Fluoropolymers Product Group (FPG) of Plastics Europe              PFAS0107

Written evidence submitted by Fluoropolymers Product Group (FPG) of Plastics Europe

UK Parliament – Environmental Audit Committee Inquiry

Addressing the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS)

On behalf of the Fluoropolymers Product Group (FPG) of PlasticsEurope, based in Brussels we are pleased to submit our input to the UK Parliament’s Environmental Audit Committee as part of its inquiry into the risks associated with PFAS.

Whilst we are not able to answer to all questions posed in your call for evidence, we hope that the information we provide will be useful for the Committee’s work. We welcome the opportunity to contribute to this important inquiry and to support the Committee’s efforts. We remain available to provide further assistance that might help.

About FPG: The FPG represents Europe’s leading fluoropolymer producers and experts, advocating for a balanced regulatory environment grounded in scientific evidence to ensure that European industries remain competitive and sustainable. Our membership includes, AGC, Arkema, Chemours, Daikin Chemicals, DuPont, Gujarat Fluorochemicals, Honeywell, W.L. Gore & Associates, Syensqo, and Kureha.

About Fluoropolymers: Fluoropolymers are a distinct subset of PFAS, characterized by their unique carbon-fluorine backbone, which imparts exceptional chemical resistance, thermal stability, and electrical insulation properties. These attributes make fluoropolymers irreplaceable in a wide range of critical applications, including healthcare, electronics, energy, transportation, and environmental protection. Their reliability and durability contribute significantly to safety, innovation, and resource efficiency across many sectors.

Our submission underscores the unique characteristics, safety profile, and socio-economic importance of fluoropolymers, arguing for their differentiation from other substances based on scientific and technical grounds. FPG emphasizes the critical role of fluoropolymers in enabling European innovation, sustainability, and industrial competitiveness, and outlines the industry’s commitment to responsible manufacturing, lifecycle management, and ongoing research.

1. About Fluoropolymers

Definition and Properties

Fluoropolymer’s structure imparts exceptional thermal, chemical, and biological stability, making fluoropolymers uniquely resistant to heat, chemicals, UV radiation, and environmental degradation[1][2]. Key properties include:

• High thermal stability: Fluoropolymers maintain their integrity at extreme temperatures, making them suitable for demanding applications.
• Chemical inertness: They are resistant to acids, solvents, and corrosive chemicals, enabling their use in harsh industrial environments and critical containment systems.
• Weather and UV resistance: These materials withstand prolonged exposure to sunlight and weather,.
• Low surface energy and non-stick behaviour: Fluoropolymers are widely used in non-stick coatings and surfaces due to their resistance to adhesion.
• Electrical insulation: Their low dielectric constant and high dielectric strength support advanced applications in electronics, telecommunications, and power transmission.
• Mechanical durability: Fluoropolymers exhibit high tensile strength, flexibility, and impact resistance, retaining their properties across wide temperature ranges.

Types and Applications

Fluoropolymers are divided into various types:

• Fluoroplastics: Used in films, coatings, linings, and insulation for their chemical and thermal resistance.
• Fluoroelastomers: Provide high-performance sealing, gaskets, and O-rings for automotive, aerospace, and industrial uses.

The benefits to the European Economic Area (EEA) enabled by the use of fluoropolymers are manifold. Advanced technologies and products in medical devices, transportation, semiconductors and energy and electrical and electronic devices would not be possible without fluoropolymer components and coatings. In addition, critical[3] (petro)chemical, pharmaceutical and other manufacturing processes can be operated safely and reliably thanks to fluoropolymer equipment, such as sealings, pipe linings, and filtering / separation membranes.

Applications span across:

• Renewable energy (solar panels, wind turbines, batteries)
• Automotive and transportation (fuel cells, wiring, seals)
• Electronics and semiconductors (high-purity water systems, insulation)
• Medical devices (implants, catheters, filtration membranes)
• Construction (weatherproof coatings, roofing)
• Food and pharmaceutical manufacturing (non-stick, contamination-resistant surfaces)

2. Safety Profile

Human Health and Environmental Safety

Fluoropolymers are recognized for their benign hazard profile[4] [5]: chemical inertness, stability, and low toxicity. They do not bioaccumulate, are not bioavailable, and are insoluble in water, minimizing any potential for environmental or human health impacts. Notable points include:

• Non-toxicity: Toxicological studies have found no significant health hazards associated with fluoropolymers under normal use.
• Inertness: They do not react with biological systems, do not degrade into harmful byproducts under environmental conditions, and are not classified as hazardous materials under transport regulations.
• Regulatory acceptance: Fluoropolymers such as PTFE and PVDF are approved for use in food contact, potable water systems, and medical devices due to their inertness and safety.

Environmental Stability

• Persistence: While highly durable and persistent, fluoropolymers do not degrade into mobile or toxic substances. Their stability is a key attribute for long-life applications.
• End-of-life[6]: Most fluoropolymer waste is managed via incineration in waste-to-energy facilities, where studies show complete conversion to inorganic fluorides and carbon dioxide, with negligible emissions of concern. Landfilling does not result in leachate contamination due to their insolubility and stability.

3. Differentiation from Other Substances[7]

Fluoropolymers are fundamentally different from other substances in their chemical family. They are high molecular weight, non-mobile, non-bioaccumulative, and non-toxic. Their unique structure and properties mean they do not share the risk profiles of other materials that may be subject to regulatory scrutiny.

4. Lifecycle Management

Responsible Manufacturing

The fluoropolymer industry is committed to best practices in manufacturing, including:

• Emission controls: Implementation of advanced technologies and processes to minimize emissions and recover processing aids.
• Research and development: Ongoing investment in new technologies to further reduce environmental impact, including the development of alternative processing aids.
• Continuous improvement: Collaboration across the industry to share best practices and drive innovation in environmental stewardship.

End-of-Life Management

• Incineration[8]: The majority of fluoropolymer waste is incinerated in controlled facilities, ensuring complete destruction and minimal environmental impact.
• Landfill: For the small proportion that is landfilled, studies confirm negligible leaching or degradation[9].
• Recycling: While technically possible for some fluoropolymers, recycling is limited by the complexity of end-use products and the need for clean waste streams. The industry is working to enhance recycling and upcycling where feasible.

5. Socio-Economic Impact

The value of the fluoropolymers sold in the EEA in 2022 was estimated via an FPG member survey to be in the range of € 1.0 – 3.0 billion, and this number is expected to increase at a modest rate to approximately € 1.2 – 3.5 billion in 2025.

Manufacturing in the EEA may decline, also following decisions from some manufacturers to stop production in the near future, but the overall demand is not expected to diminish, considering the importance of fluoropolymers for some major downstream industry sectors, including transportation (including electric vehicles), semiconductors and energy (including hydrogen and batteries).

Downstream users rely on the use of fluoropolymers for their processes and products. FPG’s 2023 socio-economic assessment report estimates that a market value of between € 700 and €1,400 billion in 2021 relied on the use of fluoropolymers in the EEA.

Market Data

• Production and Sales: Approximately 40,000 tonnes of fluoropolymers are sold annually in the EU, with Europe being a net exporter. The industry generates around €740 million in sales within the EU.
• Employment: The sector supports around 4,500 direct jobs in manufacturing and an estimated 8,900 total jobs when including indirect and induced employment across the value chain.

Economic Multiplier Effects[10]

• The use of fluoropolymers in critical industries underpins broader economic activity, innovation, and competitiveness. Their absence would have cascading effects on supply chains, product performance, and the ability to meet strategic objectives in sustainability and technology.

6. Critical Role in Strategic Sectors

Fluoropolymers are indispensable for achieving policy goals in sustainability, energy transition, digitalisation, and strategic autonomy. Their unique properties enable:

• Renewable energy systems: Essential components in batteries, fuel cells, wind turbines, and solar panels.
• E-mobility: Key materials in electric vehicles, supporting battery performance, safety, and durability.
• Semiconductors and electronics: High-purity, chemically resistant materials required for advanced manufacturing processes.
• Medical and pharmaceutical applications: Biocompatible, inert materials for implants, filtration, and packaging.
• Construction and infrastructure: Weatherproof, durable coatings and materials for long-lasting buildings and infrastructure.

7. Alternatives Assessment[11]

Lack of Viable Substitutes

• Performance limitations: Alternative materials often cannot replicate the combination of chemical, thermal, and mechanical properties provided by fluoropolymers.
• Safety risks: Substitution may introduce new hazards, reduce durability, or fail to meet stringent industry standards, especially in safety-critical applications.
• Economic and environmental costs: Inferior alternatives may require more frequent replacement, increase maintenance needs, and generate more waste, undermining sustainability goals.

Industry Standards and Regulation

• Many applications are governed by strict standards that require the use of fluoropolymers for safety, performance, and regulatory compliance. The absence of suitable substitutes would compromise these requirements.

8. Industry Commitments and Ongoing Initiatives

Collaboration with Stakeholders

• The fluoropolymer industry actively collaborates with regulators, downstream users, and research institutions.

Innovation and Sustainability

• Ongoing R&D efforts focus on reducing environmental impact, improving recycling and upcycling, and developing new applications that support European sustainability and competitiveness.

9. Conclusion and Key Messages

• Distinct and essential: Fluoropolymers are unique, high-performance materials that are critical to a wide range of strategic sectors and applications.
• Demonstrated safety: Extensive scientific evidence confirms their benign safety and environmental profile.
• Socio-economic value: The industry supports significant economic activity, employment, and innovation across Europe.
• Irreplaceable role: There are no viable alternatives that match the performance, safety, and durability of fluoropolymers in many critical applications.
• Industry responsibility: The sector is committed to responsible manufacturing, lifecycle management, and ongoing improvement in environmental stewardship.

10. EU PFAS REACH Restriction[12]

The main concerns driving regulators to include fluoropolymers in the proposed PFAS restriction under REACH[13] stem from their environmental persistence, despite fluoropolymers' distinct safety profile compared to other PFAS.

Fluoropolymers are characteristic of all PFAS chemicals and are persistent, which regulators consider an inherent environmental risk. The PFAS proposal argues that persistence alone justifies regulation, as it allows substances to accumulate indefinitely in ecosystems. As such, emissions to the environment during manufacturing and at end-of-life are of particular concern.

As part of European fluoropolymer manufacturers ongoing efforts to reduce emissions at manufacturing, and to better understand the end-of-life of fluoropolymers, the FPG has in recent years undertaken a number of activities.

• European Manufacturing Programme[14]: the FPG Manufacturing Programme is a voluntary initiative initiated in September 2023. The Programme sets a new benchmark in fluoropolymer manufacturing emission control in Europe and aims to lead the way for other manufacturing sites worldwide. The Programme’s goal is to ensure that fluoropolymers are produced responsibly. This is achieved with the lowest possible emissions using state-of-the-art commercially available technologies.

Participants in the Programme are FPG member companies with manufacturing plants in Europe are part of the Programme: AGC Chemicals Europe, Ltd., Arkema, Chemours Netherlands B.V., Daikin Chemical Europe, Syensqo, and W. L. Gore & Associates.

The Programme comprises three main parts:

1. An industry-led voluntary commitment to reduce non-polymeric PFAS emissions during fluoropolymer manufacturing.

2. A platform to promote the adoption of commercially available state-of-the-art technologies to minimise non-polymeric PFAS emissions in manufacturing, while protecting confidential business information and IP rights.

3. A commitment to inform downstream users of fluoropolymers on their safe handling and use, documented in the Guide for the Safe Handling of Fluoropolymer Resins.

The Programme specifically targets non-polymeric PFAS residues from polymerisation aid technology because of commonality between member sites and the use of this technology has emerged as one of the key concerns of regulators in recent years. While complying with their operating permits, individual companies are also working to improve understanding and reduce emissions in other areas not covered by this specific programme.

Members are committed to achieving specific average emission factors for non-polymeric PFAS residues from polymerisation aid technology. The targets are:

• By end 2024: 0.009% to air and 0.001% to water.

• By end 2030: 0.003% to air and 0.0006% to water.

By the end of 2030, emissions to air must be 0.03 kg/y or less, and emissions to water must be 0.006 kg/y or less.

Participants will continue to implement and improve state-of-the-art technologies to further reduce emissions and work towards achieving the 2030 targets. Efforts to identify and promote state-of-the-art emission control technology will continue via a Manufacturing Programme Technologies' Exchange Platform.

Members will also individually investigate and develop R&D programmes focused on substituting PFAS based polymerisation aids, where proven technically feasible, environmentally sound, meeting the performance and processing requirements and viable at an industrial and commercial scale.

An update will be published in 2026, setting out the progress made in 2025 across all the different pillars of the Manufacturing Programme as we strive towards our 2030 commitment.

Through this industry-led voluntary initiative, European manufacturers are taking concrete steps to set best-in-class fluoropolymer manufacturing practices. We are committed to transparent engagement with regulators to demonstrate industry efforts of responsible manufacturing practices and are willing to engage further in developing workable regulatory solutions for fluoropolymers.

• Assessment of Alternatives Project: in Q1 2025 FPG engaged the consultancy Ramboll to develop an Assessment of Alternatives (AoA) to Fluoropolymers report. The primary objective of this project is to demonstrate the challenges sectors face in assessing alternatives where technical feasibility, scientific (hazard and risk profiles), economic (costs related to substitution), supply chain impacts, and sustainability all need to be taken in to account when considering substitution of fluoropolymers.  

The current narrative around the substitution of fluoropolymers is rather general, non-technical, and lacks scientific basis, overlooking the true complexity of substitution for many applications.  

With the AoA, the FPG will highlight the real challenges of replacing fluoropolymers. The report will focus on fluoropolymers in (1) Transport (road, rail, shipping, aviation, defence), and (2) Semiconductors/Electronics. In these industries, alternatives to fluoropolymers either do not exist or cannot meet the demanding technical, safety, and performance standards required. 

The assessment will look at the process of identifying, developing, and validating suitable alternatives all of which can take years, depending on the technical requirements and regulatory landscape. By following these guidelines, the FPG’s AoA aims to provide a more accurate, evidence-based perspective on substitution, emphasizing the need for careful, sector-specific consideration rather than a blanket approach by regulatory authorities to banning fluoropolymers. 

The development of the AoA is expected to run until at least Q4 2025. The final report will constitute key evidence to share with other regulatory stakeholders, including ECHA, Member States Competent Authorities and the European Commission.   

Expected Date of Report’s Delivery: Q4 2025

• End-of-Life Technical Report: In December 2024, FPG launched a comprehensive End-of-Life (EoL) Technical Report for fluoropolymers. 

Recent regulatory discussions, including the PFAS restriction proposal and deliberations at ECHA Committees, have highlighted that the main environmental concerns for fluoropolymers are emissions during manufacturing and at the end-of-life stage.  

While European manufacturers already participate in emission reduction programmes during production, the end-of-life phase lacks a consolidated, up-to-date analysis. Existing literature and sector-specific reports are fragmented and do not provide a comprehensive overview of waste streams, incineration practices, and recyclability for fluoropolymers. 

The EoL Technical Report, prepared by Ramboll, aims to deliver an in-depth assessment of how fluoropolymers are managed at the end of their lifecycle across Europe. The focus will be on the most commonly used fluoropolymers in EU industries, including PTFE, FEP, FKM, PFA, ETFE, and PVDF. 

Key areas of investigation include: 

• Waste Volumes and Streams: Quantifying fluoropolymer waste by sector and tracking its movement through the waste management system. 

• Waste Prevention: Evaluating the impact of extending product life to minimize waste generation. 

• Incineration: Analysing the volumes and conditions under which fluoropolymers are incinerated, with a focus on ensuring safe and complete destruction, especially in municipal and hazardous waste incinerators. 

• Recyclability and Reuse: Reviewing current recycling technologies, recycled volumes, and future potential for upcycling and reuse of fluoropolymers. 

• Landfill Disposal: Assessing the quantities of fluoropolymers going to landfill and the conditions required for their safe disposal. 

How Will the Report Be Developed? Ramboll will consolidate information from: 

• Scientific literature and prior studies (such as the 2023 Conversio report on fluoropolymer waste). 

• Data provided by fluoropolymer producers. 

• Engagement with downstream users and end-of-life management organizations. 

This collaborative approach aims to ensure that the report is robust, representative, and actionable for all stakeholders in the fluoropolymer value chain. 

Expected Impact: The EoL Technical Report will: 

• Provide a clear, evidence-based overview of current end-of-life practices for fluoropolymers in Europe. 

• Identify opportunities for improved waste management, recycling, and emission reduction. 

• Support regulatory compliance and industry best practices. 

• Demonstrate the fluoropolymer industry’s proactive approach to addressing environmental concerns and regulatory expectations. 

Expected Date of Report’s Delivery: Q4 2025

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              May 2025