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Author's profile photo Michael Mulder

PFAS Bans and Product Compliance


Many parts of life are complicated, there are no “easy answers” or even a single correct answer. The same holds true for fluoropolymers, known as PFAS which are used in the production of so many products from trains to cookware, lubricants, and batteries. The US Environmental Protection Agency has stated that even extremely limited levels of PFAS could be dangerous. The EU wants to ban PFAS from 2027 but this could have an extremely negative effect on our transition to more sustainable everything.

Finding the balance between giving industries time to find alternatives, governments meeting commitments made regarding keeping people safe and their sustainable transition goals and finally running out of time to limit permanent damage to the environment due to climate change. If we peel back the commentary coming from each group a little, we can see that industries do not want to spend the money to research an alternative. Governments do not have the money to give away for the research and are looking for quick wins to use during the next election cycle. Environmental groups lack empathy considering the masses of people an outright ban would affect.

Currently, the European Chemicals Agency (ECHA) is doing viability studies in many EU countries (according to the Financial Times) and the outcome will be something to keep watching. A 2020 publication from the American Chemical Society on policy analysis of fluoropolymers is a great read for more background.

For your company, use of SAP S/4HANA for product compliance can keep you up to date on product marketability, (including polymers like PFAS) and dangerous goods, making sure your products are produced, stored, labeled, transported, and sold; safely and legally. Changes are coming, by using product compliance, with our regulatory content service, you can focus on your business, and we can help you be more efficient and remain compliant.

No straightforward way to address the issue:

  1. Climate change is a factor. Even though there may not be a one-to-one relationship here, any rash changes enforced by governments or regulatory bodies could harm businesses, consumer end products, and the environment. Removing a widely used chemical could create inflation, meaning businesses and consumers buy alternatives from other countries, resulting more emissions from transporting products.
  2. Creating an alternative to PFAS. Under normal circumstances this could take years of research for companies from different industries which works the same or better. That is time we really don’t have.

In a perfect world, we could produce a new, more sustainable, and safer alternative to PFAS. Thereby improving brand names, company reputations, consumer safety and meet sustainability goals; who thinks this is what will happen? The irony here is that if we come together as companies, governments, consumer and environmental groups, positive outcomes become achievable for all! Personally, we need increased collaboration, cooperation, and unity in the face of such difficult problems.

Let me know what you think, leave a comment below, I would be interested in your perspective.

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      Author's profile photo Mark Pfister
      Mark Pfister

      Hi Michael ,

      Thank you for sharing your insights on the PFAS topic. There are indeed numerous challenges involved, and implementing a ban on PFAS will undoubtedly cause heavy disruptions!

      Different countries hold varying perspectives on which PFAS substances should be restricted and what is a PFAS. In the United States, even individual states develop their own regulations on the matter. Therefore, restrictions on specific substances may vary depending on the location of manufacturing or intended product sales.

      From a regulatory affairs standpoint, a major hurdle lies in determining whether the raw materials (mixtures or parts) being purchased contain PFAS. With over 12,000 PFAS, most of which are currently unregulated, there is no legal obligation to disclose their presence along the supply chain.

      Consequently, companies must invest in establishing transparency within their supply chain regarding PFAS. While IT tools such as opesus Product Compliance Collaboration can significantly contribute to automated data collection on purchased goods, this alone is not sufficient. Companies must ensure that their suppliers understand the importance of sharing information on substances that will soon face heavy regulation and understand that this is in the best interest of both parties. In a second step, supplier contracts should be designed in a way that mandates the sharing of this information.

      Addressing the challenges of PFAS regulation necessitates taking proactive steps, particularly in the area of information collection. Companies should invest in robust IT tools to efficiently manage the collection and organization of data. Additionally, fostering collaboration with suppliers becomes paramount, ensuring their understanding of the importance of sharing information on impending heavily regulated substances. By prioritizing comprehensive information collection and collaboration, businesses can navigate the challenges of PFAS regulations and pave the way for a safer and compliant future.



      Author's profile photo Michael Mulder
      Michael Mulder
      Blog Post Author

      Thanks Mark, the issue with suppliers is something that I haven't considered enough. I love the raw material angle, that is so complex and creating regulations is going to be messy.