F-gases in the PFAS restriction file

What to know about PFAS

HFCs, HFOs and HCFOs are a distinct subset and due to their properties are not commonly regarded as PFAS.

Per- and polyfluoroalkyl substances, PFAS, covers a broad range of substances that according to currently accepted terminology contain at least one perfluoralkyl group.

The five authorities of Denmark, Germany, Norway, Sweden, and The Netherlands have relied on the OECD’s definition on PFAS to define the scope of the proposed restriction, which covers approximately 10 000 substances.

The pre-published proposal defines the group as:

What about HFCs, HFOs and HCFOs?

HFCs, HFOs and HCFOs are not commonly regarded as PFAS, as they break down in the atmosphere to substances that naturally occur in the environment. They have a defined atmospheric lifetime, measured in days or months for HFOs and HCFOs, and years or decades for HFCs.

HFCs, HFOs and HCFOs are short chain substances (≤ C₅ chains) and are not considered to be persistent, bioaccumulative or toxic substances, as defined in REACH Regulation Annex XIII.

They are gases, or low boiling point liquids that, if released to the environment, will rapidly volatilize and enter almost exclusively into the atmosphere, and are rarely found in bodies of water, ecosystems, or soil.

 Their breakdown mechanisms in the atmosphere are generally known (see table for detailed breakdown products and source references which is available here). Their final degradation products are all substances that are believed to have occurred naturally in the environment for millions of years.

The REACH restriction process

REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals, EU REG 1907/2006) is an EU regulation aiming at improving the protection of human health and the environment from the risks that can be posed by chemicals, while enhancing the competitiveness of the EU chemicals industry.

In principle, it applies to all chemical substances and therefore it has an impact on most companies across the EU.

Through the restriction process, it is possible to limit or ban the manufacture, placing on the market (including imports) or use of a substance or a group of substances.

The process for restrictions is quite long and it usually involves several players such as EU Member States, the European Chemicals Agency, and the European Commission.

Possible impact of the restriction on F-gases sector

An EU-wide ban (on the manufacture, placing on the market – including imports – or use of a substance) of the F-gases that fall into the OECD definition of PFAS would obviously result in a significant reduction in the availability and possible uses of these substances in the EU. An immediate ban could result in a scarcity of fluorinated refrigerants fluids to service and maintain the existing equipment on the market.

Moreover, the PFAS restriction could impact the components of the devices, resulting in further research needed to test and ensure safety of the new and PFAS-free components for devices using any kind of refrigerant fluids such as heat pumps, air-conditioning (including mobile), medical devices.

Hundreds of millions of systems could become obsolete under a PFAS restriction, as these systems can not readily be retrofitted with the non-PFAS refrigerants, causing an increase in production of waste. A more pragmatic approach that may be considered would be to allow continued use of existing equipment until its normal end of life, this would require a derogation to allow continued use of virgin and reclaimed F-gases to service this existing equipment for years possibly even decades.

EFCTC will carefully analise the proposal documents to ensure that the information on the F-gas sector is correct. EFCTC remains available to support the downstream users in their work on the restriction and encourages them to contribute to the public consultation by submitting information and data.