On the 23rd of February 2022 the European Chemicals Agency (ECHA) brought forward a proposal for an EU-wide restriction on all per- and polyfluoroalkyl substances (PFASs) in firefighting foams. The restriction would prevent further groundwater and soil contamination, reduce health risks for both people and the environment.
The proposal calls for a ban on the use and export of all PFAS in firefighting foams after a stipulated sector-specific transition period. A six-month consultation period commenced on the 23rd of March 2022. creating a forum for evidence-based contributions and comments relating to the proposal. ECHA’s Scientific Committees for Risk Assessment and Socio-Economic Analysis has begun an assessment of the proposed options, and will incorporate the feedback and comments received during the consultation period. The combined opinion of the two committees is expected to be delivered in 2023. The European Commission is expected to follow the findings and decisions of the committee relating to the proposal.
Additionally, five European nations (The Netherlands, Germany, Denmark, Sweden and Norway) are working on a restriction proposal that will also cover all PFASs in other uses. They are planning to submit their proposal to ECHA in January 2023. The EU’s sustainability strategy for chemicals places PFAS at the forefront of policymaking. The European Commission commits to phasing out all PFASs, allowing their use only where they are proven to be irreplaceable and essential to society.
Background
Per- and polyfluoroalkyl substances (PFASs) are a class of thousands of synthetic substances known to be very persistent and mobile. PFAS have been detected in many animal and human blood samples worldwide, as well as remote environments such as glaciers and natural water sources. The impact of perfluorinated compounds to humans and the environment has caused widespread concern and prompted countries and international organizations to act to prevent their proliferation. An increasing number of perfluorinated compounds are or will be considered controlled and restricted according to various regulations, including PFOA, PFOS, C9-C14, PFCA, and many others.
We list the requirements of PFAS across various regulatory frameworks below:
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Substances |
Requirements |
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PFAS |
REACH restricted substances proposed by Germany, the Netherlands, Norway, Sweden and Denmark: Restrictions on the production and use of PFAS substances. Update: A restriction proposal is being developed, no comments yet. |
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TPCH: prohibition。 |
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California AB 652: After July 1, 2023, the intentional addition of PFAS in juvenile products is prohibited, requiring less than 100ppm (based on total organic fluorine)。 |
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Perfluorooctane sulfonic acid and its derivatives |
EU POPs: substances/mixture≤10ppm，article＜1000ppm，textiles or other coated materials＜1ug/m2. |
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China POPs（PFOS its saltsand PFOSF）: From March 26, 2014, the production, circulation, use and import and export of PFOS and its salts and PFOSF are prohibited except for specific exemptions and acceptable uses. |
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‘Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds |
EU POPs: PFOA or any of its salts equal to or below 0,025 mg/kg where they are present in substances, mixtures or articles；PFOA-related compound or a combination of PFOA-related compounds equal to or below 1 mg/kg where they are present in substances, mixtures or articles.。 |
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CSCL（PFOA,its salts）: From October 22, 2021, the production, import or use of PFOA and its salts is prohibited, and the import of specific products containing PFOA and its salts is prohibited. |
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C9-C14 PFCAs,its salts and related compounds |
The 68 item of REACH ANNEX XVII: substance, the mixture, or the article is below 25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA-related substances.。 |
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SVHC（C9-C14PFCAs）: If the SVHC content in the article exceeds 0.1%, information transfer, SCIP notification or REACH-SVHC notification is required. |
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Perfluorohexane sulfonic acid (PFHxS) its salts and related substances |
Consultations substance of the restrictions forREACH: substance, mixture, an article in a concentration below 25 ppb for the sum of PFHxS and its salts or 1000 ppb for the sum of PFHxS related substances. Update: Proposal accepted, no formal resolution issued |
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Undecafluorohexanoic acid (PFHxA), its salts and related substances |
Consultations substance of the restrictions forREACH: substance, mixture, an article in a concentration below 25 ppb for the sum of PFHxA and its salts or 1000 ppb for the sum of PFHxA related substances. Update: Proposal accepted, no formal resolution issued |
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LCPFAC and PFAS |
TSCA The SNUR rule of TSCA: notify EPA |
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