PFAS Restriction in the EU: ECHA Consultation on Economic and Industrial Costs

The regulation of per- and polyfluoroalkyl substances (PFAS) continues to be a central issue in the European chemical policy landscape.

In anticipation of a possible ban or broad restrictions, the European Chemicals Agency (ECHA) has made available preparatory documents for a public consultation on the economic and industrial impacts of a large-scale restriction of PFAS. Stakeholder involvement at this stage is crucial, precisely because the refrigeration and advanced industrial sectors use, in various forms, materials and processes that may contain or interact with PFAS.

What does the consultation on PFAS include?

The ECHA consultation aims to gather comments and data from companies, trade associations, research institutions, and economic operators who may be affected by the implementation of restrictive measures. The focus is not only on environmental or health issues, but also on analyzing the economic and operational consequences for various sectors, including manufacturing sectors that make extensive use of advanced technologies and materials. The European regulatory framework is moving toward tightening rules for persistent chemicals , with the goal of reducing exposure and negative environmental and health impacts , but this objective must be balanced with the impact on production systems.

For the refrigeration industry, a detailed understanding of which PFAS categories and which applications will be subject to restrictions is crucial to guiding compliance, research, and technological innovation strategies. This type of consultation can ultimately impact material availability, component design, and system product life cycles.

Potential impacts on the HVAC/R industry

In the HVAC/R sector, PFAS are not refrigerants in the strict sense, but appear in lubricants, coatings, insulating foams and technical materials used in system components.

A broad restriction or ban could result in:

• Review of materials used in fluid and structural components , with the possible need to replace or redesign critical parts to eliminate additives containing PFAS.
• Supplier relationships to ensure material traceability and regulatory compliance throughout the supply chain.
• Adaptation of production and maintenance processes , as some substances currently used may need to be replaced with compatible alternatives, with potential effects on the costs and time to market of products.
• Greater commitment to managing regulatory compliance , with the need for manufacturers and designers to constantly monitor the evolution of rules and technical interpretations.

These elements indicate that more stringent regulation of PFAS is not an issue confined to the environmental sphere, but could have systemic effects on the HVAC/R supply chain, pushing the sector to strengthen its expertise in chemical compliance, management of hazardous substances, and design with alternative materials.

Preparing for regulatory change

Public consultation is a preliminary but crucial phase in the European regulatory decision-making process. For operators in the refrigeration and industrial cooling sector, actively participating with technical observations and sector data can help shape final decisions and identify technological solutions that balance environmental sustainability and system functionality.

Preparing for change also means investing in specialized training, research into alternative materials, designing for compliance with increasing chemical restrictions, and engaging with supply chain partners. Only in this way will the industry be able to effectively address the upcoming regulatory review phases and ensure robust, compliant, and competitive HVAC/R solutions.