FPG Study: Socio-Economic Assessment

The Socio-Economic Assessment was commissioned by the Fluoropolymers Product Group (FPG) to further support an evidence-based and grounded policy debate on the proposed EU PFAS restriction. It is the third in a series of FPG publications which, together with the Assessment of Alternatives and End-of-Life reports, show that fluoropolymers remain difficult or unviable to substitute in many critical applications, are effectively managed at the end of life, and support hundreds of billions of euros of European industrial output. 

The study finds that restricting fluoropolymers would have consequences far beyond the fluoropolymer market itself. It would affect the manufacturers who produce them, the industries that depend on them, and the strategic value chains they enable across transport, clean energy and advanced manufacturing. 

The findings offer a clear-eyed picture of the economic stakes involved, and reinforce FPG’s call for a full exemption of fluoropolymers from any blanket restriction under REACH. A regulatory approach designed for non-polymeric PFAS would impose wholly disproportionate costs on European industry if applied to fluoropolymers. 

The study assesses the impact of fluoropolymers from two angles: the footprint of EU fluoropolymer manufacturing itself, and the scale of downstream activity that depends on continued access to these materials. The analysis combines: 

  • Aggregated production, sales and employment data from all major EU27 fluoropolymer manufacturers 
  • Eurostat input-output tables for the EU27, to estimate supply-chain and wage-spending effects 
  • UN Comtrade import data for 2025, to estimate total EU27 market size and supply structure 
  • Eurostat Structural Business Statistics and PRODCOM product data, to estimate downstream sector scale 

The downstream analysis focuses on transport, energy and sealing applications, selected for their economic materiality, strategic relevance and the availability of robust data. They are not the only relevant sectors: semiconductors, electronics, construction, medical and broader industrial uses are all important but are not quantified here. The downstream figures should be read as measures of potential exposure, not forecasts of loss. The true economic stake is larger than the numbers presented. 

The report is based on: 

A systematic literature review of available evidence on fluoropolymer end-of-life behaviour. 
Economic feasibility Full-scale incineration testing data from European and US facilities.  
A value-chain stakeholder survey with 142 respondents from across the fluoropolymer value chain.

It examines fluoropolymers’ occurrence in waste streams, treatment routes under the EU waste hierarchy, mineralisation performance, recycling feasibility, and their contribution to waste prevention through extended product lifetimes. 

  1. Fluoropolymers’ economic contribution goes far beyond its direct input
    EU fluoropolymer manufacturers directly supported approximately EUR 620 million of output and 2,800 full-time jobs in 2025. Once supply-chain and wage-spending effects are included, the total economy-wide footprint rises to EUR 1.6 billion of output and 14,500 full-time jobs. Each euro of direct fluoropolymer output supports approximately EUR 2.61 of output across the broader EU economy.


  2. Hundreds of billions are at stake in downstream sectors
    Across transport, energy and sealing applications, fluoropolymer-dependent activity is associated with approximately EUR 330 billion of transport output, EUR 9 billion of energy output and EUR 20 billion of sealing-related output, alongside over 800,000 jobs. The sealing figures are cross-cutting and should be read alongside, not added to, the sector estimates. Semiconductors, electronics, medical and broader industrial uses are not included, meaning exposure runs significantly higher than these figures alone.


  3. Derogation would not limit economic exposure
    Even under a modelled derogation scenario with generous assumptions, approximately EUR 173 billion of output and over 386,500 jobs remain exposed across transport and energy alone. Derogation coverage is inherently narrow and uncertain, particularly for cross-cutting and energy applications. A derogation framework is not a solution. It is a partial and temporary measure that leaves European industries and EU production viability in question.
  4. Derogating only select applications would be counterproductive
    Fluoropolymer manufacturing requires demand across a wide portfolio of applications to remain economically viable. If restrictions remove a substantial share of that demand base, EU production could become unviable even where selected strategic uses are formally derogated. The consequence would be growing dependence on non-EU supply chains, running counter to EU objectives on industrial resilience, strategic autonomy and clean technology deployment.

Fluoropolymers are not a niche chemicals market. They are embedded in the industrial value chains that underpin European competitiveness, decarbonisation and strategic autonomy. Rules on their use and availability are an industrial policy decision with consequences running to hundreds of billions of euros of output and hundreds of thousands of jobs.

The findings highlight the importance of:

Assessing fluoropolymers as enabling inputs within wider industrial value chains, not only by reference to their direct sales value
Recognising that downstream exposure extends well beyond the sectors quantified in this study
Understanding that derogations alone cannot preserve the economic and strategic benefits that EU fluoropolymer access provides
Avoiding regulatory approaches that deepen EU import dependence in strategically critical materials

This study is the third in a series of reports commissioned by FPG to provide the evidence base for proportionate regulation. Combined with the limited availability of alternatives demonstrated by the Assessment of Alternatives and the effective end-of-life management confirmed by the End-of-Life report, the findings reinforce that:

  • A full exemption of fluoropolymers from any blanket restriction is the only proportionate regulatory outcome.
  • The proportionality assessment must consider the combined effect of restrictions on EU manufacturing capability, import dependence, downstream exposure and production viability.
  • Fluoropolymers cannot be treated as equivalent to non-polymeric PFAS in a regulatory framework designed to address a fundamentally different risk profile.

The Socio-Economic Assessment is a study that quantifies the economic importance of fluoropolymers in the EU. It assesses the economic footprint of fluoropolymer manufacturing in the EU and the scale of downstream industrial activity that may be exposed where their use and manufacture is restricted.

It was commissioned by FPG and prepared by Europe Economics to ensure that the ongoing REACH policy debate on PFAS is supported by a broad evidence base on the economic stakes involved, not only for fluoropolymer manufacturers but for the far larger downstream industries that depend on continued access to these materials. The study provides additional evidence supporting FPG’s call for a full exemption of fluoropolymers from any blanket restriction under REACH. Evidence presented in the study was submitted to the European Chemicals Agency (ECHA) as part of FPG’s contribution to the Socio-Economic Assessment Committee (SEAC) consultation.

The study draws on aggregated production, sales and employment data from all major EU fluoropolymer manufacturers, Eurostat input-output tables for the E7, UN Comtrade import statistics for 2025, and Eurostat Structural Business Statistics and PRODCOM product data for downstream sector estimates.

The manufacturer data are commercially sensitive and have been aggregated and anonymised in line with confidentiality principles. Results are only reported where they are based on data from at least three manufacturers.

The EU fluoropolymer market is estimated at approximately 56,500 tonnes in 2025. Domestic manufacturers produced approximately 29,500 tonnes but exported around 15,000 tonnes outside the EU27, meaning only approximately 14,500 tonnes of EU-produced fluoropolymers were supplied to the EU27 market, covering only around one quarter of total demand. Data indicates imports of approximately 42,000 tonnes, meaning non-EU sources account for approximately three quarters of market supply. 

In 2025, EU fluoropolymer manufacturers directly supported approximately EUR 620 million of output, EUR 150 million of Gross Value Added and 2,800 full-time jobs. These figures cover only the direct activity of EU producers and significantly understate the sector’s total economic contribution.

Once indirect supply-chain effects and induced wage-spending effects are included, the total economy-wide footprint rises to approximately EUR 1.6 billion of output, EUR 550 million of GVA and 14,500 full-time jobs. Each euro of direct fluoropolymer output supports approximately EUR 2.61 of output across the broader EU economy. The largest upstream effects are in chemicals and chemical products, wholesale trade, utilities, refined petroleum products, professional services and logistics.

The data show that the share of EU market demand supplied by non-EU sources has grown substantially, from around 38% in 2020 to approximately 75% in 2025. It is important to note that part of this shift reflects the reclassification of UK production as non-EU supply following Brexit, rather than a straightforward decline in EU output. Nonetheless, the overall direction is clear: the EU27 has become significantly more reliant on non-EU fluoropolymer sources.

This matters because EU fluoropolymer manufacturing requires specialised assets, technical know-how and regulatory compliance infrastructure. If restrictions further undermine the economics of EU production, recovering that domestic capability would be extremely difficult. The result would be growing strategic dependence on non-EU supply chains, which runs counter to EU objectives on industrial resilience and strategic autonomy.

Judging the economic significance of fluoropolymers by their direct sales value fundamentally misrepresents their role in the economy. In many applications, fluoropolymers account for a small share of input value but perform functions that are critical to the performance, reliability, durability and regulatory compliance of the products in which they are used. Restricting access to a technically critical input in those applications could expose far larger downstream value chains.

The relevant question is not as simple as the how large the fluoropolymer market is, but more importantly how much downstream industrial activity depends on continued access to fluoropolymers where substitution is not viable in the short run. That is what the downstream value-at-risk analysis sets out to quantify.

The quantified downstream analysis covers transport, energy and sealing applications. These three areas were selected because they are economically material, strategically relevant and could be mapped to downstream economic data with sufficient robustness for quantified analysis. However, they are not the only relevant sectors. Key industries such as semiconductors, electronics, construction, medical and broader industrial uses are also important applications for fluoropolymers As these are not included in the quantified estimates, the study only captures a subset of total downstream exposure, and the true picture is therefore significantly larger than the figures presented.

Across transport and energy alone, the study estimates that fluoropolymer-dependent applications are associated with approximately EUR 339 billion of output and nearly 752,100 full-time jobs across the EU27.

By area, the central estimates are:

  • Transport (road vehicles, aerospace, rail, maritime): approximately EUR 330 billion of output, EUR 77 billion of GVA and 727,100 full-time jobs.
  • Energy (photovoltaic products, hydrogen technologies, non-EV batteries, chlor-alkali membranes): approximately EUR 9.0 billion of output, EUR 2.9 billion of GVA and 25,000 full-time jobs.
  • Sealing applications (cross-cutting across transport, energy, semiconductors and wider industrial uses): approximately EUR 20 billion of output, EUR 5.1 billion of GVA and 54,900 full-time jobs.

The sealing figures should be read alongside the transport and energy estimates rather than added to them, as sealing applications are cross-cutting and overlap with both sectors. All figures are measures of exposure, not forecasts of loss. Semiconductors, electronics, medical and broader industrial uses are not quantified, meaning the full economic stake is likely significantly larger.

The study models the downstream exposure that would remain under a hypothetical derogation scenario based on assumptions informed by manufacturer input. The central assumptions are that 50% of relevant transport fluoropolymer sales remain restricted, 90% of relevant energy sales remain restricted, and 100% of relevant sealing sales remain restricted. These assumptions reflect the inherently narrow and uncertain coverage that any derogation framework is likely to achieve, particularly for cross-cutting and energy-related applications.

Under these assumptions, approximately EUR 165 billion of transport output, EUR 8.1 billion of energy output and EUR 20 billion of sealing-related output remain exposed, alongside over 386,500 jobs in transport and energy and a further 54,900 in sealing applications. These are short-term estimates that do not account for derogation expiry, legal scope uncertainty or the operational challenges of supplying only derogated uses.

The conclusion is clear: even under generous derogation assumptions, material downstream exposure remains. A derogation framework is not a solution. It is a partial and temporary measure.

Fluoropolymer manufacturing requires demand across a wide portfolio of applications to remain economically viable. It involves specialised assets, significant technical know-how, regulatory compliance infrastructure and fixed costs that cannot be sustained on the basis of a narrow set of derogated uses alone.

Defence, medical and aerospace applications may carry high strategic importance but account for relatively small fluoropolymer volumes. If restrictions remove a substantial share of the broader demand base, EU production could become unviable even where those strategic uses are formally derogated. A derogation for critical applications has no practical value if the EU production base needed to fulfil it no longer exists. The consequence would be growing dependence on non-EU supply, precisely the strategic dependency the EU’s own industrial and security policy is designed to avoid.

This study is the third in a series of three reports commissioned by FPG to provide a comprehensive, evidence-based foundation for the regulatory debate on fluoropolymers and to support FPG’s call for a full exemption from any blanket restriction under REACH.

The Assessment of Alternatives, prepared by Ramboll, demonstrated that viable alternatives to fluoropolymers are not available at scale across the majority of critical applications. The End-of-Life report, also prepared by Ramboll, confirmed that fluoropolymers are a negligible, well-managed waste stream that does not constitute an unacceptable risk.

Together, the three publications show that fluoropolymers are essential enabling materials in strategic European value chains, are manufactured and managed responsibly, remain difficult or unviable to substitute in many critical uses, and support hundreds of billions of euros of European industrial output. Collectively, they provide evidence underpinning FPG’s call for a full exemption for fluoropolymers.

FPG calls for a full exemption of fluoropolymers from any blanket restriction under REACH. The evidence is now in place across three independent reports. Fluoropolymers are scientifically distinct from the non-polymeric PFAS driving regulatory concern, manufactured and managed responsibly, are not replaceable across the majority of critical applications, and underpin strategic European value-chains running to hundreds of billions of euros of downstream output.

A derogation-based approach is not adequate. It would leave material economic exposure unresolved, risk undermining the viability of EU domestic production, and deepen an already significant strategic dependence on non-EU supply chains. A full exemption of fluoropolymers is the only proportionate regulatory outcome.