Orgalim position and recommendations on proposed PFAS restriction

Orgalim represents Europe’s technology industries, comprised of 770,000 innovative companies from the EU’s largest manufacturing sector.  In its position paper, Orgalim states that Europe’s technology industries are fully committed to reducing the content of hazardous substances in their products to support a more circular economy and a healthier environment. However, the proposed general ban on the production, use, and market availability of PFAS would significantly impact on its industries’ ability to produce robust and reliable products. The proposed general ban on the manufacture, use and placing on the market of any kind of PFAS (in substances, mixtures, and articles) would have a massive impact on nearly all its member companies, whose technologies are essential for the energy transition, digitisation, European infrastructure, transport and logistic chains, healthcare, process automation/measurement technology, being the sustainability of these products intricately linked to the use of PFAS.

Orgalim comments that it is important to distinguish between the different PFAS (groups) and the risks from each use. It is also important to consider whether identified risks can be minimised through targeted measures, e.g. in occupational health and safety/emission control or waste legislation, rather than through a general ban under REACH.

Orgalim observes that the definition of PFAS encompasses HFOs for refrigerants. HFOs are already alternative substances for refrigerants following the bans imposed by the F-Gas Regulation and the Montreal Protocol, making them an environmentally-friendly option with a small global warming potential (GWP) compared to certain more harmful fluorinated gases. However, the proposed restriction of PFAS also includes the removal of HFOs, and since they are already covered by both regulations, it is crucial to avoid double regulation to ensure that there will be alternatives left for refrigerants. Therefore, the interface with other regulations related to substances meeting the proposed PFAS definition (e.g., upcoming revised F-Gas Regulation) must be clarified.

The Orgalim position paper is here and reported in Cooling Post and Refrigeration Industry