✔ RoHS Guide

PFAS Restrictions for Electronics

PFAS (per- and polyfluoroalkyl substances) are a family of several thousand synthetic chemicals built on carbon-fluorine bonds, among the strongest bonds in organic chemistry. That bond makes PFAS heat-resistant, chemically inert and water- and oil-repellent - and also makes them persist in the environment for decades, which is why they are called "forever chemicals." The OECD defines PFAS as any substance containing at least one fully fluorinated methyl or methylene carbon atom, a definition broad enough to include fluoropolymers such as PTFE.

PFAS are not one of the 10 RoHS restricted substances. They are regulated through REACH, the EU POPs Regulation, the Stockholm Convention, US TSCA, US state laws and China's new-pollutants controls - and the scope of those rules is widening from a handful of individual substances to PFAS as a class.

Where PFAS appear in electronics

• Wire and cable insulation - fluoropolymers such as PTFE, FEP, PFA and ETFE for high-temperature, high-frequency and harsh-environment cabling.
• Lithium-ion batteries - PVDF (polyvinylidene fluoride) binder in cathodes, plus fluorinated electrolyte salts and additives.
• Semiconductor manufacturing - photoresists and photoacid generators, anti-reflective coatings, surfactants, and fluorinated etch and cleaning chemistries.
• Thermal management - fluorinated heat-transfer fluids used in test equipment and immersion cooling for data centers.
• Seals, gaskets and lubricants - fluoroelastomers (FKM) and PFPE greases in connectors, pumps and enclosures.
• Coatings - water- and oil-repellent treatments and some conformal coatings on printed circuit assemblies.

EU restrictions already in force

• PFOS - banned under the EU POPs Regulation (EU) 2019/1021, with narrow exemptions.
• PFOA, its salts and related compounds - banned under the EU POPs Regulation.
• PFHxS, its salts and related compounds - banned under the EU POPs Regulation.
• C9-C14 PFCAs (long-chain perfluorocarboxylic acids) - restricted under REACH Annex XVII.
• PFHxA, its salts and related substances - restricted under REACH Annex XVII for consumer uses such as textiles, food packaging, cosmetics and firefighting foams.

Several PFAS are also on the REACH SVHC Candidate List, which triggers supplier communication duties when present in an article above 0.1% by weight. See the REACH SVHC Candidate List.

EU universal PFAS restriction

In 2023, Denmark, Germany, the Netherlands, Norway and Sweden submitted a proposal to ECHA (the European Chemicals Agency) to restrict PFAS as a group under REACH, covering an estimated 10,000 substances. Electronics and semiconductors are among the sectors assessed.

• RAC (ECHA's Committee for Risk Assessment) has adopted its opinion, favoring a full ban.
• SEAC (ECHA's Committee for Socio-Economic Analysis) favors a ban with use-specific derogations, and its final opinion follows public consultation on its draft.
• Transition periods under discussion are 18 months for most uses, with time-limited derogations of five or 12 years where alternatives are not yet available.
• Next step - the European Commission drafts the final restriction and submits it to the REACH Committee, followed by scrutiny by the European Parliament and Council before it is added to REACH Annex XVII.

Stockholm Convention

The Stockholm Convention on Persistent Organic Pollutants lists PFOS (restricted under Annex B), PFOA and PFHxS (eliminated under Annex A), and long-chain PFCAs. Parties - including the EU, China and Japan - implement these listings through national law, which is why the same substances appear in the EU POPs Regulation and China's control list.

United States

• TSCA Section 8(a)(7) PFAS Reporting Rule - a one-time EPA reporting obligation for companies that manufactured or imported PFAS, including PFAS in imported articles, from 2011 through 2022. EPA has proposed exemptions for imported articles and for concentrations at or below 0.1%, and has deferred the submission period while those changes are finalized.
• Maine - prohibits sale of listed product categories containing intentionally added PFAS, with a broad ban on intentionally added PFAS in products scheduled for 2032 unless a use is designated currently unavoidable.
• Minnesota (Amara's Law) - bans intentionally added PFAS in 11 product categories now, all products by 2032 except currently unavoidable uses, and requires manufacturers to report PFAS in products sold in the state.
• Other states - California, Colorado, New York, Vermont and Washington restrict PFAS in specific product categories, mostly consumer goods, textiles and packaging.

China

China's List of New Pollutants for Priority Control, issued by the Ministry of Ecology and Environment (MEE), prohibits the production, use, import and export of PFOS, PFOA and PFHxS and their salts and related compounds, with limited exemptions. China implements its Stockholm Convention obligations through this list.

Compliance approach for electronics makers

1. Map where fluoropolymers and fluorinated chemicals enter the bill of materials - cable, seals, batteries, coatings and process chemicals.
2. Request PFAS content from suppliers through supplier material declarations; the IEC 62474 Declarable Substance List includes PFAS groups.
3. Separate intentionally added PFAS from trace impurities, since most state laws target intentionally added use.
4. Track which uses are likely to receive derogations under the EU universal restriction and which need substitution plans now.

Related coverage

• SemiconductorX - semiconductor process chemicals and fab materials
• ElectronsX - batteries, EV supply chains and electrification materials