Since the beginning of 2020, a 5-country initiative (DK, SE, NO, DE and NL) to restrict per- and polyfluorinated alkyl compounds (PFAS) under REACH is running. The goal of the initiative is to restrict them in all non-essential uses. The rationale of the initiative is EU-wide concern that the use of these substances poses an unacceptable risk under Regulation (EC) No. 1907/2006 (REACH) Art 69(4) to the environment, which is not adequately controlled and needs to be addressed.
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Currently, the group of PFAS comprises about 4700 substances divided into 2 main groups Polymers and Non Polymeric PFAS, which in turn are classified into further subgroups. The discussion was triggered by environmental scandals involving PFOA (perfluorooctanoic acid) from the class of non-polymeric perfluoroalkyl acids. This substance was used, among other things, as a starting emulsifier for the production of PTFE. Its use is now banned in Europe as well as in the USA and Japan. The industry's moratorium on voluntary substitution has meanwhile been superseded by the scandals (here especially GenX substances, also derivatives of perfluoroalkyl acids of a chemour technology) discredited.
Subsequently, it is argued that legislation always lags years behind the industry, since after the industry switches to substitute
substances that have a similar hazard potential have. Furthermore, it is argued that the entire group of substances, irrespective of their very different properties and their toxicological evaluation, is environmentally persistent. This is, of course, very difficult to refute, since it is precisely this persistence - the resistance to environmental environmental influences - is an essential property for food contact materials such as cookware.
The problem is that PFASs practically do not degrade naturally, and the biological treatment stages of wastewater treatment plants are also ineffective here, since bacteria are unable to metabolize them. Furthermore, the non-polymeric classes are highly mobile depending on their chain length and therefore spread worldwide. Thus PFOA, for example, is even found in penguin meat in the Antarctic.
Furthermore, especially the classes of perfluoroalkyl acids as well as their devirates show most unfavorable toxicity profiles with negative effects also on humans. The polymers, however, show neither mobility nor health effects of concern. However, it is argued that these in turn represent sources of low molecular weight, mobile PFASs represent.
The aspect of product safety/food contact plays no - or only a minor - role in the overall discussion. For this reason, the
responsibility of the project lies with the European Chemicals Agency ECHA and not with the European Food Safety Authority EFSA.
The restriction process planned by the 5-country initiative is as follows:
Preparation of an Annex XV REACH restriction dossier
Discussion of the dossier in the ECHA committees RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee)
Within 3 months draft amendment to Annex XVII REACH and submission to the REACH Committee
Based on the current status, as well as the composition of the Parliament and the Commission, I assume that there will be restrictions on PFAS.
Whether and how these will also affect polymers and the application cookware and bakeware is difficult to predict and depends on many factors such as the assessment of the environmental performance of the manufacture and processing of the coating materials, disposal and recycling concepts and possible alternatives and their evaluation. However, it can be considered certain that if the arguments of unmanageable environmental risk cannot be refuted, there will be significant restrictions of whatever kind.
We as WEILBURGER Coatings GmbH are therefore working against these restrictions on various levels:
Participating countries, authorities and scope of work for the restriction
Norway: Norwegian Environment Agency Fluorinated gases, ski waxes, applications in oil and gas production and mining
Germany: Federal Institute for Occupational Safety and Health BAuA Chromium plating, consumer products, transport
Netherlands: National Institute for Public Health and the Environment (RIVM) medical and pharmaceutical applications, food contact materials, production of fluoropolymers, waste and recycling
Head of R&D
Phone: +49 6471 315 185
Fax: +49 6471 315 5185
E-Mail: f.pfeifer@weilburger.com
WEILBURGER Coatings GmbH
Ahäuser Weg 12-22
35781 Weilburg
Germany
