The European Union plans to impose a restriction on perfluoroalkyl and polyfluoroalkyl substances (PFAS) as part of the REACH regulation. This group of chemicals comprises more than 10,000 different compounds. Among them are fluoropolymers used in industrial products, especially under extreme conditions such as high or low temperatures, intense abrasion or aggressive chemical environments. These materials are indispensable in many machines and systems and are used as seals, valves, hoses or coatings.
Many of these technologies from mechanical and plant engineering are central to the energy transition. After the introduction of the planned measures of the REACH regulation, the production, distribution as well as the use of PFAS would no longer be permitted. Therefore, VDMA North and ProduktionNRW organized a virtual information event on September 13, 2023. The aim was to draw the attention of the mechanical and plant engineering industry to the public EU consultation, which will run until September 25, 2023, and to encourage participation.
PFAS: concern, restriction project, public consultation.
Alena Knauz, substance policy officer at VDMA, first clarified in which products and in which production processes PFAS substances are used. In addition to seals, these substances are also used, for example, in coatings, as electrical contacts or as lubricants – but also in many others. Therefore, virtually the entire mechanical and plant engineering sector is affected by a possible ban, either in terms of products or production – albeit to varying degrees.
The proposal to restrict PFAS under REACH pursues two options: a complete ban or a ban with time-limited application-specific exemptions. Even before the consultation was closed, some active substances were exempted from a ban, while others can continue to be used for a limited time. Any applications not considered for exemptions would be subject to a direct ban on all PFASs after a transition period of 18 months – the machinery and plant engineering sector is particularly affected here.
Although the VDMA and strongly affected VDMA trade associations have already contributed statements to the consultation, companies should also participate individually in order to make clear the effects on their company and their concerns. For this reason, reference was made in the following to the opportunities for participation. In addition to a fully comprehensive and scientific commentary, there was also the option of submitting a contribution of a minimal scope. This could emphasize the approximate extent to which the company would be affected – support was provided by the VDMA position paper and the VDMA handout on the public consultation.
Discussion and exchange of experience
During the final discussion, the problem was highlighted that many manufacturing companies have limited knowledge of which precursors contain PFAS. This problem mainly results from the fact that many suppliers provide little information, have little expertise themselves, or the PFAS group is too large and the substances were not subject to information requirements before. In this context, it was emphasized that it is nevertheless useful to address these challenges in the ongoing consultation.
Furthermore, the approach of the European Chemicals Agency (ECHA) was described as bureaucratic and not very pragmatic, which is perceived as a hindrance for many companies. In this context, the demand was made for additional support from the association.
Although the association is already active on various levels, it was emphasized that additional individual concerns and affected parties are valuable. After all, the ultimate goal is to continue to enable applications without significant risk in order to maintain existing and future PFAS-containing technologies as part of the EU’s efforts toward a climate-neutral society.
- Comments submitted to the public consultation that ended on September 25, 2023.
- Position paper: Comprehensive PFAS ban threatens business fundamentals
- VDMA handout “Participation in the public consultation on the regulation of PFAS under the
- on the regulation of PFAS under the EU REACH Regulation”.
The event was offered by ProduktionNRW and VDMA North. ProduktionNRW is the cluster of mechanical engineering and production technology in North Rhine-Westphalia and is organized by VDMA NRW. ProduktionNRW sees itself as a platform to connect, inform and market companies, institutions and networks among each other and along the value chain. Significant parts of the services provided by ProduktionNRW are funded by the Ministry of Economic Affairs, Industry, Climate Protection and Energy of the State of North Rhine-Westphalia.