PFAS are a group of over 15,000 highly hazardous chemicals with a wide range of commercial and consumer applications. With regulations on these compounds on the rise all over the world, manufacturers need to be aware of their compliance obligations.
What Are PFAS?
Often abbreviated as PFAS, per- and polyfluorinated alkyl substances are a group of over 15,000 synthetic chemicals known for their beneficial properties. PFAS are often waterproof, stain-repellant, and grease-resistant, among other advantageous qualities, making them useful components in a wide range of everyday products ranging from furniture and apparel to food packaging, electronics, and cosmetics.
Over the past two-plus decades, however, a succession of lawsuits and scientific studies have shown that the chemical family persists in human beings and ecosystems for many years, leading to significant health and environmental concerns. Research has established probable links between exposure to these chemicals and several types of cancer, developmental delays in children and adolescents, and adverse immunological effects. Efforts to regulate these chemicals’ widespread use and address PFAS contamination worldwide are ongoing.
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Why Are PFAS So Popular?
The first PFAS compound, polytetrafluorethylene, was synthesized by the chemical company DuPont at its Jackson Laboratory in Deepwater, New Jersey in 1938. Eight years later, it was introduced to the world as the durable, nonstick, heat-resistant resin known as Teflon. DuPoint competitor 3M followed suit by debuting the PFAS-containing finish Scotchgard in the 1950s, and before long the American public was awash in adaptable, stain-resistant products that were manufactured with one of a burgeoning number of so-called forever chemicals.
Within just a few decades, fluorocarbons were making dozens of products more resilient and versatile. These included cookware, food packaging, pesticides, shampoo, rainjackets, upholstery, cosmetics, and a range of cleaning products. In the process, they became an essential compound for manufacturers all over the world, firmly embedding themselves in global supply chains in a way that remains difficult to reverse to this day.
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PFAS Regulations in the U.S.
Research on PFAS’ effects on human health and the environment have prompted a series of major U.S. regulations at the national and state levels.
The Environmental Protection Agency (EPA) has been actively working to address the growing challenge of PFAS contamination. One way the EPA has done this is by establishing new reporting requirements in the Toxic Substances Control Act (TSCA) that aim to compile critical data on PFAS production volumes, use information, and exposure levels.
Additionally, a raft of U.S. states have taken regulatory measures into their own hands. California, Colorado, Minnesota, and Maine—among other U.S. states—have proposed ambitious legislation seeking to significantly curb PFAS use and phase out the compounds in product categories like cookware, cosmetics, and carpets and rugs.
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What Is TSCA Section 8(a)(7), the EPA’s PFAS Reporting Mandate?
In October 2023, the EPA published a final rule under the Toxic Substances Control Act Section 8(a)(7), titled Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances. The new rule requires all in-scope businesses manufacturing or importing one of around 1,400 specific PFAS compounds to submit a comprehensive, onetime report to the EPA detailing their use of PFAS between January 1, 2011 and December 31, 2022.
Businesses covered by the reporting mandate must submit a variety of information related to their PFAS use to the agency, including the total volume of the fluorocarbon being manufactured or processed and maximum concentration levels of the compound in their products(s). As of September 2024, the deadline for submitting reports has been pushed back to January 2026 for most companies.
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How to Identify PFAS in Your Supply Chain
With regulations restricting the use of PFAS on the rise worldwide, manufacturers, importers, and other companies should be aware of which of their products contain these toxic compounds. In order to determine whether and where fluorocarbons are incorporated into their goods, companies should examine their products for the characteristics that often suggest the use of PFAS, including thermal and chemical stability, stain-resistance, and water-repellency.
In addition, organizations can glean their bills of materials (BOMs), as well as any accompanying drawings and figures, to identify the presence of PFAS. Companies that source many of their components and subassemblies from supply chains will likely have to reach out to their suppliers to pinpoint the precise location of the chemical compounds.
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Why Electronic Manufacturers Should Be Concerned About PFAS
A study conducted by Z2Data identified nearly 40,000 electronic parts in its databases that are known to contain PFAS. Because forever chemicals rose to prominence in the form of Teflon and Scotchgard, the compounds are most closely associated with the products those brand-name chemicals have been historically used on, including furniture, cookware, clothing, carpets, and rugs. But as our study demonstrates, fluorocarbons are now an essential material in electronics manufacturing, too.
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What Electronics Contain PFAS?
Because of their extraordinary versatility, PFAS are found throughout the electronic component supply chain. A myriad of widely-used parts contain these chemicals, among them cables, capacitors, printed circuit boards (PCBs), and computer hard drives. Research from Z2Data has identified four primary fluorocarbons in the electronics industry: perfluorooctanoic acid (PFOA); perfluorooctane sulfonic acid (PFOS); polytetrafluoroethylene (PTFE); and perfluorobutane sulfonic acid (PFBS).
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How Are PFAS Used in Semiconductor Manufacturing?
Forever chemicals have long played an integral role in the worldwide chip ecosystem and the delicate, painstaking process of semiconductor manufacturing. To this day, PFAS remain essential to manufacturing steps like photolithography; packaging materials and substrates; and the high performance requirements for semiconductor manufacturing equipment and lubricants.
Despite the growing awareness of the dangers of these chemicals, semiconductor trade groups continue to argue that PFAS are irreplaceable to chipmaking. In fact, some have gone so far as to say that semiconductor manufacturing would be outright impossible without unfettered access to PFAS throughout the supply chain. Nevertheless, the industry has carried out modest changes in their use of the compounds, including by transitioning away from long-chain PFAS and replacing them with their shorter-chain counterparts. While this transition is based on the premise that shorter carbon backbones will lead to shorter half-lives—and thus lower levels of bioaccumulation and environmental persistence—evidence has yet to emerge demonstrating that short-chain PFAS are any less harmful than their predecessors.
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