Dr. Joachim Guisekus, IMAT e.V. and Fraunhofer Heinrich Hertz Institute (HHI), expresses his concerns about the planned PFAS ban in the European Union.
Is Europe really taking a special path with the planned PFAS restrictions?
The issue of PFAS is on the agenda worldwide. The need for regulation cannot be denied, and we are not against it. But in the USA, there is a completely different approach to the regulatory discussion. They take a close look at where PFAS are used. The PFAS ban is preceded by a very restrictive reporting requirement. In Europe, on the other hand, 15,000 substances are to be banned on the basis of a chemical formula - and then an attempt is made to define a few exemption rules. This approach has unforeseeable consequences.
Where do you see the biggest problem?
I can't imagine how such a ban would work. With 15,000 substances, many without a CAS number, there is no one who can monitor this. The authorities wouldn't be able to cope with the expected flood of applications, there are no staff - where would they come from? Exemption rules and deadlines are defined; for the semiconductor sector, a deadline of 13.5 years after entry into force has even been set. However, this only applies to process chemicals, not to production equipment. This would have to use PFAS-free spare parts from day 1. However, nobody manufactures such parts for machines that are ten years old in some cases. Or consider ASML: PFAS are used for coatings and seals in the production of Zeiss optics for ASML. The proposed ban could lead to ASML not being allowed to build machines in Europe. But trade wars are being waged elsewhere.
Is it possible to find a substitute for PFAS?
Substitutes are conceivable for many applications. In some areas, however, there is not even an idea. However, new chemicals that could meet the requirements would be just as persistent.
