Circularity Champion
Per- and polyfluoroalkyl substances (PFAS) in our industrial equipment
With the harsh conditions in chlor-alkali plants, the use of resistant PFAS is currently indispensable for certain pieces of equipment.
Last year, five countries (‘the Dossier Submitters’) introduced a proposal to the European Chemicals Agency (ECHA) restricting PFAS as a group in all uses. The proposal identified a limited number of PFAS uses that would still be allowed via so-called ‘derogations’ with any non-derogated use being ‘banned’. Next to many other sectors, the use of PFAS in industrial equipment (including chlor-alkali plants) was not proposed to be derogated.
As with every restriction, a six-month consultation period followed this ‘Universal PFAS REACH restriction proposal’. An unprecedented number of 5,642 responses were introduced by authorities, NGOs, businesses and citizens from around the world by the end of September 2023 to ECHA as part of this consultation. One of these was from Euro Chlor, providing more information on the chlor-alkali industry’s use of fluorinated materials.
Cefic also introduced a response, including a comprehensive study on the uses of PFAS in chemical plant equipment based on the input of more than 100 Cefic members. Many Euro Chlor members also participated in this Cefic survey.
Viewing that the Dossier Submitters and ECHA Committees now need to process the 5,642 contributions (over 100,000 pages of attachments), final decisions may experience delays.
Meanwhile, Euro Chlor continues to work on this important file. The Advocacy and Regulatory Affairs Committee continues to monitor developments closely to keep members informed and help them to collect the most relevant technical and science-based input to the process. Concurrently, the General Technical Committee (GTC) is actively engaging with equipment suppliers to discuss their use of PFAS, options for alternative materials and optimal end-of life solutions.
Waste from the production process
As part of our third Sustainability Programme we report on the amount of waste generated by members. In 2023, we observed positive trends in waste reduction compared to 2022. The amount of hazardous waste decreased from 2.2 kg per tonne of chlorine in 2022 to 1.9 kg per tonne of chlorine in 2023.
Similarly, non-hazardous waste also decreased from 2.9 kg per tonne of chlorine in 2022 to 2.2 kg per tonne of chlorine in 2023.
EU’s new ‘Essential Use concept’ covers end-of-life, waste and recycling
The EU Chemicals Strategy for Sustainability suggested developing an ‘Essential Use’ concept for the assessment of chemicals, aiming to address the most harmful substances in ‘non-essential’ uses. More than three years later, in April 2024, the European Commission answered this request by publishing a Communication on potential criteria and principles for integrating this concept into EU chemical legislation. It clarifies the concept and provides guidance for its practical implementation, including questions and examples useful for conducting essential use assessments.
The conditions for an ‘Essential Use’ include minimising exposure to humans and animals and reducing emissions to the environment during production, use, end-of-life and recycling. It also ensures substitution and transition to safe and sustainable chemicals, potentially including substitution plans with commitments and timelines and ensuring that consumers and waste operators are informed about the use in the supply chain. Euro Chlor is monitoring any potential implementation of the concept into regulation via its Advocacy and Regulatory Affairs Committee.