History, application fields, health and environmental concerns
The history of poly- and perfluoroalkyl substances (PFAS) manufacturing goes back to the mid-20th century with a recent inventory identifying more than 4,700 PFAS that could have been, or may be, on the global market(1). For example, the chemicals have been used in coatings for textiles, paper and packaging products, non-stick cookware, and to formulate some firefighting foams. Such chemicals have a range of applications in the textile, aerospace, photographic imaging, semiconductor, automotive, construction, and electronics industries(2). Though the application of PFAS is versatile, there has been more and more concern regarding the environmental and health impacts associated with their release.
PFAS consumer product regulations in the EU
EU POPs Regulation
Long-chain PFAS (the so-called C8 chemistry) have been regulated in the EU and internationally. Due to their persistent, bio-accumulative, toxic (PBT) and very persistent and very bio-accumulative (vPvB) properties, PFOA, PFOS, and chemicals that can degrade into them, have been listed under the Stockholm Convention on Persistent Organic Pollutants. As a consequence, they are now restricted under the EU POPs Regulation (Regulation (EU) No. 2019/1021). PFOS has been restricted in the EU for more than ten years now, and PFOA has been added to the restricted inventory in 2020.
The detailed list of regulated substances under the EU POPs Regulation includes:
- Perfluorooctane sulfonic acid and its derivatives (PFOS) C8F17SO2X (CAS Nos: 1763-23-1, 2795-39-3, 29457-72-5, 29081-56-9, 70225-14-8, 56773-42-3, 251099-16-8, 4151-50-2, 31506-32-8, 1691-99-2, 24448-09-7, 307-35-7 and others)
- Perfluorooctanoic acid (PFOA) including any of its branched isomers, its salts and PFOA-related compounds (CAS No. 335-67-1 and others). PFOA-related compounds which, for the purposes of the Convention, are any substances that degrade to PFOA, including any substances (including salts and polymers) having a linear or branched perfluoroheptyl group with the moiety (C7F15)C as one of the structural elements.
Annex XV PFHxA restriction proposal
In March of 2020, ECHA consultations on the restriction of undecafluorohexanoic acid (PFHxA) have started in the EU (Annex XV reporting format 040615 (europa.eu)). Due to its persistency in the environment, mobility, and long-range transport potential, as stated in the Annex XV restriction proposal, PFHxA shall be restricted in other substances, in mixtures and in articles in a concentration equal to or above 25 ppb for the sum of PFHxA and its salts, or 1,000 ppb for the sum of PFHxA- related substances.
The detailed list of regulated substances includes:
Undecafluorohexanoic acid (PFHxA), its salts and related substances (including polymers):
(a) having a linear or branched perfluoropentyl group with the formula C5F11 directly attached to another carbon atom as one of the structural elements,
(b) having a linear or branched perfluorohexyl group with the formula C6F13.
It is expected that this ban will become effective in 2024.
C4 PFAS
The so-called C4 chemistry, which is manufactured by electrofluorination, is currently not regulated in the EU.
Additional information
The national authorities of five EU countries (Germany, the Netherlands, Norway, Sweden, and Denmark) have agreed to prepare a joint REACH restriction proposal to limit the risks to the environment and human health from the manufacture and use of all per- and polyfluoroalkyl substances. The call for evidence was open until July 2020. Based on the information received through this process, the five countries will prepare a detailed scope of the restriction and analyze the socio-economic impact of different restriction options. The plan is to restrict all PFAS containing CF2/CF3 groups – around 4,700 substances are affected. The restriction could come into force in 2025.
PFAS consumer product regulation in California
In October 2021, a new bill regulating per- and polyfluoroalkyl substances (PFAS) in consumer products came into force. Starting on July 1, 2023, PFAS in juvenile products that are intentionally added or present at or above 100-part-per-million (ppm), as measured in total organic fluorine, are banned and need to be replaced by the least toxic alternative chemicals. Juvenile products, i.e. products designed for use by infants and children under 12 years of age, include crib or toddler mattresses, nursing pillows, bedside sleepers, play mats, and bassinets.
Bluesign’s perspective
Bluesign has always strived for the use of safe chemicals in textiles and accessories production. Poly- and perfluoroalkyl substances have found their spot on our lists of restricted substances a long time ago – the bluesign® system substances list (BSSL) and the bluesign® system black list (BSBL). In the search engine for approved chemistry – the bluesign® FINDER – we offer more than 150 PFAS-free chemical alternatives.
With the prospect of new PFAS being restricted in the short- or mid-term, Bluesign has planned that from July 2023 all PFAS based chemicals will be phased out from the bluesign® FINDER and as of July 2024 all bluesign® APPROVED fabrics that are treated with PFAS formulations will be removed from the bluesign® GUIDE. The phase out strategy is topic of the upcoming Chemical Expert Group meeting (April 2022).
References
1. OECD. 2018. Toward a New Comprehensive Global Database of Per- And Polyfluoroalkyl Substances (PFASs): Summary Report on Updating the OECD 2007 List of Per- and Polyfluoroalkyl Substances (PFASs) ENV/JM/MONO(2018)7. Paris, France: Health and Safety Division Environment. https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/.
2.https://pfas1.itrcweb.org/fact_sheets_page/PFAS_Fact_Sheet_History_and_Use_April2020.pdf (Accessed on 5.01.2022)
