This PFAS restriction has been proposed by 5 EU States Members and currently evaluated by ECHA (European Chemical Agency) in Europe.
PFAS is a very wide family of substances (more than 5,000). Among those 5,000 substances, there are liquids, gases and solids with different toxicological profiles.
The fluoropolymers (PVDF, PTFE, ETFE, FEP, PFA…) fall under the PFAS definition based on chemical similarities but they are solid, chemically inert, stable, non-toxic, non-mobile… and according to the OECD criteria, they are classified as “Polymer of Low Concern”.
Fluoropolymers are used in tensile architectural membranes in a form of coating (PTFE), lacquer on PVC coating (PVDF), or film (ETFE, ..).
These fluoropolymers are Polymers of Low Concern, therefore most of the European tensile textile fabric manufacturers and users are requesting an exemption for fluoropolymers.
It is very important that contractors and designers of architectural tensile membranes, contribute to this consultation to provide inputs supporting evidence and to give a more precise picture on the socio-economical impacts in case of ban of fluoropolymers.
A first step is to select from a list of topics, the one your company intends to provide comments. LSAA suggest you to answer at least to the following :
- Information on alternatives (to give your opinion on viability of alternatives to fluoropolymers suggested by ECHA Europe),
- Information on benefits (to explain the benefits of fluoropolymers),
- Socio-economic analysis issues (to highlight the socio-economical impacts on your activities),
- Request for exemption (to avoid restriction of fluoropolymers).
It is important that you pay attention to the alternatives to fluoropolymers that have been suggested by the European states that have proposed the restriction.
Please give your opinion on each suggested alternative materials for tensile architectural membranes (see the suggested alternatives in the annex 1 of this document).
Do you consider that they are realistic alternatives or not to replace the existing membranes ? And why?
Submissions to be provided via the following link: Submitted restrictions under consideration - ECHA (europa.eu) and click on “give your comments”
Based on all the submissions and feedback, ECHA (European Chemical Agency) will evaluate this restriction proposal.
The producers of fluoropolymers and the producers of coated fabrics and films for architectural uses have already contributed to the ECHA’s public consultation.
It is then important that other companies affected by this restriction, provide ECHA a more informed picture of the socioeconomical impact of such restriction of fluoropolymer.
These bans could have a major impact on the Lightweight Structures industry that uses many of the fabric types mentioned.