Addressing the fragmented regulatory landscape of PFAS in electrical and electronic equipment
There is increasing attention on the use of per- and polyfluoroalkyl substances (PFAS) in electrical and electronic (E&E) equipment — an important sector where PFAS are commonly found. This attention is bringing new challenges for manufacturers and retailers, who must stay informed on a fragmented and developing PFAS regulatory landscape.
These frequently asked questions were collected by UL Solutions chemistry experts during webinars and live events. They aim to address common areas of confusion E&E manufacturers and retailers may encounter when managing PFAS-related compliance.
Explore the FAQs below and contact us anytime to discuss your compliance strategy.
- Where are PFAS found in E&E equipment?
PFAS chemicals may be present in a range of E&E equipment, including but not limited to semiconductors, printed circuit boards, wires and cables, coatings, electrical insulation, seals and gaskets, computer hard drives, etc.
- Why are PFAS used in electrical equipment?
PFAS have unique chemical properties that appeal to the industry, including:
- Chemical stability
- Thermal stability
- Low surface tension
- High thermal and electrical insulation
- Highly water repellent
- Release agents or lubricants
- Which countries or regions have banned or restricted PFAS specifically for E&E equipment?
Globally, PFAS regulations are shifting toward broader comprehensive bans and stricter enforcement. Many countries are actively restricting or proposing to restrict the use of PFAS in E&E equipment.
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Europe and Switzerland – Regulations include the EU Persistent Organic Pollutants (POPs) Regulation, which implements the Stockholm Convention and restricts certain long-chain PFAS. In addition, the EU Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation — Annex XVII, entry 65, restricts C9-C14 linear and/or branched perfluorocarboxylic acids (C9-C14 PFCAs), their salts and related substances.
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United States (U.S.) – PFAS regulations currently vary by state. Some states have bans on PFAS in cookware, including electric cookware. Maine, Minnesota and New Mexico will ban PFAS in all products unless there is a “Currently Unavoidable Use” waiver.
At the federal level, the U.S. issued a Toxic Substances Control Act (TSCA) reporting rule under section 8(a)(7) that requires manufacturers and/or importers of products containing PFAS to report on PFAS use, production, byproducts, disposal, exposures and known environmental or health impacts for the period from Jan. 1, 2011, through Dec. 31, 2022. The reporting window opens July 11, 2025.
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- Are PFAS found in batteries?
Yes. PFAS can be found in various battery components, including but not limited to coatings, gaskets, seals, pipes, valves, etc. Lithium-ion batteries can contain PFAS, specifically bis-perfluoroalkyl sulfonimides (bis-FASIs). PFAS salts and additives may be used in lithium-ion batteries to enhance performance, durability and safety.
- For PFAS reporting under TSCA, what if my supplier or I don’t have product information from 2011 to 2022?
Testing is not required under the TSCA rule. However, if you are an importer of articles and you have information on the presence of PFAS, you may have specific reporting obligations.
- If I request a PFAS declaration from my supplier and I have nondetectable test reports for target PFAS substances and fluorine , is that sufficient for EU and U.S. markets?
In principle, yes. There are currently no specific testing requirements in either market. Not detectable test reports for target PFAS substances and fluorine can serve as effective risk mitigation when managing PFAS in your products.
- Are there databases where I can find high-risk materials used in E&E applications that contain PFAS?
In the EU and the U.S., there are databases listing uses of registered PFAS. Some materials such as fluorinated polymers are considered high-risk materials for E&E. In contrast, components like metal parts typically do not contain PFAS. PFAS may also be present in applied paints. However, these databases are not comprehensive. For example, in the EU, polymers are not subject to registration. For imported articles, specific PFAS may be used that are not registered as substances in either the EU or the U.S., making it difficult to obtain complete information on their use.
- Is fluorine screening a reliable method for confirming PFAS are not present?
It depends. If fluorine is not detected and a supplier declaration confirms no intentional use, this may be sufficient for some U.S. markets. However, for the EU market, fluorine screening alone is not sufficient.
- What is the capability among service providers to measure total fluorine or test for individual PFAS substances according to the limits of 25/250 parts per billion (ppb)?
Some laboratories can measure total fluorine, but current research indicates that detection limits for total fluorine in consumer products do not show levels as low as 25/250 ppb. Typical detection limits for total fluorine are in the range of 10 to 20 milligram per kilogram (mg/kg).
It is not known if any laboratory can test for all 10,000 targeted PFAS substances using liquid chromatography/tandem mass spectrometry (LC/MS/MS) or gas chromatography/mass spectrometry (GC/MS).
UL Solutions laboratories offer targeted testing for a defined list of PFAS substances. For these substances, limits of 25 ppb for an individual target substance and 250 ppb for the total of all target substances can be reached.
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