Where are PFAS in your electronics supply chain?

PFAS (per- and polyfluoroalkyl substances) have come under public scrutiny in recent years, with local and federal governments taking steps to reduce their presence in everything from drinking water to fast food wrappers. 

PFAS have a long and controversial history, but their prevalence–combined with their long half-lives and links to health diseases such as kidney cancer and pregnancy-induced hypertension–has generated renewed attention from a health-conscious public. 

While regulation does exist around PFAS, most of it focuses on select PFAS in food wrappers or other products like cosmetics. However, following a recent proposal to outright ban or severely restrict PFAS across the European Union, other industries will also need to consider the potential impact new PFAS regulation might cause to their supply chains. 

Why Upcoming PFAS Regulation Matters for the Electronics Industry

Modern PFAS regulation have approached regulation from two angles:

1. Restricting a single or few substances (eg. PFOS)
2. Restricting an entire group (with some exceptions)

For example, the Food and Drug Administration (FDA) currently limits the types of PFAS that can be used in food contact products, although it doesn’t limit the amount of PFAS in those products.

By contrast, the recent proposal by the five national authorities aims more towards a group ban. The proposal (submitted by Germany, Denmark, the Netherlands, Sweden, and Norway) asked the European Chemicals Agency (ECHA) to consider two options:

1. A full ban, with an 18-month grace period for companies to transition 
2. A ban with use-specific, time-limited derogations

But the challenge companies face doesn’t just lie with how big or small a ban might be: it’s also what it covers. The Environmental Protection Agency (EPA) and ECHA aren’t working off the same list when they discuss PFAS. In reality, no agency is.

Which PFAS Are Being Regulated

Getting a full list of PFAS is more complicated than you might think.

The Center for Disease and Control Prevention identifies over 9,000 types of PFAS while the EPA recognizes over 14,000 in total. Meanwhile, ECHA mentions over 10,000 potential PFAS that are at risk under the proposed regulation.

This can make it exceptionally difficult to understand which PFAS might be regulated and where. However, as of right now there are a few key PFAS in electronics that would fall under the proposed ECHA ban:

1. Perfluorooctanoic acid (PFOA)
2. Perfluorooctane sulfonic acid (PFOS)
3. Polytetrafluoroethylene (PTFE)
4. Perfluorobutane sulfonic acid (PFBS)

All of these are used either in electronics products or the manufacturing process for electronic components. 

Monitoring the ever-evolving landscape of environmental compliance can be a challenge to follow. To address this challenge, Z2Data’s platform tracks new regulations so companies can immediately assess a law’s impact on their products and components in real time. In the case of PFAS, this would include the full list of all chemicals mentioned in any new EU regulation. Learn more about how Z2Data keeps customers compliant here.  

Where Are the PFAS in Your Electronics Supply Chain?

Research from Z2Data shows four primary PFAS are used in the electronics industry:

Perfluorooctanoic acid (PFOA)‍

• Electronic components like cables and computer parts

Perfluorooctane sulfonic acid (PFOS)

• Electronic components like cables and computer parts

Polytetrafluoroethylene (PTFE)

• Electrical insulation
• Medical Devices
• Aerospace
• Seals and gaskets
• Textile coatings

Perfluorobutane sulfonic acid (PFBS)

• Surfactant
• Emulsifier
• Aerospace
  

These PFAS show up in a myriad of ways in the electronics manufacturing process, including: 

• Semiconductors: PFAS are currently used in the manufacturing process of semiconductors. High purity PFA tubing is regularly used for its ability to “withstand corrosive surfactants for longer periods of time than standard fluoropolymer tubing.” These tubes must often handle harsh chemicals including hydrogen fluoride or hydrogen peroxide.
• Printed Circuit Board Assembled (PCBA): PFAS used as soldering agents.
• Printed Circuit Board (PCB) Laminates: PFAS are used as flame-retardants to reduce the risk of fire. 
• Cable polyvinylidene fluoride (PVDF) coatings: PFAS are used to prevent electrical arcing. They leave PFOA residues and impurities. 
• Computer hard drives: PFAS are used as lubricants to reduce friction between moving parts. 
• Synthetic Rubbers & fluoroelastomers: PTFE in particular is used as a processing aid to produce fluoroelastomers. As a result, they can remain as a residue in the final product. 
• Polycarbonates: PFAS can be used as an additive. 
• PTFE tapes: PTFE is often used as a coating on tapes. These can also leave unintentional residues of PFOA. 
• Mineral oil (grease): can contain PFAS as impurities. 

Why Are PFAS So Prevalent in Electronics Manufacturing?

PFAS are a popular–and hard-to-substitute choice–for manufacturers due to several unique chemical properties:

• Chemical stability: they are highly resistant to chemical reactions and degradations.
• Thermal stability: they can withstand high temperatures without degrading or releasing toxic by-products. 
• Low surface tension: they are highly repellant to liquids, which can help create non-stick surfaces (hence their popular use on non-stick pans).
• High thermal and electrical insulation: they are useful in electrical components and thermal insulation applications. 
• Hydrophobicity: they are highly water-repellent, which makes them useful for water-resistant coating or even firefighting foams. 
• Lubricity: They are useful as release agents or lubricants. 

These qualities make them a popular choice for manufacturers who need reliable and sustainable parts when it comes to producing electronic components.

Where Do PFAS Show Up in Electronic Components?

Z2Data’s database indicates PFAS appear in a large number of electronic components. Most of these are tantalum capacitors, followed by flash memories, and resistor trimmer potentiometers. Other parts include:

• Crystal Oscillators
• Rectangular connector headers and receptacles
• Tantalum polymer capacitors

To learn more about how Z2Data sources its information and if your products have measurable amounts of PFAS in them now with our free 14-day trial of our platform. Z2Data will show you how to identify PFAS use in your supply chain as well as source cross references to reduce your environmental compliance risk/ 

Concerns About PFAS Regulation From Manufacturers

The ECHA has allowed companies and individuals to add public commentary to the proposed PFAS ban. Several manufacturers in the electronics supply chain have added their perspectives.

Here are seven on the impact of PFAS in the semiconductor manufacturing process:

Comment #1
Fluortubing PTFE tubing is essential for the safe and efficient delivery of harsh chemicals used in semiconductor manufacturing. Its unmatched properties of chemical resistance, purity, and non-reactivity make it the preferred material for ensuring the high-quality and purity of semiconductor materials during transportation and processing. - Flurotubing, Netherlands

Comment #2
We manufacture Bisphenol AF (BPAF, CAS No.; 1478-61-1), which is useful as a raw material for semiconductor materials and electronic components…BPAF is used in versatile applications for semiconductor and electronics.

First, BPAF is used as a raw material for photosensitive polyimides (PSPIs). PSPIs are quite essential to fabricate organic light emitting diodes (OLEDs) that are available for smartphones and TVs. PSPIs are also essential to fabricate high-performance semiconductor chips installed in data centers, personal computers (PCs), smartphones, etc. - Glass Central Co., Ltd., Japan

Comment #3
There are sensor wires for automotive safety parts that cannot be manufactured without PTFE, which does not melt even at the melting point or higher in environments exceeding 300°C, and there are no alternative materials. It cannot be replaced.

Due to its excellent heat resistance, oil resistance, and chemical resistance, fluororubber is widely used in chemical plants, semiconductor-related equipment, etc., mainly for automobiles. Oil resistance is better than any other rubber, and chemical resistance, solvent resistance, and ozone resistance are outstanding compared to other rubbers. It is used for sensor wires, which are automobile safety parts that require heat resistance and flexibility, and there is no substitute material. - Anonymous, Japan

Comment #4
Our research clearly demonstrates that if the semiconductor industry’s proposed derogation does not fully cover the uses captured in the updated Table A.49, then the ability to manufacture or import semiconductors in the EU will stop following the entry into force (EiF) and the expiration of the 18 month transition period (≈ 2028 timeframe). 

Rather than being hyperbole, this is the only foreseeable outcome based on the fact that essentially all equipment, and most chemicals, required for the semiconductor manufacturing process depend on the use of PFAS substances, mixtures, and articles for which replacements are not currently known.  Such an outcome will be nothing short of a catastrophe for the EU economy and its citizens given the criticality and strategic position the semiconductor industry holds in enabling so many devices and industries such as automotive, electronics, communications, data storage & analysis, legal & regulatory infrastructure, remote education, scientific (including materials) research, medicine & medical devices, clean technologies for green energy etc. - SEMI Europe GmbH, Germany

Comment #5
We develop and produce valves with high corrosion resistance. Our valves are used in various fields such as medical and analytical fields.

"The fluid control unit integrated particle counter is a device necessary for measuring samples using a particle counter, which is indispensable for quality control of semiconductor-related industries such as semiconductor manufacturers, semiconductor device manufacturers, and material manufacturers. Fluororesins and fluororubbers that are resistant to dust generation and corrosion are required. Currently, no alternative material exists. " - Anonymous, Japan

Comment #6
Lithography process is one of the most important processes in semiconductor production process for manufacturing Large Scale Integrated circuits (=LSI). Without this process, LSI cannot be made. We, Shin-Etsu provide the photo resist materials, EB resist materials, middle layer materials and under layer materials to semiconductor manufacturers and photo mask manufactures as our customers, in which PFAS are used for improving each performance.

If we cannot use PFAS, we will not be able to continue to provide lithography materials with same level’s performance. - Shin-Etsu Chemical Co. Ltd, Japan

Comment #7
PFAS possess various properties not found in other substances, such as heat resistance and chemical stability, and have therefore been used as essential materials in a wide range of applications including energy (fuel cells, lithium-ion batteries, etc.), semiconductor manufacturing, automotive components, machinery and devices of all kinds, telecommunications, healthcare, construction, and household goods. If the manufacture, placing on the market, and use of PFAS were to be uniformly banned, economies and societies could be severely impacted. - Keidanren (Japanese Business Federation), Japan

Want to learn more about PFAS regulations and their risk to you?

Join us on November 9, 2023 for a free webinar on PFAS. This webinar will take a close look at the latest updates on PFAS regulations in the United States and Europe, including the recent proposed 10,000+ PFAS ban in the EU. We’ll also explore where PFAS are in the manufacturing process and what parts of the supply chain could be affected by new and far-reaching regulations.

Webinar - PFAS Restrictions in Electronics: What You Need to Know

Thursday November 9, 2023 @ 11 am PDT (2 pm EDT)

Register here: https://tinyurl.com/2653wzm2

The webinar will be led by Mike Kirschner, a product environmental compliance expert with 20 years of engineering and engineering management experience at companies like Intel, Tandem Computers, and Compaq.

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