IPC Responds to European Chemicals Agency for a Proposed Universal Ban on PFAS

By Suhani Chitalia, manager, IPC environmental regulatory affairs

IPC is advocating for a 13.5-year minimum transition period to the European Chemical Agency’s (ECHA) proposed restriction on all per- and polyfluoroalkyl substances (PFAS). The ECHA proposal was put forward by five Member States in the European Union (EU) and would ban manufacture, market placement, and use of all PFAS.  

The response was supported by an IPC-established Tiger Team, consisting of policy, industry, and technical experts. In preparation for IPC’s response, the Tiger Team evaluated multiple data sources, including submitted responses, a PFAS Uses Data Sheet, and the IPC PFAS Uses Survey, to understand where and how PFAS are potentially used in the electronics manufacturing supply chain. Through this exploration, the need for time to understand and identify PFAS across a complex, multi-tiered, and globally diverse supply chain, became apparent.

As written, the proposal does not allow a feasible transition period to identify, investigate, and develop alternatives to essential PFAS uses or potential uses in electronics.  IPC emphasizes that the current transition period undermines the time necessary to undergo a thorough, comprehensive alternatives assessment to ensure the availability of safer options and prevent regrettable substitution. The “cascading” impacts that a ban of this magnitude can have touches not only the electronics sector but all of society. Recognizing the irreplaceable utility provided by PFAS-containing and potential PFAS-containing electronics in facilitating the EU's digital and green transitions, the response emphasizes that a ban can undermine existing EU policy. The ban, ultimately, required more time by industry to determine and identify PFAS and then understand whether feasible alternatives exist.

The submission highlights the following in its response:  

• A responsible industry response to a universal PFAS restriction will require more time; a derogation for the 18-month transition period plus a minimum of 12 years is needed to effectively minimize impacts to the users of electronics
• The complex electronics supply chain creates challenges in reliably identifying the presence of PFAS
• The proposed restriction does not fully consider the cascade of utility PFAS provides in the complex electronics supply chain
• PFAS are used in electronics manufacturing processes and products, but the extent of these uses remains unknown and therefore a restriction of PFAS will lead to unintended impacts
• Sufficient time to enable alternatives assessment is crucial to ensure safer options and avoid regrettable substitution for all uses
• PFAS-containing and potential PFAS-containing electronics provide irreplaceable utility and enable the EU’s digital and green transitions
• Insufficient transition times for electronics can have dire consequences and undermine the ongoing EU’s sustainability goals

As the global conversation surrounding PFAS intensifies, IPC remains committed to both environmental responsibility and industry innovation. IPC’s submission underscores its dedication to collaborative and science-based approaches, seeking to strike a balance between safeguarding the environment and ensuring the continued availability of essential electronic components and applications.

For more information on PFAS and IPC’s response to ECHA, contact Kelly Scanlon.