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Five European countries are currently working on a European restriction on per-and polyfluoroalkyl substances (PFAS), aiming to limit the risks these substances pose to people and the environment. A proposal is expected in January 2023 and the possible date of entry into force of this restriction is expected in 2025.
The concept of “essential uses” will likely be included in the REACH restriction process. It is unknown how this will be done in practice and to what extent it will impact the PFAS restriction.
This restriction is not affecting solely the chemical industries but also the entire supply chain, including industry associations, manufacturers, importers, distributors and downstream users.
In addition to pressure from regulators, consumers and NGOs are highly active and demanding transparency.
Both regulatory and societal pressure call for proper risk management that should be part of a company-wide PFAS strategy. The following steps should be considered:
• Know your inventory and supply chain
• Identify products with PFAS (including impurities and production processes) and understand your reporting responsibilities (for example, TSCA reporting)
• Stop using PFAS where possible and find safer alternatives
• Assess safety and how vital the PFAS-containing application is for society
• Complete a Process Audit to determine if you have solid compliance management processes in place to ensure you are not introducing these chemicals to the market
Our 3E Regulatory Consulting Services team can help you identify and address the use of forever chemicals. We can screen your product compositions to ensure products can be manufactured, shipped and sold in intended markets.