Arkema comments on the UE PFAS restriction proposal

On June 1^st, Arkema, a PVDF fluoropolymer producer, provided a response to the public consultation on the EU restriction proposal submitted by 5 countries aiming at banning the manufacture, use and placing on the market of PFAS. In this context, and concerning more particularly PVDF, Arkema has shared data and information relating essentially to:
 

• safety during the life cycle, including toxicological and ecotoxicological information
• emissions
• end-of-life
• potential socio-economic impacts of the proposed restriction.

These data and information have been provided in respect with the scientific approach of REACH regulation that must remain the rule for risk analysis.
 
It has been recalled that Kynar^® PVDF homopolymers and copolymers are used in many industrial applications. They are designed for extreme inertness in harsh environments, flame and smoke resistance properties, weather resistance, durability and ease of processing. They are more than ever strategically key to European industry and sovereignty, as well as to the EU Green Deal, notably for electric vehicles batteries, semiconductor chip manufacturing, 5G, hydrogen production, the manufacture of industrial safety equipment and medical equipment, or water filtration and solar energy.
 
Further details on specific usages features and benefits, emissions, or on the existence and viability of alternatives will be provided in a second submission to the public consultation.
 
As stated in the response provided to the public consultation:
 

• Through extensive research and development activities, Arkema has developed an innovative patented technology to produce PVDF fluoropolymers without the use of PFAS fluorosurfactants, using only non-fluorinated surfactants. Today, Arkema's two largest PVDF production plants do not use PFAS fluorosurfactants at all in the manufacture of PVDF. The last plant will achieve its transition to this new technology by the end of 2024.

• Kynar^® FSF^® PVDF fluoropolymers are considered not to pose risks to human health, have a favorable (eco)toxicological profile, and meet the OECD definition for polymers of low concern. The aforementioned points are the reasons why the United Kingdom authorities have proposed a specific exemption for fluoropolymers, classified in low hazard groups under their draft PFAS regulation.

• Regarding socio-economic impacts, a calculation following ECHA guidelines has been performed for production and use of Arkema's PVDF in Europe. Potential impact of the restriction is quite huge in terms of cost per kilo of emissions saved, which might question the proportionality of the restriction.

• Regarding end-of-life of Kynar^® FSF^® PVDF, data on landfill, incineration and recycling were provided in the submission.

During the public consultation, Arkema proposed, as a preferred option, to adopt a more segmented approach based on the level of risk of the substance to facilitate the effectiveness and implementation of the restriction, and thus to grant an exemption in favor of fluoropolymers produced without PFAS fluorosurfactant. Indeed, it was specified that the potential emissions as well as the end-of-life of these products can be effectively managed through alternatives regulations such as the Waste Directive, the Landfill Directive and the Industrial Emissions Directives.
 
Should the requested exemption not be granted, Arkema has proposed, as an alternative option, to support selective sector specific derogations based on absence of alternative. Based on the information gathered from our customers and downstream users, in many applications, no viable alternatives are available or may require an important compromise on the combination of properties, whilst used in critical applications for the European industry and sovereignty as well as for the EU Green Deal.
 
We will complete our response to the consultation in the coming weeks with further data.