Q.1

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

AMDEA understands that the EAC is adhering to the PFAS definition detailed in Appendix 1 of the Chief Scientist’s Group Report on PFAS published by the Environment Agency in August 2021. In this, PFAS are defined as a large group of synthetic organofluorine chemicals that contain at least one fully fluorinated methyl (–CF₃) or methylene (–CF₂–) group 1. This broad definition encompasses both non-polymeric and polymeric PFAS with fluoropolymers specifically mentioned as a type of polymeric PFAS.

In terms of benefits, polymeric PFAS – specifically fluoropolymers – offer unique properties, including:

• Chemical, biological, and thermal stability: fluoropolymers are resistant to heat, chemicals, and biological degradation.
• Heat and chemical resistance: they can withstand high temperatures and harsh chemicals.
• Unique dielectric properties: fluoropolymers have excellent insulating properties, making them ideal for electronic applications.
• Fire resistance: they are non-flammable and can help in fire prevention.
• Weather resistance: fluoropolymers are durable and can resist various weather conditions.
• Non-wetting and non-stick properties: these properties make them useful in coatings and surface treatments.
• Durability: fluoropolymers are long-lasting, which enhances the lifespan of products they are used in.

With regards to usage, AMDEA represents manufacturers of domestic appliances so offers a response that is specific to this sector. PFAS usage (which is principally of fluoropolymers) within the sector spans:

1. Electronics:

-          Semiconductors, wires, and cables: fluoropolymers are used for insulation and protection.

-          Flexible printed circuit boards: they provide stability and durability.

2. Lubricants:

-          Compressor oils and ball bearings: fluoropolymer-based lubricants are used for their stability and resistance to wear.

3. Anti-drip and anti-stick coatings:

-          Non-stick cookware: fluoropolymers are used in coatings for their non-stick properties.

-          Sliding discs of cookware: they ensure smooth operation and longevity.

4. Air conditioners and heat pumps:

-          Refrigeration appliances: fluoropolymers are used in components like seals and gaskets to prevent leaks and ensure efficient operation.

5. Other applications:

-          Food contact materials: fluoropolymers are used to prevent sticking and contamination.

-          Filters and valves: fluoropolymers are used in filters for their ability to capture ultra-small particles and in valves for their chemical resistance.

-          Door hinges and sealings: they provide durability and resistance to wear.

Q.4

How sophisticated is current knowledge of how and where PFAS enter the supply chain?

Current knowledge is well-developed but not fully comprehensive. With respect to the domestic appliance industry, the complexity of global supply chains makes it difficult to accurately trace fluoropolymer usage. Product parts and materials are sourced from multiple suppliers, often across different regions of the world. Nevertheless, many domestic appliance manufacturers have built upon existing supply chain mapping/management exercises (e.g., for the purposes of managing compliance with RoHS, REACH and other chemicals laws) to identify where fluoropolymers are used. Such exercises typically involve assessing parts and materials as well as the likely polymeric PFAS (specifically fluoropolymer) content of finished products. Manufacturers have also invested in substance-level data collection to assess fluoropolymer risks and prevent disruptions.

In terms of how and where fluoropolymers enter the supply chains of domestic appliances, this spans:

1. Raw materials:

-          Fluoropolymers are introduced at the raw material stage, particularly in the form of PTFE, PVDF, FEP, FKM, and PFA.

2. Manufacturing processes:

-          Fluoropolymers are used in the manufacturing of electronic components, lubricants, anti-dripping agents, and non-stick coatings.

-          They are also present in fluorinated greenhouse gases used in air conditioners and heat pumps.

3. Product parts and materials:

-          Fluoropolymers are found in semiconductors, wires, cables, flexible printed circuit boards, compressor oils, ball bearings, door hinges, and sealings.

-          They are used in filters, valves, and other components that require chemical resistance and durability.

Q.5

What is the current understanding of how PFAS are made and then used in terms of product ranges, and geographical and socioeconomic distribution?

As AMDEA understands it, PFAS are manufactured through two primary processes:

1. Electrochemical fluorination (ECF): this process involves the electrochemical reaction of hydrocarbons with hydrogen fluoride, producing a mixture of linear and branched PFAS compounds.
2. Fluorotelomerisation: this process involves the reaction of telomer alcohols with perfluoroalkyl iodides, producing linear PFAS compounds.

In terms of product range usage, AMDEA has already commented upon this with regards to domestic appliances. Other product ranges do make use of polymeric PFAS too, of course – and specifically fluoropolymers. Among these are other types of electrical and electronic equipment (e.g., IT and telecommunications equipment, monitoring and control equipment), firefighting foams, textiles, medical devices, and vehicles.

Concerning geographical distribution, data[1] from the Chicago Council on Global Affairs and ChemSec identify the USA, China, Japan and Germany as the countries in which polymeric PFAS are manufactured in the largest quantities, with these countries hosting the major chemical companies (e.g., 3M, BASF, Bayer, Chemours, Daikin, Honeywell) that produce polymeric PFAS for assorted industrial applications. Meanwhile, usage is assumed to be global, not least because of the many applications/products in which fluoropolymers are found. In absolute terms, usage will likely be higher in certain industrialised nations (e.g., the USA, China) when consideration is given to the country’s industrial base, population size and affluence. It is difficult to comment upon socioeconomic distribution; AMDEA would suggest research is needed into this.

Q.9

Is the current regulatory regime for the use and disposal of PFAS, including UK registration, evaluation, authorisation and restriction of chemicals (UK REACH), adequate? If not, how can it be improved?

That EU REACH is implemented in Northern Ireland and UK REACH is implemented in Great Britain makes for fragmented regulation. In turn, this creates uncertainty that affected businesses (suppliers of ‘articles’ in the case of domestic appliance manufacturers and importers) need to anticipate and navigate. In terms of improvement, it would be helpful if the UK Government communicated more, and more regularly, on its thinking and policy intentions. For industry, learning of intent and anticipating change in good time is important, as is the ability to engage with Government early on when it comes to potential changes in regulation.

Q. 10

Is a precautionary approach to PFAS desirable or is an approach that uses regulation to assess their benefits and risks more appropriate?

A regulatory approach that assesses the benefits and risks of PFAS is appropriate and AMDEA’s preferred approach.

To put this in perspective, please consider the possibility of fluoropolymers being subject to a future EU-wide universal PFAS restriction. Taking a precautionary approach would see such a restriction enacted, but it would fail to distinguish fluoropolymers as distinctly different substances from other polymeric and non-polymeric PFAS, also to account for the benefits that fluoropolymers provide.

In the case of domestic appliances, the industry makes use of certain fluoropolymers, most of which – PTFE, PVDF, FEP, FKM, PFA – are found in a wide range of products (refrigeration appliances, air conditioners, washing and/or drying appliances, cleaning appliances, cooking appliances) and components (electrical, lubricants, plastic and/or rubber materials, non-stick coatings). In addition, applications with temperature resistant, chemical resistant, sealing – or non-stick – properties are used in various steps during the manufacturing process of domestic appliances.

The industry makes use of fluoropolymers for their unique properties, with drop-in

alternatives difficult to find. Alternatives would necessarily require development and testing, which would consume both time and resources. Importantly, the substitution of fluoropolymers must not lead to any reduction of product usability and lifespan; to do so would risk working against the sustainability of the industry and the UK Government’s plans to transition to a circular economy. Not only this, if the deployment of the alternative requires product redesign/reformulation, the process of development and full deployment would require multiple steps being taken (steps outlined in the diagram below) the completion of which normally amounts to years.

Unlike other polymeric and non-polymeric PFAS, fluoropolymers:

• Have negligible residual monomer and oligomer content and low to negligible leachability.[2]
• Have very high molecular weights with little or no long-range transport potential. Based on current information, fluoropolymer molecules are believed to be too large to cross cell membranes. As such, they are believed to pose less risk to

human health and the environment relative to non-polymer PFAS.[3]

• Are considered to be non-mobile in the environment, non-bioaccumulative and unable to bioconcentrate.[4]
• Have been shown, at least by certain studies[5], either to exhibit low toxicity or be non-toxic.
• Exhibit chemical, thermal and biological stability such that they are not expected to transform to dispersive non-polymeric PFAS when disposed of in landfill sites.

With the above in mind, the domestic appliance industry is of the mind that fluoropolymers should be treated differently from other PFAS due to their distinct properties and lower risk profile. It is a position that was put to the European Chemicals Agency by APPLiA Europe[6] when stakeholder comments were being taken on the EU REACH Annex XV restriction report.[7] In the context of the question posed by the EAC, AMDEA feels it serves to illustrate why assessing the benefits and risks of PFAS – and more specifically fluoropolymers – is appropriate with regards to the regulatory approach.

Q.11

Is there any regulatory divergence across the UK in terms of PFAS? If so, what are the implications, and is there a need for a more joined-up approach?

There is divergence in that, in Great Britain, it is UK REACH that is implemented and, in Northern Ireland (NI), EU REACH. Differences exist between these two regulatory regimes. One of the implications of this divergence is that, for businesses that operate across the UK, it presents a need to navigate different regimes, increasing compliance complexity and cost. Market fragmentation might arise too, whereby products compliant in one region may not be compliant in another, affecting intra-UK trade and market access. In terms of approach, it would be helpful if the UK Government could raise, discuss and arrange for the Health and Safety Executive (HSE) to once again be a CARACAL[8] member with the European Commission. The HSE could potentially be re-introduced to CARACAL as an ‘other public entity (Type E)’ organisation, with its place justified on the grounds that NI implements EU REACH while CARACAL participation would also lend itself to increasing UK-EU cooperation on law enforcement – one of the topics upon which agreement was struck at the recent, May 2025 UK-EU Summit. In CARACAL, the HSE could give voice to some of its thinking on PFAS, including but not limited to the suitability of certain definitions and what resulted from its PFAS regulatory management options analysis.

Q.12

How do other jurisdictions around the world, including the EU and US, regulate PFAS use and disposal, and what lessons, if any, can the UK learn?

Focusing on the EU, the EAC is likely well-aware of the proposed universal PFAS restriction that is currently under evaluation. In addition to this, it is worth noting that PFOS and its derivatives have been restricted under the EU Persistent Organic Pollutants Regulation for over a decade, similarly that the EU Drinking Water Directive specifies limits for 20 individual PFAS at 0.1 µg/L, effective from 2026. There are also sector-specific restrictions in place, as have been implemented for firefighting foams and food contact materials.

In terms of lessons to learn, giving adequate time to stakeholders to compile data and respond to consultations that address potentially sweeping regulatory changes is important, likewise maintaining engagement with stakeholders and involving them in assessments of risks and socio-economic impacts.

It is important to note that emissions of fluoropolymers can be effectively controlled across their entire life cycle. This begins with the use of raw materials containing extremely low levels of non-polymeric PFAS, typically below 1 ppm. During manufacturing, advanced recovery and abatement technologies are applied to significantly reduce residual non-polymeric PFAS, particularly those originating from polymerisation aids. These efforts are reinforced by robust safety and environmental management practices during downstream processing and application stages, ensuring that emissions from fluoropolymer-containing materials are carefully minimised. This comprehensive approach reflects the European fluoropolymer industry’s commitment to achieving average emission factors of non-polymeric PFAS residues from polymerisation aid technology of 0.003% to air and 0.0006% to water by 2030.[9]

Likewise, viable technologies already exist for the responsible treatment of end-of-life fluoropolymers. In alignment with circular economy principles, extended producer responsibility (EPR) schemes may support the large-scale collection, recycling, and environmentally sound disposal of fluoropolymer-containing products. Such initiatives would address the dual objective of advancing sustainable manufacturing in the UK and ensuring the safe management of fluoropolymers throughout their life cycle. Recent progress includes the deployment of specialised treatment technologies that prevent emissions of short-chain polymeric PFAS during recycling, enabling the controlled and environmentally responsible waste treatment of substances such as PTFE.