Hot Spot Release of EU PFAS Restriction Proposal- Industry Action Required

What is it?

In January 2022 Hot Spot BV002476 alerted members to an EU proposal to restrict or ban the use of PFAS materials such as PTFE, ETFE, FKM and FFKM. They are commonly used as sealing or lining components in valves, and a ban will have significant negative consequences for the pressure equipment industry. The PFAS restriction proposal has now been published and will be released on March 22 for a “public consultation” which is scheduled to last for 6 months.

The BVAA have been contacted by the European Sealing Association (ESA) to advise us that as part of the consultation process, they have engaged Ricardo Energy & Environment to create a socioeconomic analysis (SEA) for the sealing industry. The ESA have recognised that they will need specific information from downstream users to provide a picture of how products containing PFAS are used and what the unique benefits are. The data will be collected from valve and pump manufacturers and process plants to provide vitally important “downstream” information to add credibility to the analysis. They are requesting BVAA members’ help to gather data to support a special exceptional case for sealing devices.

The BVAA are asking that members initially respond to this Hot Spot by following the link on the attached invitation from Ricardo to register interest in providing information for the SEA. Following registration, a questionnaire will be forwarded in the next few weeks and all replies will be retained and collated by Ricardo under the terms of their NDA with the ESA. Because of the specific data needed the BVAA cannot respond to this issue without the direct support and data of its members.

Therefore, please advise the BVAA secretariat when you respond to the link so that we can understand our member’s reaction to this issue. It is likely that a BVAA PFAS task group will then be formed to ensure that we are able to respond effectively.

Why is it Important?

If a ban on the use of PFAS as sealing or lining materials takes place virtually every aspect of modern living will be impacted, the environment will be damaged, and most industries will not be able to function as effectively because there is often no suitable alternative material available in many of these applications. Aerospace, automotive, chemical, power, water, food, pharmaceutical, nuclear are just some of the industries that fundamentally rely on the performance of these materials.

It is important that the industry works to ensure that the public consultation highlights the vital role of PFAS as sealing materials and effectively makes the case that they should be treated differently to other PFAS containing products that are produced in high volumes and have frequent direct contact with humans and the environment as consumer items. Please also refer to the attached letter of engagement document from ESA providing more information and links on the issue. It also summarises the proposed timeline which could result in a ban of PFAS materials as soon as 2026.

Continuous Improvement - Did we miss anything?

Hot Spots are intended to alert members and provide a brief overview of new standards, activities or procedures that are being introduced in the industry. If there is key information missing that would be helpful, please let us know so that we can improve our future service.

Please Note: This Hotspot is for information purposes, and we invite comments from BVAA members only. Please also note that at time of publication ballots may be closed. For more information, please contact the Secretariat.

BVAA Members: Did you know we have a hotspot tab on the BVAA website? Head over to www.bvaa.org.uk/login-here.asp and log into the member only area. You then need to select ‘Hotspots’ for the latest. For information on how to access the member only area of the website please contact jane@bvaa.org.uk. 

Published: 29th March 2023