Definition of PFAS Under RMOA
PFAS are a group of man-made chemicals widely used in various industrial and consumer products due to their unique properties, but they are also known to persist in the environment and pose potential risks to human health and the ecosystem. Under this RMOA, PFAS are defined as fluorinated substances that contain at least one fully fluorinated methyl carbon atom (without any hydrogen, chlorine, bromine, or iodine atom attached to it), or two or more contiguous perfluorinated methylene groups (–CF2–). This reduces the number of PFAS in scope to hundreds, maintaining focus on substances that are persistent degradation products of PFAS.
Risk Management Measures to Be Considered
The HSE concludes that it would be appropriate, considering the Precautionary Principle, to initiate some or all of the following risk management measures with regard to certain uses of PFAS:
- Preparation of Annex XV dossiers to potentially support one or more restrictions of PFAS under UK REACH, including:
- the use and disposal of FFF where non-PFAS alternatives are available,
- other wide dispersive uses such as the application of coatings or use of cleaning agents,
- the manufacture and placing on the market of consumer articles from which PFAS are likely to be released into air, water or soil, or directly transferred to humans. This includes textiles, upholstery, leather, apparel, rugs and carpets, paints, varnishes, waxes and polishes, cleaning products. Consideration may be given to other consumer articles if other gaps are identified in consultation with other legislative regimes such as food contact materials.
- UK REACH authorization of PFAS used in processing aids in the manufacture and processing of fluorinated polymers
- Perfluorooctanoic acid (PFOA) and its ammonium salt – persistent, bioaccumulative and toxic (PBT), reprotoxic;
- C9-C10 PFCAs and their ammonium and sodium salts – PBT, reprotoxic;
- C11-C14 PFCAs – very persistent, very bioaccumulative (vPvB);
- PFHxS and its salts – vPvB;
- 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts, and its acyl halides (HFPO-DA) (the ammonium salt is commonly known as GenX® ); and
- perfluorobutane sulfonic acid (PFBS) and its salts.
How REACH24H Can Help
As a compliance service provider, REACH24H can help businesses navigate the complex regulatory landscape, including the recent proposal by the UK Health and Safety Executive (HSE) to regulate the use of poly- and perfluoroalkyl substances (PFAS). Our regulatory expertise and knowledge can help companies understand and comply with these measures, including the preparation of Annex XV dossiers to potentially support one or more restrictions of PFAS under UK REACH.
Contact Us
If you have any questions regarding UK REACH regulation, don’t hesitate to get in touch with us. Tel: +86-400-809-5809 Email: customer@reach24h.com
