Global Electronics Association Submits Updated Position on ECHA PFAS Restrictions
By Diana Radovan, director of sustainability policy
Key Summary
• The Association submitted updated feedback to ECHA on the revised 2025 PFAS Draft Restriction Proposal
• The update responds to ECHA’s upcoming RAC opinion and draft SEAC opinion on PFAS restrictions
• Broad PFAS limits could significantly affect electronics manufacturing
• Functional-critical PFAS, including fluoropolymers, currently lack technically viable alternatives
• A proportionate, risk-based approach is needed to address essential PFAS use in electronics
With the European Chemicals Agency (ECHA) preparing its final Risk Assessment Committee opinion and draft Socio-Economic Analysis Committee opinion on the upcoming PFAS restriction, the Global Electronics Association has provided updated feedback on the revised 2025 Draft Restriction Proposal. The submission, directed to ECHA and the dossier submitters from Denmark, Germany, the Netherlands, France, and Sweden, outlines sector-wide concerns regarding the impact of broad PFAS restrictions on electronics manufacturing. A proportionate, risk-based approach is urgently needed to address the use of functional-critical PFAS in electronics, particularly fluoropolymers and other substances for which no technically viable alternatives currently exist.
Read the full position here. Contact: DianaRadovan@electronics.org
Because ECHA is finalizing key opinions on the PFAS restriction, and the revised 2025 proposal still raises concerns for electronics manufacturing. The Association provided updated feedback to ensure these impacts are clearly understood.
Broad restrictions may affect essential PFAS used in electronics manufacturing. These include functional-critical substances that remain necessary for sector operations and for which no technically viable alternatives exist.
Some PFAS, such as fluoropolymers, enable functions in electronics manufacturing that cannot currently be replicated by alternative materials. They remain essential because no technically viable substitutes are available.
The Association is urging a proportionate, risk-based regulatory approach that considers essential PFAS uses in electronics and avoids restricting substances that lack viable alternatives.
The submission was directed to ECHA and the dossier submitters from Denmark, Germany, the Netherlands, France, and Sweden, who are responsible for the PFAS restriction proposal.