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End of PFAS Commenting Period in Less Than One Month, Fluoropolymers Critical

On March 22, 2023, the European Chemicals Agency started a consultation on a proposal to restrict all PFAS in all applications in the EU. The consultation runs until September 25, 2023. So far, hundreds of comments have been submitted, mainly related to critical uses of fluoropolymers. The submitters have been pointing out that the restriction proposal does not address the whole industrial segments, such as machinery in industrial applications that require fluoropolymers in components that operate in harsh conditions (high temperature, reactive chemicals, high friction). For such uses, according to the submitters, there are no alternatives available, so these uses should be derogated. 

In our view, these submissions will be impactful and may push the EU authorities to propose further derogations and even wide derogations, not limited to specific uses. But for this, it is crucial that industry demonstrates that the use of fluoropolymers is critical across industries. Thus, it is warranted that all actors that rely on the critical uses of fluoropolymers make a submission with the description of critical uses and a socio-economic analysis of the impact of the restriction. The link to the commenting form in public consultation is available here.

If you have any questions, please do not hesitate to reach out to Ales Bartl ( or your existing contact at Keller and Heckman LLP.