Proposal for regulation of PFAS and TFA

In July 2021, a "Registration of Intent" (RoI) for the EU Chemicals Regulation 1907/2006 REACH was filed. This RoI will be followed by a Dossier, a report documenting the harms of the chemicals targeted, on many fluorinated hydrocarbons. The Dossier shall be delivered in January 2023. After publication of the Dossier, persons, companies and associations have some months time to deliver their statements. Possible rules and regulations in REACH could become valid from 2025.

The RoI was delivered by 5 national European chemical agencies. In the definition it includes all substances with fully fluorinated carbon groups, meaning middle groups CF2 and end groups CF3. In total it is about 4000 .. 10000 chemicals.

These chemicals are either persistent in nature themselves, meaning very durable, or their breakdown products are persistent in nature. One of the breakdown products of many refrigerants is trifluoro acid or trifluoro acetic acid (TFA). This substance is washed out of the atmosphere by rain if it is formed from gases at relevant altitudes. It is very stable in the environment and can influence metabolic processes in organisms.

For refrigeration, use bans for the mentioned chemicals can create difficulties in several areas:

Listing these chemicals as substances of high concern in REACH can lead to ban of many uses, and even to significant limitations for applications or to high handling safety measures and qualification demands for the users. As the main target, the writers of the RoI name bans.

The additional regulation of refrigerants under REACH can limit the possibilities of the refrigeration industry to fulfil the demands of the F-Gas Regulation significantly.

Sources:

Substance Information - ECHA (europa.eu)

Registry of restriction intentions until outcome - ECHA (europa.eu)