Addressing the Implications of the PFAS Ban on the Nuclear Industry

Sophie Dayraut, Communication & Advocacy Manager, nucleareurope

The nuclear industry faces a significant challenge with the proposed ban on per- and polyfluoroalkyl substances (PFAS). PFAS are a large class of thousands of synthetic chemicals that are used throughout society. They are commonly used in textiles, sealants, gaskets, lubricants, and many other applications. Their persistence in the environment and potential adverse health effects have raised concerns. On 13 January 2023, a dossier was submitted to the European Chemicals Agency (ECHA) by Denmark, Germany, the Netherlands, Norway, and Sweden, aiming to reduce PFAS emissions into the environment. Authorities estimate that without action, approximately 4.4 million tonnes of PFAS could enter the environment over the next three decades.  

With the potential restrictions proposed encompassing a wide range of PFAS compounds, the nuclear sector must identify their uses and collaborate to address this critical matter. 

Scope of the Ban 

The proposed ban targets substances containing fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atoms, excluding any attachments of hydrogen (H), chlorine (Cl), bromine (Br), or iodine (I). Unlike previous restriction proposals under the Regulation on the registration, evaluation, authorisation and restriction of chemicals (REACH), this ban covers an extensive array of PFAS, estimated to be between 5000 and 10000 compounds. These substances are known for their resistance to heat, water, and grease, making them valuable in various industrial applications. This is why the nuclear industry needs to understand where PFAS are used in the sector and map essential uses, as this persistence can be key for some applications. 

Restriction Options and Consultation Period 

Two restriction options were proposed to ECHA for consideration by the authorities who submitted the dossier. The first option, RO1, suggests a complete ban on PFAS with no derogations, proposing  a transition period of 18 months. The second option, RO2, also advocates for a full ban but allows for either a 5 or 12-year derogation, along with an 18-month transition period. Furthermore, a limited number of derogations without time constraints are included. ECHA has opened a 6-month consultation period, ending on 25 September 2023, during which stakeholders can provide information and feedback on the proposal. 

Importance of Providing Substantiated Information 

Downstream users, including the nuclear industry, bear the responsibility of providing information about the significance of specific PFAS uses. As the ban has the potential to impact a wide range of nuclear applications, it is crucial for the industry to thoroughly assess and identify the uses of PFAS within its operations. nucleareurope is collaborating with its members to submit a comprehensive response to the ECHA consultation substantiated by scientific data. By presenting well-supported arguments, the industry can effectively convey the importance of specific uses of PFAS and advocate for the necessary derogations or alternative solutions. 

Collaborative Efforts and Involvement of the Supply Chain 

To address this complex issue, nucleareurope plans to engage with all companies across the supply chain. By involving stakeholders, including suppliers, in the consultation process, nucleareurope aims to facilitate the collection of relevant data and insights. nucleareurope is also working with the European Chemical Industry Council (CEFIC) to comprehensively address the concerns associated with the PFAS ban. 

The proposed ban on PFAS poses a significant threat to the nuclear industry, with potential ramifications for its operations and processes. The consultation on the proposed ban on PFAS compounds presents a crucial opportunity for the nuclear industry to advocate for the necessary derogations and emphasise the concept of essential uses. By actively engaging in the consultation process and providing substantiated information backed by scientific data, we aim to secure derogations where needed. We need to ensure that the ban does not unintentionally hinder essential applications within the nuclear industry that currently lack viable alternatives or require additional time for transition. We hope to shape an outcome that recognises the essential uses of PFAS within the nuclear sector.