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EU: Restriction on PFCAs proposed under REACH

January 2018- Relevant for: Electrical & electronics, Hardlines, Softlines, Toys and children's products

On 20 December 2017, the European Chemicals Agency (ECHA) launched the 1st public consultation1 on the proposal to restrict C9-C14 perfluorocarboxylic acids (PFCAs), their salts and related substances, under REACH Annex XVII.

PFCAs are synthetic compounds and hazardous to human health and environment. C9-PFCA and C10-PFCA, as well as their sodium and ammonium salts can cause damage to human health. In addition, C9-C14 PFCAs are bioaccumulative and belong to the most persistent chemical substances known, so they have been identified as substances of very high concern (SVHCs). C9-C14 PFCAs related substances are mainly used in the textile application (e.g. apparel, carpets), paper and paint. C9-C14 PFCAs can be used as alternatives to perfluorooctanoic acid (PFOA) which is always used in special finishing to textiles and paper to give water, grease, oil and/or dirt repellency.

The intention of this proposal is that C9-C14 PFCAs are potential alternatives to PFOA. The proposed restriction can prevent industry switching from PFOA to C9-C14 PFCAs. Moreover, C9-C14 PFCA related substances can be transformed to C9-C14 PFCAs in the environment. Hence, their related substances are also included in the proposal.

All interested parties can comment on the proposal using the ECHA website until the end of the consultation period on 20 June 2018, but comments received by 16 February 2018 can assist in early stages of comments development.

Table A. Proposed restriction on C9-C14 PFCAs, their salts and related substances2

Proposed scope of restriction

Substances, mixtures and articles

Proposed limit

  • Substances: Not used (Not detected)
  • As constituents in another substances, mixtures, articles or any parts:
    • Sum of C9-C14 PFCAs and their salts: < 25 ppb;
    • Sum of C9-C14 PFCAs -related substances: < 260 ppb
Proposed exemption
  • The manufacture of a substance where this occurs as an unintended by-product of the manufacture of fluorochemicals with a carbon chain equal to or shorter than 8 atoms;
  • A substance that is to be used, or is used as a transported isolated intermediate provided specific conditions are met.
  • Articles placed on the before the date of application (i.e. 18 months from the date of entry into force
Proposed date of application

18 months from the date of entry into force

[1] Public consultation on PFCAs
[2] Restriction report (with the scope and conditions of the restriction listed on pp. 15) 

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