May 11, 2023
By Roberta Canciello, senior technical specialist, Retail Consumer Products team, UL Solutions
Several regulatory actions are being taken to regulate per- and polyfluoroalkyl substances (PFAS) in consumer products in the EU. These toxic substances are also known as “forever chemicals” due to their high persistence. Without the ability to degrade, their concentration in the environment will continue to increase. Exposure to these substances can have negative effects on both humans and the environment.
PFASs are a group of about 10,000 mainly man-made substances used in numerous applications in the EU. These applications include textiles, food packaging, lubricants, refrigerants, electronics, construction and many more.
In the EU, some PFAS are already regulated under REACH and POP legislation (see Table 1) and the SVHC list, while other groups are being proposed for restrictions (see Table 2).
Table 1
| PFAS currently restricted in the EU | ||
|---|---|---|
| Substance group | Limits in articles | Applicable from |
| PFOA and PFOA related substances (various cas numbers) | 25 ppb as total content and 1000 ppb for PFOA-related substances | July 4, 2020 |
| PFOS (various CAS numbers) | 1 microg/m2 for treated articles and 0.1% by weight as total content | Aug. 25, 2010 |
| PFCA and PFCA related substances (various CAS numbers) | 25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA-related substances | Feb. 25, 2023 |
| PFHxS | 25 ppb for the sum of PFHxS and their salts or 1,000 ppb for the sum of PFHxS -related substances | Aug. 28, 2023 |
Table 2
| PFAS groups under proposal for restrictions in the EU | ||
|---|---|---|
| Substance group | Limits in articles | Applicable from |
| PFHxA | 25 ppb for the sum of PFHxA and their salts or 1,000 ppb for the sum of PFHxA -related substances | Still under proposal |
The current larger proposals for restriction (see Table 3) will cover a greater number of substances with specific exemptions and different dates of entry into force for specific uses.
PFAS are defined as 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.
A substance that only contains the following structural elements is excluded from the scope of the proposed restriction: -CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (-CH2-), an aromatic group, a carbonyl group (-C(O)-), -OR’’, -SR’’ or –NR’’R’’’, and where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-).
Table 3
| Larger proposals for PFAS restriction | ||
|---|---|---|
| Restriction proposals | Limits in articles | Applicable from |
| Option 1 | Full ban | Still under proposal and there will be a transition period of 18 months without derogations. |
| Option 2 |
|
Still under proposal and there will be a transition period of 18 months with derogation for some uses. |
To ensure compliance with regulatory requirements, relevant enterprises should familiarize themselves with these requirements as early as possible and adapt their protocols and manuals to investigate the presence of PFAS in their products.
UL Solutions can assist customers in finding the best strategies for complying with PFAS regulations in terms of both testing and communication along the supply chain. Additionally, we can provide support and training to help customers prepare for regulatory changes and upcoming restrictions on PFAS.
References
Persistent organic pollutants – perfluorohexane sulfonic acid (PFHxS)
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