European HVAC&R stakeholders have until October 17 to respond to a survey prepared by five countries – Germany, the Netherlands, Norway, Sweden and Denmark – in regard to per- and polyfluorinated alkyl substances (PFAS), including some HFC and HFO refrigerants.

The five countries announced on July 15 their intention to submit a joint proposal to restrict PFAS to the European Chemicals Agency (ECHA) under the REACH regulation by July 2022.

The REACH authorities for of the Netherlands, Germany, Denmark, Sweden and Norway are preparing a “REACH Annex XV Restriction Dossier” for this group of PFAS.

The original deadline for responding to the “stakeholder consultation” survey, September 19, was extended to October 17. The survey can be accessed here.  

This survey is intended to provide respondents with “the current overview the five authorities have on the different uses of PFAS,” says an introduction to the survey. “By checking the presented data and providing feedback you/the respondents can ensure that the correct information is used for the assessment and preparation of a REACH Annex XV Restriction Dossier.” 

The respondents can also provide the countries’ REACH authorities with information that is “still lacking.”

Following submission next year, the restriction proposal would then be subject to “adoption of the final opinions” by ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC), before it would be adopted by the European Commission (EC).

‘Forever chemicals’

PFAS, which represent a group of over 4,700 highly durable “forever chemicals” ­are used to produce many consumer products, but exposure to PFAS can be harmful to human health. PFAS include perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), which have already been limited and banned, respectively, in the EU.

As defined by the five countries, PFAS cover a number of f-gases, including certain HFCs and HFOs that are used in HVAC&R applications. Among the HFCs that the countries identified as being PFAS are: R32, R134a, R125, R143a and R152a. Some of the HFOs include R1234yf, R1234ze(E) and R1233zd(E). These HFCs and HFOs fall under the scope of PFAS as defined by the countries, which is that a substance contain at least one CF2 (perfluorinated methylene group) or one CF3 (perfluorinated methyl group) in its molecular structure.

In addition, trifluoroacetic acid (TFA), which is a PFAS, is an atmospheric degradation product of HFO-1234yf and HFC-134a.

The f-gas industry in Europe has pushed back against the classification of HFCs and HFOs as PFAS. “HFCs, HFOs and HCFOs are a distinct subset and due to their properties are not commonly regarded as PFAS,” says the European Fluorocarbons Technical Committee (EFCTC) on its website.

The REACH regulation governs the registration, evaluation, authorization and restriction of chemical substances in the EU. HFCs are separately regulated by the EU F-Gas Regulation, though HFOs are not.


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