GAMBICA                            PFAS0026

GAMBICA Response to the Government Consultation on PFAS

About GAMBICA
GAMBICA is the UK’s trade association for companies in the industrial automation, test and measurement, laboratory technology, and process instrumentation sectors. Our members develop and supply essential technologies for scientific research, pharmaceuticals, advanced manufacturing, healthcare, and environmental monitoring.

Many of the sectors supported by our members are critically dependent on Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS). Without continued access to certain classes of PFAS, these industries—and the public benefits they provide—would face serious disruption.

What benefits do PFAS provide, and how widely are they used?

PFAS materials offer unique chemical, thermal, and mechanical properties that are not replicated by any known alternatives. These properties are critical for equipment and processes that underpin scientific research, healthcare, pharmaceuticals, electronics manufacturing, and environmental monitoring. In many cases, PFAS have replaced more hazardous substances and enabled innovation in safety, energy efficiency, and functionality.

Examples of essential PFAS uses among GAMBICA members include:

• Filtration systems: PFAS (especially PTFE) are essential in low-air and liquid filters used to remove viable organisms (bacteria, viruses, endotoxins) during medicine preparation. HEPA filters incorporating PFAS allow high airflow with low energy use—reducing carbon emissions while maintaining sterile environments.
• Tubing and chemical resistance: Laboratory instruments require tubing that can withstand highly aggressive chemicals, elevated temperatures, and physical wear. PTFE and PFA are unmatched in these conditions.
• Chemical bottle vents: PFAS materials are used in vents for chemical bottles, which must safely release gases to prevent pressurisation and potential explosions during transport and storage.
• Electronics manufacturing: PTFE components are widely used in semiconductor processing, wafer fabrication, and lithography due to their chemical inertness and ability to withstand corrosive environments.
• Analytical and laboratory equipment: High-performance liquid chromatography (HPLC, UHPLC) systems depend on PTFE/PFA frit adapters, tubing, degasser membranes, and filter assemblies to function reliably. Substituting these materials is currently not possible without compromising performance or safety.
• Vacuum technology and microscopy: Scanning electron microscopes, turbo molecular pumps, and other high-end equipment require PFAS for their low outgassing, UV resistance, chemical inertness, and long-term stability.
• Lubricants and self-lubricating surfaces: PFAS-based lubricants (e.g., Krytox™, Fomblin™) provide the low outgassing and high stability required in high-vacuum environments.
• Nanoscience equipment: PTFE coatings are critical in atomic force microscopes, nanoscience equipment, and high-voltage applications (e.g., magnet wire insulation for up to 10,000 volts).
• Component longevity and maintenance: Many laboratory and industrial systems have long lifespans, and continued access to PFAS-based spare parts is vital for their upkeep. Without these, critical infrastructure would be scrapped prematurely, resulting in significant cost and environmental waste.

Disposal and environmental controls
PFAS used in industrial and laboratory technologies are typically contained within durable, enclosed systems. At end-of-life, these products are processed under the WEEE Directive, where PFAS components are incinerated. Due to strict waste disposal protocols and high material value (e.g., metals), environmental exposure is minimal to non-existent.

To what extent are UK health and environmental regulators equipped to detect, monitor, and understand the risks posed by PFAS?

UK laboratories are well-equipped to detect and monitor PFAS in the environment and food chain. However, monitoring and risk assessment would not be possible without access to some PFAS compounds for calibration and detection reference standards.

How developed is the UK’s research base on PFAS and their impact?

UK research institutions are actively monitoring PFAS and evaluating their environmental and health impacts. However, for many specialist applications, PFAS-free alternatives are not under development or are estimated to be more than a decade away from viable deployment and validation.

Is the current regulatory regime under UK REACH adequate?

We support the current risk-based approach under UK REACH, which enables nuanced decision-making based on specific use-cases, rather than blanket bans. This approach ensures that essential uses of PFAS can continue while environmental and health concerns are responsibly managed.

Should a precautionary approach be taken, or is a risk-benefit assessment more appropriate?

A precautionary approach—especially if applied broadly—risks causing disproportionate economic and societal harm by eliminating substances for which no alternatives exist and where exposure is minimal. We strongly advocate for a balanced, evidence-led approach that assesses both risks and benefits. Many PFAS used in our members’ industries are not known to pose significant environmental or health risks when properly managed.

What can the UK learn from PFAS regulations in other jurisdictions?

The EU’s current proposal for a blanket PFAS ban has triggered widespread concern. Over 5,600 applications for derogations and exemptions have been submitted, reflecting the broad reliance on PFAS across industries.

If adopted without adjustment, the EU’s proposal could halt pharmaceutical and biopharma production across Europe—jeopardising access to over 1,900 drug products, including more than 600 on the WHO’s “Critical Medicines List.” Similar disruptions are expected in electronics, fine chemicals, and advanced manufacturing.

We urge the UK to take a more pragmatic approach: one that recognises the diversity of PFAS, distinguishes between substances of concern and those used safely in enclosed systems, and prioritises evidence over ideology.

Conclusion

The UK must avoid unintended consequences that could arise from overly broad restrictions on PFAS. We support a risk-based framework that protects human health and the environment while preserving the UK’s capacity for innovation, manufacturing, and scientific research.

We would welcome the opportunity to support policymakers further by sharing industry case studies and technical insights into PFAS applications and alternatives.

May 2025