is of great relevance to our industry was also demonstrated by the participation in the discussion session on regulatory developments in European and national environmental and chemical policy at the ZVO Surface Days in Berlin. Here, a lively discussion arose between experts and the audience. Experts made it clear that, due to the wide range of uses, it is still difficult to assess what the actual consequences of a comprehensive PFAS ban would be. The discussion also revealed that the willingness on the part of political and regulatory authorities to listen and address the concerns and arguments of industry was shockingly low. In this respect, the consensus of the discussion was that it is important to make the public more aware of the relevance of PFAS substances for Germany and Europe as an industrial location and to build up a counter-pool in this way. He said it was important to make the regulatory authorities aware that such a blanket and non-specific ban on such an extensive group of substances with such heterogeneous properties would be enormously detrimental to industry in Germany and Europe and to technological competitiveness. The fact that the EU Commission recently changed tack on the subject of chromic acid and is now planning a restriction instead of an authorization could be an indication that factual arguments and necessities could ultimately be taken into account, even if after protracted disputes. In any case, it is necessary for companies to check whether and to what extent they or suppliers use PFAS or PFAS are used for precursors. Here, many companies may be surprised at the extent to which PFAS plays a role for them in the production chain.