the proposal. ECHA’s scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) now must review these comments, and use them, as well as additional information received, to inform a final opinion on the rule. They could decide to move forward with no changes to the rule, alter it, or scrap it altogether. The final decision on the restriction will be taken by the European Commission together with the EU Member States. It has been relatively quiet as the two commissions review the comments, and PFAS users and producers have eagerly been awaiting any news. Taking into account the broad scope of the proposed restriction dossier, covering more than 10,000 substances used in many different sectors, the committees have decided to take a sector- based approach in their evaluation. This allows for proper attention to the specificities and different nature of the uses, risks and respective restriction options. On November 20, 2023, they released a progress update which gave a little more insight into where the restriction may be heading. In this update they stated, “To date, the RAC has reached a provisional conclusion on the hazard assessment of PFAS. In addition, provisional conclusions have been reached by the RAC and SEAC on five sectors: consumer mixtures and miscellaneous consumer articles, cosmetics, ski wax, metal plating and manufacture of metal products and petroleum, and mining.” ECHA also stated that due to the input from the public and others during the consultation phase, there were uses of PFAS that were not specifically named in the initial restriction dossier that were identified. One of the uses identified through consultation was sealing applications and fluoropolymers. They went on to state, “Fluoropolymers are one example of a group of PFAS with high interest for stakeholders and the consultation has brought further insight into… potential socio-economic impacts of a ban of their manufacture, placing on the market and use. Specific attention is being given to this group by all actors in the opinion development process.” This is welcome news to anyone in the rubber industry, as it is showing that the committees are giving special focus to fluoropolymers as they make their decisions and may hint to these INDUSTRY 2024 was a busy year for PFAS regulators and users alike. With the EPA, U.S. state, and Canadian reporting requirements, and the individual state-level and EU restrictions, as well actions in other regions of the world, it continues to be obvious that the focus on PFAS in the regulatory sphere is not going away any time soon. As more and more eyes are put on these substances, we can expect there to be much more discussion on how to properly regulate them. 22 / INSIDE RUBBER / 2025 Issue 1
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