Per- and polyfluoroalkyl substances (PFAS) are a large class of thousands of synthetic chemicals that are widely used throughout major industry sectors including electronics. Varying approaches to PFAS actions and differing opinions on how to restrict PFAS presents a challenge to manufacturers who seek to be proactive in addressing upcoming PFAS restrictions.
Why should I care?
The European Commission commits to phasing out all PFASs, allowing their use only where they are proven to be irreplaceable and essential to the society.
New reporting obligations in the US require manufacturers to be active in 2024.
EPA – Reporting and Recordkeeping Requirements for PFAS, under TSCA Section 8(a)(7): anyone who has manufactured (including imported) a PFAS for a commercial purpose in any year since 2011, is covered by this rule (must report during Nov 2024 – May 2025).
Maine PFAS reporting: must report intentionally added PFAS by 2025-01 (must report during 2024).
Minnesota PFAS reporting: must report intentionally added PFAS by 2026-01 (must report during 2025).
All US obligations cover electrical and electronic equipment, and it is unlawful to fail or refuse to submit the required information.