Fluoropolymers Product Group (FPG) Position Statement:
The Case for Exempting Fluoropolymers: Safeguarding European Strategic Resilience
Brussels, 20 January 2026
Executive Summary: A Necessary Exemption
The Fluoropolymers Product Group (FPG) welcomes the acknowledgement from the PFAS restriction dossier submitters in their August 2025 Background Document that fluoropolymer production in Europe is critical and should continue under strict emission controls, a commitment already implemented through the FPG Manufacturing Programme.
However, the proposed regulatory approach is fundamentally flawed: it is overly complex, disproportionate, and risks undermining Europe’s industrial competitiveness and strategic autonomy. Fluoropolymers do not pose an unacceptable risk and can be responsibly managed.
We propose a complete and full exemption for fluoropolymer manufacture and uses based on the weight of scientific evidence and their critical role in the European economy.
The Problem: Undermining Strategic Sectors and Creating Uncertainty
- Strategic Risk: Fluoropolymers are essential materials for manufacturing and chemical processing industries. Curtailing the use of fluoropolymers would jeopardize Europe’s industrial base and resilience in critical technologies. Fluoropolymers are also indispensable in critical applications – from semiconductors and green hydrogen to medical devices and renewable energy – enabling Europe’s digital and ecological transitions and reinforcing its strategic autonomy.
- Flawed Risk Assessment: The updated Background Document fails to meet the requirements of the REACH Regulation for ‘unacceptable risk’ (Article 68) because restrictions are justified based on persistence rather than on assessed risk and neglecting the scientific principle of proportionality. Fluoropolymers are polymeric PFAS that exhibit different properties and synthesis pathways compared to other non-polymeric PFAS. They present a low, manageable risk, especially given industry-led initiatives for safe lifecycle management.
- Unworkable Timelines and Derogations: The proposed 5- and 12-year derogations are insufficient given the long R&D and certification timelines required in many sectors. These short timeframes generate market uncertainty, stifling investment and innovation. Furthermore, substitution often entails costly system redesign, performance loss, and lengthy requalification; in many cases, no viable drop-in alternatives exist or will be available in time.
- Complexity and Technical Chaos: The Background Document restriction proposal creates a burdensome regulatory landscape that will make compliance and enforcement extremely challenging. This complexity is aggravated by several technical flaws:
- The proportionality assessment is biased by the reliance on generic Environmental Release Categories (ERCs) for emission estimates, which significantly overestimate actual emissions rather than using precise, sector-specific data.
- The introduction of a new emission limit of 0.01% to all compartments for all PFAS for continued manufacturing lacks an adequate assessment of its technical and economic feasibility.
- Without effective sampling, testing, and adequate knowledge among border authorities, enforcement across the EU internal market and external borders will remain insufficient to control products containing PFAS.
The Solution: A Pragmatic, Risk-Based Regulatory Focus
A broad, ‘one-size-fits-all’ restriction lacks proportionality and is doing further damage to business confidence. The FPG calls for a risk-based differentiated approach that reconciles industrial and societal resilience:
- Full Exemption and Clarity: The PFAS restriction should provide a full exemption on fluoropolymer manufacture and uses. We need immediate clarity over the longterm future of fluoropolymers in the EU to avoid investment uncertainties.
- Regulate Emissions, Not Materials: Since concerns about fluoropolymers relate mainly to emissions during manufacturing, processing, use, and end-of-life stages, the focus should shift entirely to regulating and implementing robust emission reduction strategies.
- Leveraging Existing Legislation: The established framework of the Industrial Emissions Directive (IED) provides a mechanism for managing risks associated with emissions. The IED sets permitting conditions and emission limit values based on Best Available Techniques (BAT/BREF), which provides certainty for manufacturers to align their voluntary emission reduction efforts with official EU standards.
Conclusion
Exemption with robust emission reduction strategies is a pragmatic solution that addresses concerns on PFAS pollution while alleviating industry uncertainty. A risk-based restriction that recognises the voluntary manufacturing commitments as a basis for alternative risk management will ensure timely implementation, simplify obligations, and sustain EU competitiveness and security.
To maintain Europe’s industrial base, support the green and digital transitions, and protect strategic autonomy, the only viable path is to distinguish between PFAS categories and provide a full exemption for fluoropolymers.