Supervising PFAS-impact on producers
The commonly used term PFAS is an abbreviation for perfluorinated and polyfluoroalkyl substances, and is an important topic of conversation, especially for manufacturers. Since the 1930s, this family of more than 4,700 chemicals has contaminated drinking water and polluted the environment, which has attracted the attention of North American and European authorities. With the increase in PFAS regulations, various industries have been affected. This is true for manufacturers of electronic and electrical equipment (EEE) that take advantage of its important chemical properties: oil and water repellency; heat and chemical resistance; and surface tension reduction.
Knowing the current and upcoming regulations regarding your product and PFAS is the first step in compliance. The following are important regulations for the three major markets.
In April 2021, the Ministry of the Environment and the Ministry of Health issued a notice of intent under the Canadian Environmental Protection Act of 1999 to address PFAS as a whole.
In the United States, the Environmental Protection Agency (EPA) has implemented the Toxic Substances Control Act (TSCA) to regulate chemicals on the US market. As of 2020, TSCA requires the following:
For more detailed information, please refer to the Compliance Guide for Imported Articles Containing Surface Coatings[Jan. 2021]
In addition, as of October 2021, EPA has published a PFAS strategic roadmap, detailing their commitment to 2021-2024. Among the main targets set, EEE will become a priority industry in the upcoming PFAS Action Act of 2021 (HR 2467).
As you can see, the PFAS strategic roadmap was only released a few weeks ago. As a manufacturer, it is very important to continuously monitor changes in regulations to maintain compliance.
According to the International Stockholm Convention, the European Union (EU) Persistent Organic Pollutants (POP) regulations restrict perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), two important PFAS chemicals.
The European Chemicals Agency (ECHA) tracks certain PFAS substances in accordance with the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations. For example, manufacturers must declare perfluorobutane sulfonic acid (PFBS), its salts, and PFOA that are listed as substances of very high concern (SVHC).
Finally, starting from February 2023, C9-C14 PFCA and similar PFAS are restricted for use in EU and EEA countries/regions under REACH Annex XVII restrictions.
Step 2: Risk assessment of parts
Monitoring regulations is an important step, but only if you know what the product’s components contain. Conduct internal risk assessment on components that may contain PFAS. A detailed list of the components you have purchased and their components will help monitor your compliance as regulations change.
Step 3: Inform your supply chain
Clarify your expectations throughout the supply chain. In order for the parts you buy to comply with PFAS standards—whether regional, domestic or international—your suppliers need to understand your intentions. In fact, not all suppliers have inventory of all high-risk parts, so you need your attention.
These steps are critical, but not always easy to manage. To ensure that all regulations are met and all components are considered, laboratories and consulting companies can help you streamline the process.
The PFAS molecule contains a chain of carbon atoms and fluorine atoms. The chemical bond between carbon and fluorine is one of the strongest natural bonds. Because the carbon-fluorine bonds are strong and long-lasting, these chemicals will not decompose when they are inevitably released into the environment. This chemical bond that makes PFAS dangerous to the environment is an important quality of circuits and electronic products. Manufacturers will need to monitor their products and take action in accordance with the new regulations.
The three notorious PFASs are polytetrafluoroethylene (PTFE under the Teflon trademark), PFOA and PFOS. These are the first to be mass-produced and can be found widely in the environment. Due to the impact on human health and the environment, they are no longer produced in Canada or the United States and have been eliminated. These derivatives such as GenX have been used as substitutes. However, they are still equally dangerous and worrying.
PFAS is released through the manufacturing process and the disposal of by-products. Once released, PFAS can easily enter the environment; they can be found far away from the place of origin, penetrate the food chain and contaminate drinking water sources. Because of their persistence, these eternal chemicals will stay in the environment and accumulate as more releases are made. Since we cannot get rid of them, their concentration is increasing, and humans may ingest and inhale excessive amounts of substances. In fact, humans ingest them, but don't excrete them so quickly. Therefore, the PFAS family is bioaccumulative.
But you may not know... However, their effects above certain concentrations may include:
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