AGC Chemicals Europe, Ltd.                            PFAS0059

AGCCE response to inquiry: Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

Introduction

1. AGC Chemicals Europe, Ltd (AGCCE) values the opportunity to submit comments to this inquiry.  As a member of the Chemical Industries Association (CIA), Japanese Business of Council Europe (JBCE) and Fluoropolymers Product Group (FPG) of PlasticsEurope, AGCCE supports comments those organisations have submitted.

2.     AGCCE is the European subsidiary of AGC Inc., whose HQ is in Japan.

3. PFAS are divided into non-polymeric PFAS (perfluoroalkyl and polyfluoroalkyl substances), and the polymeric PFAS (fluoropolymers, perfluoropolyethers, and side-chain fluorinated polymers)[1],[2].

AGCCE’s UK site manufactures fluoropolymers, PTFE and ETFE, a class of high-performance synthetic resins.

Within AGCCE’s manufacturing processes, a limited number of non-polymeric PFAS are used to ensure the quality and performance of our final fluoropolymer products, as these create unique properties which cannot be replicated by other compounds. AGCCE also imports other high performance fluoroproducts to the UK for end use in various industries[3].

4. Not all PFAS have identical hazards and risk profiles and shouldn’t be treated as a single group. When assessing potential risks, toxicity, bioaccumulation, toxicokinetic, and exposure profiles should be considered. These characteristics vary among different PFAS substances. AGCCE encourages regulatory action proportionate to the risk.

5. Although fluoropolymers fit the PFAS structural definition, they are fundamentally different and should not be grouped together with other PFAS, which may be of concern since sources demonstrate that fluoropolymers have a low hazard profile, are non-toxic, not-bioavailable, non-water soluble, non-mobile, do not bioaccumulate, and have not demonstrated negative human health impacts [4],[5],[6],[7]. Moreover, the UK Environment Agency (EA), and Health and Safety Executive (HSE) acknowledged their low hazard in PFAS RMOA stating that restrictions need not apply to this group[8].

6. AGCCE is committed to responsible manufacturing principles, continuous improvement of the best available techniques in our manufacturing process, limiting environmental emissions where feasible, and conducting R&D to advance our technologies. As a member of the FPG, AGCCE has adopted the following commitments outlined in the FPG Manufacturing Programme[9]:

a)     A voluntary commitment to reducing non-polymeric PFAS emissions;

b)     Participating in a platform promoting the adoption of commercially available state of the art technologies to minimise non-polymeric PFAS emissions in its manufacturing;

c)     A commitment to inform downstream users of fluoropolymers on their safe handling and use.

7. Fluoropolymers provide unique combinations of properties. They are used in a variety of applications where the highest technical, safety and performance requirements are vital. In most cases these cannot be achieved by alternatives.

8. Fluoropolymers have a high societal value: they are the cornerstone of the green and digital transition, and UK’s strategic autonomy in a wide array of industrial sectors, e.g. hydrogen, batteries. A blanket regulation of fluoropolymers would have a serious socio-economic impact, undermining UK competitiveness.

9. AGCCE takes its responsibilities towards people and the environment extremely seriously and welcomes the facilitation of a constructive discussion that would promote better understanding of PFAS, their uses, and finding solutions for improved monitoring and optimum disposal process.

Question 1.

10. PFAS is a large class of over 10,000 chemicals representing substances with very different properties2,[10], including liquids, gases, solids, polymers and non-polymers, non-toxic and (eco) toxic, mobile and insoluble, inert or reactive substances. The term PFAS doesn’t inform whether a substance poses risk1.

11. While fluoropolymers meet PFAS definition their unique structure and properties mean they don’t share the risk profiles of other PFAS e.g. PFOA.

Fluoropolymers demonstrate benign profile. They are non-toxic, non-bioaccumulative, have high molecular weight which limits mobility and bioavailability, have high stability and resistance to environmental degradation. Fluoropolymers don’t degrade into mobile or toxic substances. These minimize any potential for environmental or human health impacts4,5.

12. The C−F bond strength in fluoropolymers imparts exceptional properties: chemical, thermal (-200 to +260 oC), photochemical, oxidative, hydrolytic and biological stability. Fluoropolymers display low surface-energy and non-stick behaviour, electrical insulation and mechanical durability. In combination these properties result in extension of product life, reducing maintenance and failures.

13. Alternatives may match some fluoropolymers’ characteristics. Fluoropolymers are expensive, and alternatives have already been implemented when viable.

14. Fluoropolymers are central to achieving the UN Sustainable Development Goals, Net Zero targets and decarbonisation as they are used in renewable energies and energy storage systems: wind turbines, solar panels, green hydrogen production, batteries and fuel cells.

Other critical uses include[11],[12],[13],[14],[15]:

• Chlorine manufacture for drinking water. Fluoropolymer ion-exchange membrane technology replaced asbestos/mercury process in chlor-alkali manufacturing. It is safer, more energy efficient and results in better product quality. Society relies on chloro-alkali manufacture for cleaning products, pharmaceuticals, polymers.
• Electronics e.g. semiconductor production infrastructure, batteries and components.
• Automotive, aerospace and maritime e.g. safe fluid handling, electrical systems, mould release films, fuel cells in E-mobility. Key safety equipment in harsh environments is often heavily regulated - replacements will take time to approve.
• Architecture e.g. Eden project, O2 Arena, Manchester Victoria Station Roof.
• Medical applications e.g. catheters, hernia meshes, medical imaging and analysis.
• Infrastructure and Industrial Machinery e.g. seals, pipes, vessels, valves. Without fluoropolymers increased maintenance will be required with increased potential for worker exposure to hazardous substances.
• Defence sector– key ingredient in munitions and military flares.
• Oil and gas e.g. seals & telemetry.

Question 2, 3 and 6.

15. AGCCE has always worked collaboratively with local and national authorities including the EA during the evaluations of PFAS raw materials used in our manufacturing, sharing information on PFAS fluoropolymer manufacturing process and emissions, providing evidence for the UK PFAS RMOA and numerous other requests.

16. We are aware of the UK regulators work:

• EA PFAS risk screening project and information collection on non-polymeric PFAS (Regulation 61 notices).
• COT PFAS working group undertaking assessment of evidence base and risk assessment of PFAS.
• HSE, supported by EA, published UK PFAS RMOA to examine the risks and the most appropriate management options.

17. Currently available commercial tests cannot analyse for all the PFAS molecules in the family and there is no accurate nor standardised single analytical method available capable of measuring the total PFAS concentration in products. This raises challenges to industry and regulators with regards to any proposed universal standards.

Development of reliable, timely, cost-effective analytical techniques to identify and quantify actual PFAS molecules (and not just organic fluorine) is a must before any policies are taken forward.

Total Organic Fluorine (non-targeted tests) are useful for screening, but targeted molecule level analysis will be needed to demonstrate compliance.

18. We believe that the knowledge of PFAS and risks they pose is still limited within UK and globally, for example:

• Limited understanding of diversity, differing risks and hazards of PFAS.  Many consider all PFAS to be the same in terms of hazards to humans and the environment.

• Epidemiological and studies on human health effects are limited to some PFAS of concern. There is considerable disagreement on the magnitude of impacts from exposure, or the required exposure level at which adverse health effects occur[16],[17].

• Limited understanding of background exposures, most studies considered ‘hotspots’.

• Limited research based on a lifecycle approach which incorporates the future impacts of actions already implemented i.e. future impact of emissions reduction, how lifespan of fluoropolymers compares to short life of alternatives (including energy and resources used to make more of the alternative to replace parts).

• Limited research into the risks of alternatives. High potential for regrettable substitution. Current proposals on fluoropolymers substitution overlooks complexity and lacks scientific basis.

Fluorotechnology is only selected after extensive evaluation, with high costs[18] industry is always looking for alternatives. The enduring use has been the irreplaceable combination of properties enabling required attributes.

For key industries such as aerospace, specifications and standards are defined for the entire life cycle of a specific version of aircraft.

Question 4 and 5.

19. Supply chains are long and complex, being multitier and international, and knowledge of chemicals used reduces through the tiers. Complexity was shown by ASD-Europe submission to ECHA’s PFAS restriction proposal consultation- “in larger aircraft the number of PFAS-containing components will likely be in excess of 1 million”[19].

20. Fluoropolymers are only used when necessary and frequently in very small quantities. Actors further down the supply chain may not be aware that PFAS is used in their article, many don’t know fluoropolymers are a PFAS and are not sufficiently educated on end-of-life management.

For example, PTFE is used to manufacture a breathable water-resistant textile used for mobile phone speaker diaphragm, the fabric is smaller than a postage stamp. PTFE meets combination of waterproofing, functionality, acoustic and electrical requirements, while alternatives do not.

21. Whilst not incorporated, PFAS are vital in manufacturing processes of numerous electrical components like microprocessors.

Tracking PFAS through an industrial process is challenging. Systems, processes, analytical techniques all need to be developed and certified for various media to accurately report at incredibly low levels.

22. Fluoropolymers are selected to enable a long working life. Primary users of fluoropolymers will know they are using PFAS. Their customers will have specified a requirement that necessitates fluoropolymers. The more complex an item, the more widely used in society, the less understood the makeup of individual component. ECHA’s submission by the EIGA[20] highlighted the unique cryogenic properties of PFAS materials. This is vital for handling liquid gases used in many hospitals.

23. A PFAS containing part might be manufactured in China where regulations are not as stringent. Until 2023 China was using PFOA in their manufacturing[21]. Items manufactured from this could potentially be still entering the UK supply chain and being a source of PFOA release into the environment.

24. There are also uncertainties about legacy emissions from historic production facilities in the UK which also contribute to levels of PFOA in the environment.

Question 7.

25. AGCCE have submitted a response on this subject to POST consultation on PFAS directly and as part of CIA.

26. As science and technology has developed, AGCCE are constantly improving manufacturing processes in line with our sustainability goals, a range of abatement technologies are utilised in the AGCCE manufacturing process. This included additional abatement installed in 2024 to reduce our emissions even further, as part of the FPG Manufacturing Program.

27. There are effective technologies to abate emissions and remediate PFAS. An overview of technologies including costs and the effectiveness was reviewed comprehensively by the ITRC[22].

Technologies include thermal treatment such as incineration. While incineration has a high operational cost, it is effective in destruction of the whole range of PFAS in solid and liquid waste[23],[24],[25],[26],[27],[28].

Fluoropolymers are of low hazard and data is available on their incineration demonstrating that controlled incineration evidence mineralization and produces only negligible levels of PFAS of concern[29],[30],[31],[32].

The European Environmental Agency considers thermal-combustion treatment to be 100% effective in removing PFAS from soils and effective for eliminating PFAS-containing waste[33] although other techniques are available22,[34].

28. Several technologies are technically effective to treat PFAS in drinking and wastewater when used independently or combined. They are widely used at commercial scales22,25,[35],[36]. Granulated Activated Carbon (GAC) and Ion exchange are more cost effective.

29. Treatment of PFAS in air can be performed using capture or thermal destruction methods. Capture of vapours include adsorption on GAC, clays or resins and capture of particles include bag houses, cyclones, wet scrubbers of electrostatic precipitators22,[37].

30. Bench-scale technologies are available. They showed variable effectiveness and commercialisation needs to be considered22,25,37. New destruction technologies may also offer solutions for remediation of non-polymeric PFAS.  

Question 8.

31. UK is a global leader in innovation and has a world class R&D.

UK Government has an opportunity to continually improve the evidence base on PFAS through cross-representative groups working with industry stakeholders, downstream users, academia, and environmental organisations.

32. Research should focus on generating and reviewing scientific data to enable risk-based evaluation of PFAS groups, development of standardised analytical and monitoring methods, and development of the end-of-life management guidance.

Question 9.

33. Evidence-based approach is required to segregate and classify PFAS based on risks. Not all PFAS have identical hazards and risk profiles and shouldn’t be treated as a single group. Regulation should be proportionate to the risk and focus on PFAS of concern.

PFOA, PFHxS and PFOS are already regulated due to toxicological or environmental concern. However, fluoropolymers display different toxicological properties than other PFAS4,5. Studies confirm negligible leaching or degradation from landfilled fluoropolymers[38].

34. UK REACH regulation and existing site operating permits under the Environmental Permitting Regulations are working well to regulate use of chemicals in manufacturing, including PFAS. These regimes already do and will continue in future to provide a mechanism for addressing potential concerns related to emissions during manufacture.

35. Companies are already acting through voluntary agreements and working with the appropriate environment regulator to minimise emissions. Many companies, including AGCCE, have already implemented the best available technologies to reduce emissions and have committed to further reducing emissions from fluoropolymer manufacturing.

AGCCE as a member of the FPG are signatories to the European industry Manufacturing Programme9. This voluntary commitment is aimed at reducing PFAS emissions setting specific targets for all signatories to reach by the end of 2024 and 2030.

FPG members, including AGCCE, have successfully met the first reduction target for non-polymeric PFAS residues from polymerisation aid technology[39]:

• For Air, members achieved a reduction of these emissions in their 2024 annual average emission factors below their target of 0.009%[40];

• For Water, while not all European fluoropolymers manufacturers have met the 2024 annual average emission factor for the emissions target of 0.001%, they all met that ambitious target at the end of 2024, therefore guaranteeing these emissions below 0.001% for 2025.

Such programmes could be utilised in the UK to demonstrate responsible manufacturing, promote the use of state-of-the-art technologies, support transparency and inform safe handling throughout the value chain.

36. Waste Management Regulations are already working well to manage hazards of waste. Multiple industries are subject to end-of-life regulations including but not limited to electrical, automotive, chemical and medical industries.

Question 10.

37. The evidence and risk-based approach that recognises differences between PFAS categories, together with the assessment of socioeconomic benefits is more appropriate.

38. In prioritising any action, UK should adopt a smart approach anchored on science and risk considering the broadness of PFAS definition. Application of the precautionary principle has the potential, if all PFAS are grouped as the same, to prohibit various important uses of PFAS that do not cause concern i.e. fluoropolymers in existing applications, such as aerospace, automotive, renewable energy, electronics and semiconductors, military, medical devices, uses that are critical and beneficial to society; in addition, it will also hamper transition to net zero carbon and achievement of the UN’s sustainability development goals.

Question 11.

39. There are general regulations managing use of chemicals within the UK that also cover PFAS. PFAS registration is already covered by UK REACH and manufacturing by the Environmental Permitting and Health and Safety regulations (e.g. COSHH).

40. To enable smart regulation a better defined, more specific, subgrouping of PFAS based on hazard profile is required.

41. There is a need for a more integrated approach and consistent regulations across various regulatory regimes, but this is a broader issue and not specific to PFAS.

Question 12.

42. In the US:

• The Environmental Protection Agency (EPA) has taken several actions to regulate PFAS, however prioritises regulating PFAS compounds that have demonstrated persistence, bioaccumulation and toxicity. Previously in 2024 the Agency set limits for six PFAS in Drinking Water Regulations, however in May 2025 announced its intent to reconsider PFHxS, PFNA, GenX and PFBS while retaining PFOA and PFOS in the regulation[41],[42].

• Introduction of TSCA 8(a)(7) for reporting all PFAS imported since 2011[43]. This is a major data gathering exercise and has been delayed due to IT departments’ budget restraints. Significant investment would be needed if UK wanted to track all PFAS in the supply chain.

43. From January 2025, under the Japanese Chemical Substance Control Law, Japan prohibits the manufacture, import and use of 138 PFAS (Class I Specified Chemical Substances). This regulation builds upon previous bans and imports of PFOS, PFOA (both 2021) and PFHxS (2024). In 2020, Japan also set a provisional target value of 50 ng/L for total PFOS and PFOA in drinking water.

44. In contrast, the EU is attempting to regulate across multiple Regulations and Directives. Member States are also developing national laws in specific areas. EU REACH PFAS restriction proposal attempts to regulate all PFAS without recognizing that they are not the same10. However, Authorities now consider other restriction options than a ban for certain uses[44]. Moreover, it has been reported that the new German Government rejects a total ban of PFAS[45].

45. China has only recently banned the import, export, manufacture, processing, and use of PFOA and PFOS. This is an example of poor regulation of PFAS of concern that UK manufacturers already phased out over a decade ago and results in, from UK perspective, in outsourcing of pollution and difficulty to compete.

46. Regulating all PFAS as a single group, regardless of risks, is not supported by the UK HSE RMOA8.

UK should focus on the global approach given the nature of a global concern but UK regulations should be based on science, available evidence, risk, socio-economic assessment, and ensuring a level playing field for UK manufacturing.

Question 13 and 14.

47. There is emerging research across the globe, and we don’t believe UK is in any different position to other leading countries. We believe UK is one of the leading countries in monitoring, detection, and treatment of PFAS pollution.

To reduce knowledge gaps, we need appropriate regulation of PFAS that are of concern where we have sufficient scientific and technical knowledge to do so, and to undertake more research where we do not.

To fill in the missing science, government and stakeholders should work together to identify a research plan that avoids duplication of other activities. 

May 2025