Bathroom Manufacturers Association                            PFAS0028

Written evidence submitted by the Bathroom Manufacturers Association

Bathroom Manufacturers Association (BMA) Response to the PFAS Restriction Proposal

The Bathroom Manufacturers Association (BMA) represents suppliers of bathroom fixtures and fittings in the UK. Although we are a small organization (SME), our membership includes 91 companies—from sole traders to large multinational corporations—who are responsible for approximately 75% of the core bathroom products sold in the UK by value. The combined annual sales of our members total around £1.6 billion. This consultation response has been developed with input from both technical and commercial experts within our membership.

BMA acknowledges the public and political concerns surrounding per- and polyfluoroalkyl substances (PFAS) and appreciates the opportunity to contribute to the Environmental Audit Committee’s consultation on proposed restrictions.

We emphasize that some PFAS materials, particularly fluoropolymers, are not easily replaceable. These substances offer a unique combination of durability, chemical resistance, mechanical strength, and thermal stability that is critical to a wide range of applications, including those in our industry.

In sanitary products, PFAS fluoropolymers such as PTFE® are primarily used in sealants (O-rings) and high-performance lubricants and greases for fittings. While alternatives exist for basic sealing applications under standard operating conditions, no viable substitutes have yet been identified for use in aggressive media, high temperatures, or steam systems. In such cases, substitution would compromise performance, reliability, and safety.

Our members have provided specific examples highlighting the necessity of fluoropolymers. One manufacturer reports that PFAS materials account for less than 5% of product weight but are essential in 95% of their equipment. Valves and taps are required to withstand up to 200,000 load cycles—the equivalent of a 20-year lifespan. This performance is currently achievable only with fluoropolymer-based greases and sealants. Despite over two years of testing, alternative materials have failed to meet these durability requirements.

PFAS-containing polymers and elastomers are also critical in applications involving aggressive chemicals and high heat. Unlike standard polymers, PFAS materials retain elasticity and sealing performance where others quickly degrade. For instance, non-PFAS materials such as high-density polyethylene are ineffective above 100°C or in contact with hydrocarbon fluids, making them unsuitable for steam or fuel systems.

BMA supports a proportionate, risk-based approach to PFAS regulation. We urge regulators to recognize the distinct characteristics and low-risk profile of fluoropolymers compared to other PFAS. Fluoropolymers are non-toxic, non-bioavailable, insoluble in water, immobile in the environment, and do not bioaccumulate. Grouping all PFAS substances under a single regulatory category overlooks these important distinctions.

We advocate for:

• Clear differentiation between PFAS types based on intrinsic properties, toxicological profiles, and essential uses.
• Exemptions and extended transition periods where substitution is not currently feasible.
• Continued support for innovation while maintaining product safety and performance.
• Effective market surveillance to ensure compliance and maintain fair competition.

We also endorse the European Sealing Association’s position paper on PFAS regulation, which provides valuable technical insight into sealing applications. The document is available at: ESA PFAS Position Paper.

In summary, we urge decision-makers to adopt a pragmatic and evidence-based approach that balances environmental concerns with the critical performance requirements of essential sanitary products.

May 2025