A blanket ban on all types of PFAS (per-and polyfluoroalkyl substances), or ‘forever chemicals’, is currently being considered by the European Chemicals Agency (ECHA). PFAS are used in cleaning products, non-stick pans, personal care products and more, so a ban on these will save lives and deliver sustainable practices. But, as Daniel Fraile at Hydrogen Europe explains, the PFAS subgroups of fluoropolymers and perfluoropolyethers are used in clean techs materials needed for wind turbines, batteries, semiconductors, EVs, heat pumps and hydrogen, with no viable commercial alternative available. Furthermore, they are not “bioavailable,” “bioaccumulative” or water-soluble and are considered polymers of low concern according to OECD criteria. The ECHA should make the distinction and not include these subgroups in the ban, says Fraile. That way the billions already invested in their use won’t be wasted, and the continued roll out of essential clean energy solutions can stay on track.
PFAS: the “forever chemicals”
In January 2023, five countries (Denmark, Germany, Norway, Sweden, and the Netherlands) tabled a proposal under the EU’s REACH (the EU/EEA’s chemicals framework) aiming to ban all types of PFAS (per-and polyfluoroalkyl substances). The PFAS group covers over 10,000 substances which have gained the moniker ‘forever chemicals’ due to their resilience when exposed to water, heat, and time. They do not break down easily, or at all, and residues have been found in humans and in wildlife, with studies linking them to health issues in both.
Just like lead and asbestos before them, the heavy regulation of PFAS is objectively a good thing, particularly when safer, cleaner, and more sustainable replacements exist. PFAS are used in cleaning products, non-stick pans, personal care products and more, and it is certainly right that they be removed from the type of consumer item that we come into close contact with every day.
It is important to mention at this stage that not all PFAS are created equal. The PFAS grouping also includes the subgroup fluoropolymers and perfluoropolyethers. These do not present significant toxicity concerns, cannot degrade into other PFAS, and are not “bioavailable”, “bioaccumulative”, or water-soluble. As such, they are considered polymers of low concern according to the OECD’s criteria.
…used in mainstream clean tech applications
Notably, fluoropolymers are used in a wide variety of clean technology applications. Wind turbines, batteries, semiconductors, electric vehicles, heat pumps, and hydrogen technologies like fuel cells and electrolysers all make use of this particular PFAS at some point in their value chain. The resilience, heat-and power-conducting quality, amongst others, of fluoropolymers make them a crucial component in these technologies. Importantly, there is no viable commercial alternative available and neither is there one on the horizon.
A total ban would undermine climate ambitions
Herein lies the crux of the issue: a blanket PFAS restriction would severely undermine the EU’s climate ambitions. There are no means by which to achieve our emission reduction targets without these clean technologies and, by extension, without fluoropolymers. On the economic side, the hundreds of billions of euros invested over the last 20 years into decarbonising our societies through renewable energy, electric vehicles and green hydrogen would be wasted, as clean tech companies go bankrupt or pack up and move to other markets and our climate ambitions – whatever they may be – fall dramatically short.
A science-based approach to the ban
The file is currently being evaluated by ECHA and there is still plenty of time before it moves from its desk to the European Commission’s. The unprecedented size and scope of the dossier makes this a massive undertaking and is rightly being considered slowly and carefully. Eventually, though, it will be decided upon by European legislators, and it is important that the restriction is approached responsibly and rationally. A recent joint statement united some of Europe’s largest clean tech associations – Hydrogen Europe, Wind Europe, EGEC, ACEA, Recharge, and others – in calling for “a science-based, differentiated approach to the various types of PFAS, based on their essentiality, their environmental impact and availability of alternatives.”
Both the European public and policy makers must be made aware of the nuances to the PFAS restriction to ensure we do not collectively cut off our nose to spite our face. The future of the energy transition is at stake.