The report was prepared to evaluate the availability and feasibility of alternatives to fluoropolymers in selected applications, using the same type of methodology applied under EU chemicals legislation. Its purpose is to provide technical evidence on whether substitution is currently possible, and what timelines and challenges would be involved, so that regulatory discussions can be based on realistic assumptions. 

The assessment looks at specific case studies in the transport and electronics & semiconductor sectors. For each use, it identifies the key performance requirements and evaluates potential alternatives against technical performance, safety, availability and economic feasibility. This approach reflects how alternatives are assessed in regulatory processes, where substitution must be demonstrated for concrete applications rather than assumed in general. 

Fluoropolymers are used in a very wide range of applications, each with different technical requirements. Substitution must be assessed for specific uses; the study analyses representative case studies in detail. These illustrate the technical requirements, the evaluation of alternatives, and the steps needed to substitute materials in real industrial conditions. This approach reflects how alternatives are assessed under EU regulatory frameworks. The case-study approach allows a detailed and realistic assessment of specific uses, while illustrating the types of challenges that may arise when substitution is considered in practice. 

The study analyses selected case studies in order to illustrate how alternatives assessment works in practice. Because fluoropolymers are used in many different applications with different technical requirements, conclusions from one use cannot automatically be applied to others. The report therefore does not attempt to generalise across all uses but shows that substitution must be assessed individually for each application. It does, however, illustrate the inherent complexity of substitution that results from the fact that fluoropolymers are used in a wide range of interdependent components and processes.  

Fluoropolymers are used in a very wide range of applications, each with different technical requirements and operating conditions. The study shows that findings from one case study cannot automatically be extrapolated to other uses, because performance criteria, standards and safety requirements differ. For this reason, alternatives must be assessed at the level of specific applications. This applies within sectors too: findings from one transport case study cannot be reliably extrapolated to other automotive uses, given differing performance requirements and contextual factors. 

For the transport case studies, the study concludes that currently identified alternatives cannot be used as replacements for fluoropolymers, their inherent technical limitations make engineering a solution in the foreseeable future unlikely, and no other feasible alternatives have been identified. Substitution in these applications is not yet possible. For semiconductor applications, alternatives often fail to meet key technical performance criteria or are not yet sufficiently validated for industrial use. 

The assessment shows that substitution can be a long and complex process. Depending on the application, it may involve research and development, testing, certification, customer approval and changes to manufacturing processes. In some of the cases analysed, full substitution could take many years, and in certain applications potentially decades. In semiconductor manufacturing in particular, these timelines reflect individual use cases and do not capture the full system complexity, as fluoropolymers are used across multiple interdependent processes. Substitution would therefore need to be addressed at system level, implying significantly greater technical and economic challenges. 

No. The study aims at contributing technical evidence on substitution feasibility, so that regulatory decisions can distinguish between uses where alternatives exist and uses where they do not yet exist. This helps ensure that measures are effective while avoiding unnecessary disruption to critical applications. 

The study highlights that availability, safety, economic viability, supply chains, and sustainability must be taken into account when evaluating fluoropolymers. Acknowledging their distinct and unique properties, established safety profile and strategic importance, a full exemption within the REACH restriction would facilitate timely implementation, reduce administrative complexity and sustain EU competitiveness and security. In this context, FPG supports a regulatory approach that targets emissions rather than materials and recommends a risk-based restriction framework that recognises the voluntary manufacturing commitments as a basis for alternative risk management. 

The findings underline that regulatory measures must be grounded in the actual availability of alternatives for each use, as well as the role each application plays in complex systems. As their emissions can be controlled, fluoropolymers do not pose an unacceptable risk, and a full exemption is therefore warranted on that basis alone. The findings of this report further strengthen that case: viable alternatives are often not available, and where they exist, the hazard assessment shows that some carry significant concerns of their own, raising the risk of regrettable substitution. A restriction would moreover result in significant negative socioeconomic impacts on strategic EU industries. This approach is consistent with the principles of EU chemicals legislation, which require decisions to be based on robust scientific evidence.