TECHNOLOGY EXPLAINER
Fluoropolymers and PFAS
— used because they resist breaking down, and questioned for the same reason
The European Chemicals Agency (ECHA) describes PFAS as a group of substances that contain carbon–fluorine bonds and resist degradation both in use and in the environment. Fluoropolymers such as PTFE, PVDF, FEP and PFA fit that structural definition. The EU's PFAS restriction proposal includes fluoropolymers, but as of October 2026 the proposal is still being evaluated by ECHA's scientific committees; it has been neither adopted nor brought into force.
- What fluoropolymers and PFAS are (the short version)
- The fluoropolymer family: PTFE, FEP, PFA and PVDF
- A materials engineer's view (1): the melting point is not one number
- The numbers: manufacturers' stated values and test methods
- Our calculation: what happens 55 °C below the melting point
- A materials engineer's view (2): the C–F bond, and the double edge of "hard to break down"
- The manufacturing problem: from PFOA to HFPO-DA
- How PFAS is defined and where regulation stands: separating proposed, under evaluation and in force
- Should fluoropolymers be treated as "polymers"? Sorting out the debate
- A materials engineer's view (3): three layers to consider when thinking about alternatives
- Challenges and limits / Glossary / References / Claim-to-source audit
Sourced = a statement found in published material (link given)
Our calculation = a figure this article derived from stated assumptions
Not yet confirmed = a proposal, plan or outlook, for which adoption or a track record has not been confirmed
Structural readings and materials-design interpretations are marked separately as commentary.
Property values are given together with the test method, conditions and source, and a manufacturer's stated value is always identified as such.
This article neither recommends nor condemns any particular product or company. Regulation is described by stage: proposed, under evaluation, adopted, in force.
1. What fluoropolymers and PFAS are (the short version)
- What a fluoropolymer is: an OECD report defines a fluoropolymer as a polymer whose backbone is made of carbon alone, with fluorine atoms attached directly to it (a definition the report cites from Buck et al.)Sourced. PTFE, FEP, PFA and PVDF are typical examples.
- What PFAS are: the OECD definition (2021) covers fluorinated substances that contain at least one fully fluorinated methyl (–CF3) or methylene (–CF2–) carbon atom, with no H, Cl, Br or I attached to that carbonSourced. Under this definition PTFE, with its chain of –CF2– units, counts as a PFAS (applying the definition is our own reading).
- Where regulation stands: the EU restriction proposal includes fluoropolymers in its scope, the U.S. TSCA reporting rule has no polymer exemption, and Japan's Chemical Substances Control Law (CSCL) designates substances one by oneSourced. These are at different stages, which Section 8 sorts out.
The debate over fluoropolymers is not only about whether the polymer itself is harmful. There are broadly two issues: (1) whether the polymer can be assessed separately from other PFAS, and (2) how to treat emissions from making, using and disposing of the material, and whether alternatives exist. Unless the two are read separately, the arguments of supporters and regulators talk past each other (our summary).
2. The fluoropolymer family: PTFE, FEP, PFA and PVDF
Chemours explains that PTFE does not flow when heated, because of its linear orientation and extremely high molecular weight, so it is processed by special methods such as compression moulding, paste extrusion and dispersion coatingSourced [Reference 18]. FEP and PFA were therefore developed so that the polymer could be melt-processed; the company says the aim was to combine the performance of PTFE with the processing efficiency of thermoplasticsSourced. Arkema describes PVDF (Kynar) as a fluorinated thermoplastic homopolymer, with grades for extrusion, compression and transfer mouldingSourced [Reference 17].
3. A materials engineer's view (1): the melting point is not one number
The Chemours data for granular PTFE (PTFE 7A X) give the melting peak separately as 344 ± 10 °C on the first heating and 327 ± 10 °C on the second (ISO 12086 / ASTM D4894)Sourced [Reference 14]. ASTM D4591 (the DSC test method for transition temperatures and heats of transition of fluoropolymers) says that the DSC curve of PTFE that has never been melted gives meaningful information on its morphology and molecular structureSourced [Reference 20]. One reading is that once the polymer has melted and recrystallized, its crystal state changes, so the melting peak is lower on the next heating (our commentary).
The same material states that the properties of a moulded part depend on preforming pressure, sintering time and temperature, and cooling rateSourced. So the "melting point 327 °C" in a PTFE property table is a value for the raw powder, not a value that reflects the history of a moulded part. If you measure a moulded part by DSC, you must always check which heating run you are reading. We treat this issue, along with crystallization, melting point and glass transition, in our explainer on the glass transition and creep.
4. The numbers: manufacturers' stated values and test methods
The values below are for one specific grade each, taken from each company's technical material. The grades, specimens and test methods are not the same, so the table is not a ranking. A blank or "not in the material" means that the item does not appear in that company's document.
| Item | PTFE (Teflon PTFE 7A X) | FEP (Teflon FEP 100) | PFA (Teflon PFA 340) | PVDF (Kynar 740) |
|---|---|---|---|---|
| Category | Granular resin (ASTM D4894 Type II) | Melt-processable resin (ASTM D2116 Type I) | Melt-processable resin (ASTM D3307 Type I) | Pellets for extrusion, compression and transfer moulding |
| Melting point | First 344 ± 10 / second 327 ± 10 °C (ASTM D4894) | 260 °C (ASTM D4591 / D3418) | 305 °C (ASTM D4591) | 168 °C (ISO 11357-1/-3, 10 °C/min) |
| Density / specific gravity | Standard specific gravity 2.16 (ISO 12086 / ASTM D4894) | Specific gravity 2.14 (ASTM D792) | Specific gravity 2.15 (ASTM D792) | Density 1.77 to 1.79 g/cm³ (ISO 1183-1) |
| Tensile strength | 48.3 MPa (skived tape, 0.13 mm thick) | 26 MPa (23 °C, ASTM D638) | 25 MPa (23 °C) / 12 MPa (250 °C) | Yield stress 44.8 to 55.2 MPa (23 °C, ASTM D638) |
| Elongation at break | 375% | 300% (23 °C, ASTM D638) | 300% (23 °C) / 480% (250 °C) | Nominal strain at break above 50% (ISO 527-1/-2) |
| High-temperature indicators | Not in the material | Continuous service temperature 205 °C (defined below) | Continuous service temperature 260 °C (defined below) | Deflection temperature under load 105 °C (1.8 MPa, ISO 75-1/-2); glass transition temperature −40 °C (ISO 11357-1/-2) |
| Flame retardancy | Not in the material | UL94 V-0, limiting oxygen index above 95% | UL94 V-0, limiting oxygen index above 95% | V-0 (IEC 60695-11-10, 0.55 mm thick), limiting oxygen index 44% (ASTM D2863) |
| Dielectric | Not in the material | Dielectric constant 2.03 (1 kHz, 1 GHz, ASTM D150) | Dielectric constant 2.03 (1 MHz, ASTM D150) | Dielectric constant 11 (100 Hz), 8 (1 MHz) (IEC 62631-2-1) |
Chemours product material [References 14, 15 and 16] and the Arkema Kynar 740 technical data sheet [Reference 17]. All Sourced (manufacturers' stated or typical values; Chemours notes that typical values must not be used as specifications).
The Chemours material for FEP 100 and PFA 340 defines the continuous service temperature on the basis of accelerated heat-aging tests, as the temperature at which tensile strength and elongation at break retain 50% of their original values after 20,000 hours of thermal agingSourced. That is neither a melting point nor a deflection temperature under load. It measures something different from the 105 °C deflection temperature in the PVDF material. The "tensile strength" entries are likewise different: the FEP and PFA values are at 23 °C, the PTFE value is for a thin tape (0.13 mm), and the PVDF value is a yield stress. Even in the same "strength" row, the yardsticks are not matched.
The higher dielectric constant of PVDF than of FEP and PFA is said to be related to the polarity of the PVDF molecule (our commentary, based on general understanding). The 2.03 of PTFE, FEP and PFA and the 8 to 11 of PVDF are an example of how even "fluoropolymers" serve quite different uses.
5. Our calculation: what happens 55 °C below the melting point
From the 23 °C and 250 °C values in the Chemours PFA 340 material, we work out the ratiosOur calculation. The melting point in the same material is 305 °C, so 250 °C is 55 °C below it.
- Tensile strength: 12 MPa ÷ 25 MPa = 48%
- Flexural modulus: 55 MPa ÷ 590 MPa = 0.0932 = about 9.3% (about 1/11)
- Elongation at break: 480% ÷ 300% = 160%
Assumptions and limits: the three values are typical values for one grade, PFA 340, and do not apply to other grades or other resins. The material does not give the specimen or speed for each temperature, and the ratios use only two points, so changes at intermediate temperatures cannot be read from them.
Without even reaching the melting point (305 °C), the modulus drops to nearly a tenth. In design, the question is not "can it be used up to the melting point?" but what the modulus and creep are at the temperature of use. Chemours also says of PFA 340 that its creep resistance at high service temperatures offers a superior balance of properties compared with other fluoroplasticsSourced [Reference 16]. The material does not, however, name the resins compared or the conditions. We cover how to think about creep, and how to compare materials at matched temperature and time, in our explainer on the glass transition and creep.
6. A materials engineer's view (2): the C–F bond, and the double edge of "hard to break down"
In its explanation of PFAS, ECHA says that all of them contain carbon–fluorine bonds, which are among the strongest bonds in organic chemistry, and that this makes them resist degradation both in use and in the environment (our paraphrase)Sourced [Reference 1]. The features Chemours lists for fluoropolymers are chemical inertness, heat resistance, a low coefficient of friction, non-stick behaviour, very low water absorption and excellent weatherabilitySourced [References 14 to 16]. The PFA 340 material also gives a water absorption below 0.03% (24 h, ASTM D570) and a limiting oxygen index above 95% (ASTM D2863).
For a product, the value lies in "not degraded by chemicals" and "long-lasting." For regulators, the same property is the basis of the concern that the substance does not break down in the environment and keeps accumulating. ECHA's Committee for Risk Assessment (RAC) says that PFAS are highly persistent, remain in the environment for a long time, travel long distances and contaminate groundwater and soil, and that some have serious health effects such as cancer and reproductive effectsSourced [Reference 2]. What matters here is that this assessment is about "the group called PFAS"; it does not say that individual fluoropolymer products directly harm their users. The assessment of the polymers themselves is debated, and Section 9 sorts out that debate.
From the materials-design side, durability and degradability are a trade-off. Designs that build in degradability (for example, epoxies that are easier to recycle thanks to a degradable curing agent) have been studied for other resins, but within the scope of this article we could not confirm from primary sources a design that cuts the C–F bond of a fluoropolymer under mild conditions (our commentary).
7. The manufacturing problem: from PFOA to HFPO-DA
Some fluoropolymers are made by emulsion polymerization in water, and fluorinated surfactants (polymerization aids) have been used in the process. ECHA says that HFPO-DA (including its salts) is used as a processing aid in the manufacture of fluoropolymers (resins, wires and cables, coatings and others)Sourced [Reference 7]. The ammonium salt of HFPO-DA is commonly called GenX (ECHA's dedicated page refers to the decision that identified GenX as a substance of very high concern). It is often cited as an example of a "new" polymerization aid replacing older PFAS, but that characterization is our own.
| Year | Event | Stage |
|---|---|---|
| 2010 / 2015 | The EPA's PFOA Stewardship Program. It asked eight companies, Arkema, Asahi, BASF, Clariant, Daikin, 3M/Dyneon, DuPont and Solvay Solexis, to cut facility emissions and product content by 95% by 2010 and to work towards eliminating emissions and content by 2015 | Voluntary programme (target years have passed) |
| May 2019 | The Conference of the Parties (COP-9) to the Stockholm Convention listed PFOA in Annex A (elimination) (decision SC-9/12). Individual exemptions follow the provisions of the annex | Adopted (convention) |
| June 2019 | ECHA's Member State Committee unanimously identified HFPO-DA as a substance of very high concern (SVHC). The reasons were a combination of persistence, mobility in water, accumulation in plants and potential for long-range transport | Identified (placed on the SVHC Candidate List) |
| October 2021 | In Japan, PFOA or its salts were designated Class I Specified Chemical Substances under the CSCL and the designation took effect (22 October 2021). Thirteen import-prohibited products were specified | In force |
All Sourced (EPA [Reference 9], Stockholm Convention Secretariat [Reference 8], ECHA [Reference 7], Ministry of the Environment [Reference 12]).
The review by Lohmann et al. (2020, peer-reviewed) says that the production of some fluoropolymers is closely tied to the use of legacy and novel PFAS as polymerization processing aidsSourced [Reference 23]. On the other hand, the summary of the EU restriction proposal sets out emission limits for fluoropolymer manufacture whether the polymerization aid used is fluorinated or non-fluorinatedNot yet confirmed [Reference 5].
The summary of the proposal by the five national authorities proposes that, where polymerization aids are used in fluoropolymer manufacture, PFAS emissions be no more than 0.0036% of annual production (from the end of 2030)Not yet confirmed. We turn this into an actual quantityOur calculation.
- Assumption: a site produces 10,000 tonnes a year (not the figure of any real plant)
- 10,000 t × 0.0036% = 10,000 × 0.000036 = 0.36 t/year (360 kg/year)
- For reference, under the general manufacturing proposal (0.01% of annual production, from 6.5 years after the restriction enters into force), the same assumption gives 10,000 × 0.0001 = 1 t/year
Assumptions and limits: these values are conditions in the restriction proposal and have not been adopted. The final values may change with the committees' evaluation and the European Commission's decision. We have also not checked the details of how "annual production" is counted (which substances and which sites are covered).
A technical data sheet lists product properties such as melting point, strength and dielectric constant. One of the regulatory issues, however, lies in what leaves the process, not what stays in the product. Both the phase-out of PFOA and the identification of HFPO-DA concerned "content in products" and "emissions during manufacture" (the EPA programme named both as goals). Beyond the property table, anyone choosing a material now has to check which polymerization aid the supplier uses and how it controls emissions (our commentary).
8. How PFAS is defined and where regulation stands: separating proposed, under evaluation and in force
"PFAS regulation" means something different in each region. To begin with, what counts as a PFAS differs.
| Region / body | Definition of PFAS (or unit of regulation) | Treatment of fluoropolymers |
|---|---|---|
| OECD (2021) / EU restriction proposal | A substance with at least one fully fluorinated methyl (–CF3) or methylene (–CF2–) carbon atom, with no H, Cl, Br or I bonded to that carbon. The background document of the EU proposal uses the same definition | Included in the scope of the proposal. The scope covers both "non-polymers" (for example perfluoroalkyl carboxylic acids) and "polymers" (for example fluoropolymers and perfluoropolyethers) |
| U.S. EPA (TSCA 8(a)(7)) | A structural definition (40 CFR 705.3). A substance with any of three substructures: (1) R-(CF2)-CF(R′)R″ (CF2 and CF are saturated carbons), (2) R-CF2OCF2-R′, (3) CF3C(CF3)R′R″ | Asked whether fluoropolymers are exempt, the EPA's Q&A answers that they are not, because this rule has no polymer exemption (November 2024 edition) |
| Japan (CSCL) | Not a group called PFAS: substances are designated individually (for example PFOA or its salts) | Within the scope of this article, we found no regulation by a "fluoropolymer" category (regulation is by individual substance) |
All Sourced (OECD [Reference 6], summary by the five authorities [Reference 5], EPA Q&A [Reference 11], Ministry of the Environment [References 12 and 13]). Describing Japan's approach as "designation by individual substance" is our commentary, read from the wording of the Ministry's announcements.
EU: the restriction proposal is "proposed and under evaluation"
- Proposal: prepared by the authorities of the Netherlands, Germany, Denmark, Norway and Sweden, and submitted to ECHA on 13 January 2023. A consultation ran from 22 March to 25 September 2023 and drew more than 5,600 commentsSourced [References 1 and 4].
- Update: on 20 August 2025 the five authorities published an updated version (Background Document). It added assessments of eight further sectors (printing, sealing, machinery, other medical uses, military, explosives, technical textiles, and a broad group of industrial uses including solvents and catalysts)Sourced [Reference 4].
- Restriction options: according to the summary of the update, three options were evaluated sector by sector: (RO1) a full ban; (RO2) a ban with time-limited derogations (6.5 or 13.5 years); and (RO3) continued use under strict emission limits. For sectors where alternatives are likely to be found, the proposal allows no derogation beyond 18 months after entry into force. For the sectors assessed, the five authorities consider RO2 preferable to a full ban. Emission reductions are estimated at 83% for RO2 and about 96% for a full banNot yet confirmed [Reference 5].
- Estimated quantities: the five authorities estimate that about 190,000 to 340,000 tonnes of PFAS were placed on the European Economic Area (EEA) market in 2020, of which 84,000 to 199,000 tonnes were polymeric PFAS (mainly fluoropolymers) (estimates by the authorities)Sourced [Reference 5].
- Committee evaluation: the RAC adopted its final opinion (adopted on 2 March, announced by ECHA on 3 March). The Committee for Socio-economic Analysis (SEAC) agreed its draft opinion on 10 March of the same year, published it on 26 March and ran a consultation until 25 May. ECHA states that both committees support an EU-wide restriction with appropriate derogationsSourced [References 2 and 3].
- Next steps: SEAC is expected to adopt its final opinion by the end of 2026, after which the opinions go to the European Commission. The Commission then makes a restriction proposal, which is discussed and voted on in the REACH Committee (Member States)Not yet confirmed [Reference 2].
The lengths of derogation in the proposal (6.5 and 13.5 years), the emission limits (0.01% and 0.0036%) and the treatment of each sector are the proposal of the five national authorities that submitted it. We have not confirmed how the RAC and SEAC opinions treat individual periods and sectors. ECHA's announcement says the committees support a restriction with targeted derogations, and this article stays within that. ECHA's dedicated page also carries the results of a consultation dated 3 June 2026 and the main points of the 11 June SEAC meeting, but we have not checked their content. The final scope and transition periods will be decided by the European Commission's proposal and the vote that follows.
United States: the reporting rule is "finalized", its revision is "proposed"
- On 11 October 2023 the EPA finalized its reporting and recordkeeping rule for PFAS under TSCA section 8(a)(7). It covers PFAS manufactured (including imported) for commercial purposes since 1 January 2011, and information on use, production volume, disposal, exposure and hazard is reported electronicallySourced [References 10 and 11].
- According to the EPA's page, an interim final rule of May 2025 set the submission deadline at 13 October 2026 (13 April 2027 for small businesses that import PFAS only as part of articles). A proposal of November 2025 would exempt mixtures and products at a concentration of 0.1% or less, imported articles, certain by-products and impurities, research and development chemicals, non-isolated intermediates and others, and a final rule is expected in 2026Not yet confirmed [Reference 10].
- The EPA's 2010/2015 PFOA Stewardship Program is in the table in Section 7 [Reference 9].
Japan: designation of individual substances
- PFOA or its salts were designated Class I Specified Chemical Substances under the CSCL on 22 October 2021, following a Cabinet decision on 16 April 2021. Thirteen import-prohibited products were specified, and fire extinguishers, extinguishing agents and foam extinguishing agents must comply with national technical standardsSourced [Reference 12].
- A later cabinet order added branched isomers of PFOA or their salts and PFOA-related substances as Class I Specified Chemical Substances. According to the Ministry of the Environment, the order takes effect in stages: 10 September 2024 (branched isomers) and 10 January 2025 (related substances, import-prohibited products and so on)Sourced [Reference 13].
9. Should fluoropolymers be treated as "polymers"? Sorting out the debate
Fluoropolymers are high-molecular-weight solids that barely dissolve in water. So there is an ongoing debate over whether they can be handled in the same way as other PFAS (such as low-molecular-weight surfactants). Below, three positions from peer-reviewed papers are set out as claims only.
| Paper | Main claim (summary) | Note |
|---|---|---|
| Henry et al. (2018, IEAM) | Fluoropolymers are thermally, chemically, photolytically, hydrolytically, oxidatively and biologically stable, with little residual monomer or oligomer. With molecular weights far above 100,000, they cannot pass through cell membranes. They meet the criteria for "polymers of low concern" (PLC) and should be assessed and regulated separately from other PFAS. "Read across" from other PFAS is not scientifically appropriate | The authors include an affiliate of a company that uses fluoropolymers (W. L. Gore) |
| Korzeniowski et al. (2023, IEAM) | Concludes that 14 fluoropolymers (fluoroplastics and fluoroelastomers) meet the PLC criteria, and, together with Henry et al., states that the commercial fluoropolymers of the seven participating companies account for about 96% of the global commercial fluoropolymer market. They fit the structural definition of PFAS but differ greatly from other PFAS in their properties | A study involving the "seven participating companies" |
| Lohmann et al. (2020, ES&T) | Having assessed impacts across the whole life cycle, the review finds no scientific rationale for concluding that fluoropolymers are of low concern for environmental and human health. The production of some fluoropolymers is tied to the use of legacy and novel PFAS as polymerization processing aids, and other PFAS such as monomers and oligomers are released during production, processing, use and disposal. Options for recycling from consumer products are limited. Production and uses should be curtailed except for essential uses | A review in the peer-reviewed journal Environmental Science & Technology |
All Sourced (abstracts of each paper [References 21, 22 and 23]). The market share is the authors' own statement, not an estimate by a market research firm, and it has not been verified by a third party.
The three claims do not so much contradict one another as look at different things (our summary; it does not support any one of them).
- The product (the polymer) as the unit: looking at properties such as high molecular weight, insolubility and lack of bioavailability, one can say fluoropolymers differ from low-molecular-weight PFAS. This is the position of Henry et al. and Korzeniowski et al.
- The life cycle as the unit: looking at what lies outside the product, such as polymerization aids, monomers, oligomers, behaviour on incineration and disposal, and the difficulty of recycling, fluoropolymers cannot be separated from PFAS emissions. This is the position of Lohmann et al.
The stance of regulators so far appears closer to the latter. The EU proposal includes polymers in its scope and then provides derogations for uses without alternatives. The EPA reporting rule does not exempt polymers. From the materials side, the starting point for reading technical documents and regulatory news is to separate the debate over whether it is safe as a polymer from the debate over managing the process through to disposal (our commentary).
10. A materials engineer's view (3): three layers to consider when thinking about alternatives
The phrase "an alternative to fluoropolymers" actually covers three different layers. Unless you separate which layer is being discussed, the arguments "alternatives exist" and "alternatives do not exist" pass each other by (our summary).
| Layer | What is replaced | What can be confirmed from public material |
|---|---|---|
| 1. Process | Change how it is made, for example the polymerization aid | The summary of the five authorities' proposal refers to the polymerization aids used in fluoropolymer manufacture as being either fluorinated or non-fluorinated and proposes emission limits [Reference 5]. 3M announced in December 2022 that it would exit PFAS manufacturing by the end of 2025 [Reference 24] (we have not confirmed what has happened since) |
| 2. Material | Replace it with a material other than a fluoropolymer | The five authorities propose a 13.5-year derogation for fluoropolymers in seals, lubricants and batteries, citing that development of alternatives has in many cases not yet begun, and they also state that uncertainty is high [Reference 5] (proposal stage). As a product-level example, Mitsubishi Gas Chemical has published a transparent polyimide varnish containing no fluorine (PFAS-free) [Reference 25] (manufacturer's statement) |
| 3. Design and operation | Change how it is used and disposed of (narrowing uses, recovery and recycling) | Lohmann et al. say production and uses should be curtailed except for essential uses, while noting that options for recycling from consumer products are limited [Reference 23]. ECHA's committees recommend management measures to minimize emissions (a PFAS management plan for each site, emission monitoring and so on) [Reference 2] |
What often happens when looking for substitutes is that people search for candidates with a vague requirement such as "fluoropolymer-like properties." As the table in Section 4 shows, even among "fluoropolymers" the melting point ranges from 168 °C to 344 °C and the dielectric constant from 2.03 to 11. The candidates change greatly depending on which items are truly essential (our commentary).
- Temperature: continuous service temperature, or a short-term maximum? What are the modulus and creep at the temperature of use (Section 5)?
- Chemicals: which chemicals, at what concentration, temperature and duration of exposure?
- Friction and non-stick behaviour: what is the target coefficient of friction, and how much wear is acceptable?
- Electrical: what are the target dielectric constant and dissipation factor, and at what frequency?
- Purity and extractables: what level of metal, ion or organic extractables is acceptable in semiconductor or food uses?
- Regulation and certification: how much certification (food contact, medical, automotive) would have to be redone if the material is changed?
Chemours too says that choosing a material is a question not of which is better but of which fits the application, and lists as deciding factors service temperature, chemical exposure and permeation limits, mechanical stress and flex life, processing method and production scale, and surface finish and puritySourced [Reference 18]. A realistic starting point is to line up the alternative candidates on the same items, by the same test methods and conditions.
11. Challenges and limits
- Regulation is moving: for the EU proposal, SEAC's final opinion by the end of 2026, the European Commission's proposal and the REACH Committee vote are still to come. This article reflects what could be confirmed on 2 October 2026 and may change afterwards.
- The EU numbers are "the proposers' proposal": the length of derogations, emission limits and treatment of each sector are the proposal as submitted. They are not necessarily the same as the final regulation.
- Other regions and other rules: this article covers only part of the EU (REACH), the United States (the TSCA reporting rule) and Japan (the CSCL). It does not cover U.S. state laws, drinking water standards, CERCLA, the EU Drinking Water Directive or Packaging Regulation, or PFOS and PFHxS.
- Limits of the property values: Section 4 gives typical values for one grade from each company. Because grades, specimens and test methods differ, the size of the numbers does not show which material is better.
- Health and environmental assessment is a specialist field: this article sets out regulators' announcements and the claims of peer-reviewed papers. It does not assess the safety of any individual product. Some of the papers on the low concern of polymers involved companies, and others did not.
- Not covered here: substances produced by the thermal decomposition of PTFE, behaviour on disposal (incineration, landfill), fluoroelastomers and fluorinated lubricants, and fluoropolymer recycling technology.
12. Glossary
- Fluoropolymer
- A polymer with a carbon-only backbone to which fluorine is attached directly (PTFE, FEP, PFA, PVDF and others).
- PFAS
- Under the OECD definition, a fluorinated substance with a fully fluorinated methyl or methylene carbon. A group containing thousands of substances.
- PTFE
- Polytetrafluoroethylene. It does not flow even when melted, so it is processed by methods such as compression moulding and sintering.
- FEP / PFA
- Melt-processable fluoropolymers. FEP is a copolymer of TFE and hexafluoropropylene.
- PVDF
- Polyvinylidene fluoride. A thermoplastic whose glass transition temperature is below room temperature (−40 °C for Kynar 740).
- Polymerization aid
- A processing aid such as a surfactant used in emulsion polymerization. A substance of the process, not a component of the product.
- PFOA
- Perfluorooctanoic acid. Used as a legacy polymerization aid and regulated under the Stockholm Convention and Japan's CSCL.
- HFPO-DA (GenX)
- A substance used as a processing aid in fluoropolymer manufacture. Identified as an SVHC by ECHA in 2019.
- REACH / ECHA
- The EU chemicals regulation and the European Chemicals Agency that administers it.
- RAC / SEAC
- ECHA's two scientific committees. The RAC handles risk assessment and SEAC handles socio-economic analysis.
- SVHC
- Substance of very high concern. Placed on the REACH Candidate List, which creates obligations such as providing information to customers.
- TSCA 8(a)(7)
- The PFAS reporting and recordkeeping rule under the U.S. Toxic Substances Control Act. It has no polymer exemption.
- CSCL
- Japan's Chemical Substances Control Law. Class I Specified Chemical Substances are, in principle, banned from manufacture and import.
13. References
- European Chemicals Agency (ECHA) "Per- and polyfluoroalkyl substances (PFAS)" hot-topic page (including a chronological list) — https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas
- ECHA "ECHA supports PFAS restriction with targeted derogations", 26 March 2026 — https://echa.europa.eu/-/echa-supports-pfas-restriction-with-targeted-derogations
- ECHA "ECHA's Risk Assessment Committee adopts its opinion on PFAS restriction proposal", 3 March 2026 — https://echa.europa.eu/-/echa-s-risk-assessment-committee-adopts-its-opinion-on-pfas-restriction-proposal
- ECHA "ECHA publishes updated PFAS restriction proposal", 20 August 2025 — https://echa.europa.eu/-/echa-publishes-updated-pfas-restriction-proposal
- KemI (Swedish Chemicals Agency) and the other four national authorities "What you need to know about the updated PFAS restriction dossier" (updated October 2025, PDF, summary of the background document) — https://www.kemi.se/publikationer/rapporter-fran-samarbetsprojekt/2025/what-you-need-to-know-about-the-updated-pfas-restriction-dossier
- OECD "Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances", Series on Risk Management No. 61 (2021, PDF) — https://www.oecd.org/content/dam/oecd/en/publications/reports/2021/07/reconciling-terminology-of-the-universe-of-per-and-polyfluoroalkyl-substances_a7fbcba8/e458e796-en.pdf
- ECHA "MSC unanimously agrees that HFPO-DA is a substance of very high concern", 27 June 2019 — https://echa.europa.eu/-/msc-unanimously-agrees-that-hfpo-da-is-a-substance-of-very-high-concern
- Secretariat of the Stockholm Convention "Information on the 16 chemicals added to the Stockholm Convention" — https://www.pops.int/TheConvention/ThePOPs/TheNewPOPs/tabid/2511/Default.aspx
- U.S. Environmental Protection Agency (EPA) "Fact Sheet: 2010/2015 PFOA Stewardship Program" — https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship-program
- U.S. EPA "TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances" — https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping
- U.S. EPA "TSCA 8(a)(7) Rule: Reporting and Recordkeeping Requirements for PFAS Q&As", November 2024 edition (PDF) — https://www.epa.gov/system/files/documents/2024-12/tsca-8a7-pfas-faqs_nov2024.pdf
- Ministry of the Environment, Japan Announcement of the Cabinet decision on the cabinet order partially amending the Order for Enforcement of the Chemical Substances Control Law (PFOA, April 2021; in Japanese) — https://www.env.go.jp/press/109478.html
- Ministry of the Environment, Japan Announcement of the amendment of the Order for Enforcement of the Chemical Substances Control Law (branched isomers and related substances of PFOA, 2024; in Japanese) — https://www.env.go.jp/press/press_03409.html
- Chemours "Teflon™ PTFE 7A X" product information (March 2020, PDF) — https://www.teflon.com/en/-/media/files/teflon/teflon-ptfe-7a-x-product-info.pdf?rev=8857d802e22f4b08b7b68b7ef9da7b3d&hash=B453CCA54062515E454FD2598269C554
- Chemours "Teflon™ FEP 100" product information (PDF) — https://www.teflon.com/en/-/media/files/teflon/teflon-fep-100-product-info.pdf?rev=c37d94036ad04b33a7a44325ac07a3c1&hash=15E3B14B9236C1F52CE5FE80CFF6C8C4
- Chemours "Teflon™ PFA 340" product information (PDF) — https://www.teflon.com/en/-/media/files/teflon/teflon-pfa-340-product-info.pdf?rev=82238a0cd6af4b1dbd58e991fd8cc86d&hash=0055785638604E72525F1DB841F28F11
- Arkema "KYNAR® 740" technical data sheet (PDF) — https://hpp.arkema.com/assets/arkema/TDS_KYNAR%C2%AE%20740_en_WW.pdf
- Chemours "Fluoropolymers 101: PTFE, FEP, PFA, and ETFE Explained", 5 August 2026 — https://www.teflon.com/en/insights/all-insights/fluoropolymers-101
- ASTM International "ASTM D4894-15 Standard Specification for Polytetrafluoroethylene (PTFE) Granular Molding and Ram Extrusion Materials" — https://store.astm.org/d4894-15.html
- ASTM International "ASTM D4591-07(2012) Standard Test Method for Determining Temperatures and Heats of Transitions of Fluoropolymers by Differential Scanning Calorimetry" — https://store.astm.org/d4591-07r12.html
- Henry BJ et al. "A critical review of the application of polymer of low concern and regulatory criteria to fluoropolymers", Integr Environ Assess Manag 2018;14:316-334 (DOI: 10.1002/ieam.4035, PubMed) — https://pubmed.ncbi.nlm.nih.gov/29424474/
- Korzeniowski SH et al. "A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers", Integr Environ Assess Manag 2023;19:326-354 (DOI: 10.1002/ieam.4646, PubMed) — https://pubmed.ncbi.nlm.nih.gov/35678199/
- Lohmann R et al. "Are Fluoropolymers Really of Low Concern for Human and Environmental Health and Separate from Other PFAS?", Environ Sci Technol 2020 (DOI: 10.1021/acs.est.0c03244, PMC) — https://pmc.ncbi.nlm.nih.gov/articles/PMC7700770/
- 3M "3M to Exit PFAS Manufacturing by the End of 2025", 20 December 2022 — https://news.3m.com/2022-12-20-3M-to-Exit-PFAS-Manufacturing-by-the-End-of-2025
- Mitsubishi Gas Chemical Company "Neopulim™ (Transparent polyimide varnish)" product page — https://www.mgc.co.jp/eng/products/ac/neopulim.html
14. Claim-to-source audit
| Claim in the text | Basis | Label |
|---|---|---|
| The definition of PFAS (a substance with at least one fully fluorinated methyl or methylene carbon atom), and that a fluoropolymer is a polymer with a carbon-only backbone to which fluorine is attached directly (the definition of Buck et al., as cited) | OECD report (2021)Reference 6 https://www.oecd.org/content/dam/oecd/en/publications/reports/2021/07/reconciling-terminology-of-the-universe-of-per-and-polyfluoroalkyl-substances_a7fbcba8/e458e796-en.pdf | Sourced |
| That the PFAS definition in the EU background document is consistent with the OECD's, and that fluoropolymers are within the scope. EEA market placement in 2020 of about 190,000 to 340,000 tonnes, of which polymers (mainly fluoropolymers) 84,000 to 199,000 tonnes. Restriction options RO1, RO2 and RO3, the lengths of derogation (6.5 and 13.5 years), 18 months for sectors with likely alternatives, emission reductions of 83% and about 96%. A manufacturing emission limit of 0.01% (after 6.5 years) and 0.0036% for fluoropolymer manufacture with polymerization aids (from the end of 2030). A proposed 13.5-year derogation for fluoropolymers in seals, lubricants and batteries (with a statement that uncertainty is high) | Summary by the five national authorities (updated October 2025)Reference 5 https://www.kemi.se/publikationer/rapporter-fran-samarbetsprojekt/2025/what-you-need-to-know-about-the-updated-pfas-restriction-dossier | Not yet confirmed |
| That the proposal was submitted to ECHA on 13 January 2023, that a consultation ran from 22 March to 25 September 2023, and that more than 5,600 comments were received. The chronology on ECHA's hot-topic page (items for August 2025, March 2026 and 3 and 11 June) | ECHA hot-topic pageReference 1 https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas | Sourced |
| The publication of the updated version on 20 August 2025, the eight newly assessed sectors, and the sectors assessed for alternative restriction options | ECHA news (20 August 2025)Reference 4 https://echa.europa.eu/-/echa-publishes-updated-pfas-restriction-proposal | Sourced |
| The RAC's final opinion (announced 3 March), SEAC's draft opinion, the consultation (until 25 May). That both committees support an EU-wide restriction with derogations. That the RAC recommends measures to minimize emissions. That SEAC's final opinion is expected by the end of 2026. The procedure of a European Commission proposal and a REACH Committee vote. The RAC adoption on 2 March and the SEAC agreement on 10 March | ECHA news (26 March 2026)Reference 2 https://echa.europa.eu/-/echa-supports-pfas-restriction-with-targeted-derogations | Not yet confirmed |
| The adoption of the RAC opinion (announced by ECHA on 3 March 2026) and the subsequent SEAC procedure | ECHA news (3 March 2026)Reference 3 https://echa.europa.eu/-/echa-s-risk-assessment-committee-adopts-its-opinion-on-pfas-restriction-proposal | Sourced |
| That HFPO-DA was unanimously identified as an SVHC by the Member State Committee on 27 June 2019, that it is used as a processing aid in fluoropolymer manufacture, and the reasons for the identification | ECHA news (27 June 2019)Reference 7 https://echa.europa.eu/-/msc-unanimously-agrees-that-hfpo-da-is-a-substance-of-very-high-concern | Sourced |
| That PFOA was listed in Annex A at COP-9 in 2019 (decision SC-9/12). Individual exemptions follow the provisions of the annex | Stockholm Convention SecretariatReference 8 https://www.pops.int/TheConvention/ThePOPs/TheNewPOPs/tabid/2511/Default.aspx | Sourced |
| The eight participants in the 2010/2015 PFOA Stewardship Program, the 95% reduction by 2010, and the goal of elimination by 2015 | EPA fact sheetReference 9 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/fact-sheet-20102015-pfoa-stewardship-program | Sourced |
| The finalization of TSCA 8(a)(7) (11 October 2023), the submission deadline (13 October 2026; 13 April 2027 for small article importers), the proposal of November 2025 to add exemptions, and that a final rule is expected in 2026 | EPA pageReference 10 https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping | Not yet confirmed |
| The structural definition under TSCA 8(a)(7) (three substructures in 40 CFR 705.3). That the answer to "Are fluoropolymers exempt?" is no, because there is no polymer exemption. That PFAS manufactured (including imported) since 1 January 2011 are covered | EPA Q&A (November 2024 edition)Reference 11 https://www.epa.gov/system/files/documents/2024-12/tsca-8a7-pfas-faqs_nov2024.pdf | Sourced |
| That PFOA or its salts were designated Class I Specified Chemical Substances under the CSCL with effect from 22 October 2021 (Cabinet decision 16 April 2021), the 13 import-prohibited products, and the technical standards for fire extinguishers and similar | Announcement by the Ministry of the Environment (2021)Reference 12 https://www.env.go.jp/press/109478.html | Sourced |
| The designation of branched isomers and related substances of PFOA, and the staged entry into force on 10 September 2024 and 10 January 2025 | Announcement by the Ministry of the Environment (2024)Reference 13 https://www.env.go.jp/press/press_03409.html | Sourced |
| PTFE 7A X standard specific gravity 2.16, tensile strength 48.3 MPa (skived tape 0.13 mm), elongation at break 375%, melting peaks (first 344 ± 10 °C, second 327 ± 10 °C), conformity to ASTM D4894 Type II. That the properties of a moulded part depend on preforming pressure, sintering time and temperature, and cooling rate | Chemours PTFE 7A X product informationReference 14 https://www.teflon.com/en/-/media/files/teflon/teflon-ptfe-7a-x-product-info.pdf?rev=8857d802e22f4b08b7b68b7ef9da7b3d&hash=B453CCA54062515E454FD2598269C554 | Sourced |
| FEP 100 specific gravity 2.14, tensile strength 26 MPa, elongation 300%, melting point 260 °C, continuous service temperature 205 °C (defined as the temperature at which tensile strength and elongation retain 50% after 20,000 hours of thermal aging), UL94 V-0, limiting oxygen index above 95%, dielectric constant 2.03, and that it is a copolymer of TFE and hexafluoropropylene | Chemours FEP 100 product informationReference 15 https://www.teflon.com/en/-/media/files/teflon/teflon-fep-100-product-info.pdf?rev=c37d94036ad04b33a7a44325ac07a3c1&hash=15E3B14B9236C1F52CE5FE80CFF6C8C4 | Sourced |
| PFA 340 specific gravity 2.15, tensile strength 25 MPa (23 °C) and 12 MPa (250 °C), elongation 300% and 480%, flexural modulus 590 MPa and 55 MPa, melting point 305 °C, continuous service temperature 260 °C, water absorption below 0.03%, limiting oxygen index above 95%, dielectric constant 2.03 (1 MHz), and the statement on creep resistance at high temperature | Chemours PFA 340 product informationReference 16 https://www.teflon.com/en/-/media/files/teflon/teflon-pfa-340-product-info.pdf?rev=82238a0cd6af4b1dbd58e991fd8cc86d&hash=0055785638604E72525F1DB841F28F11 | Sourced |
| Kynar 740 density 1.77 to 1.79 g/cm³, melting point 168 °C (ISO 11357-1/-3, 10 °C/min), glass transition temperature −40 °C, deflection temperature under load 105 °C (1.8 MPa), yield stress 44.8 to 55.2 MPa, nominal strain at break above 50%, limiting oxygen index 44%, dielectric constant 11 (100 Hz) and 8 (1 MHz), and that it is for extrusion, compression and transfer moulding | Arkema Kynar 740 technical data sheetReference 17 https://hpp.arkema.com/assets/arkema/TDS_KYNAR%C2%AE%20740_en_WW.pdf | Sourced |
| That PTFE does not flow when heated and is processed by special methods, that FEP and PFA have the advantage of melt processing, and the factors for choosing a material | Chemours Fluoropolymers 101 (5 August 2026)Reference 18 https://www.teflon.com/en/insights/all-insights/fluoropolymers-101 | Sourced |
| The scope of ASTM D4894 for PTFE (a homopolymer of tetrafluoroethylene, or a modified material containing no more than 1% by weight of other fluorinated monomers) | ASTM D4894-15Reference 19 https://store.astm.org/d4894-15.html | Sourced |
| That ASTM D4591 is a DSC test method for transition temperatures and heats of transition of fluoropolymers, and that the DSC curve of never-melted PTFE gives information on morphology | ASTM D4591-07(2012)Reference 20 https://store.astm.org/d4591-07r12.html | Sourced |
| The claim that fluoropolymers meet the PLC criteria and should be assessed and regulated separately from other PFAS (Henry et al.), and that the authors include an affiliate of W. L. Gore | Henry et al. (2018)Reference 21 https://pubmed.ncbi.nlm.nih.gov/29424474/ | Sourced |
| The claim that 14 fluoropolymers meet the PLC criteria, and the authors' statement that the commercial fluoropolymers of the seven participating companies account for about 96% of the market (Korzeniowski et al.) | Korzeniowski et al. (2023)Reference 22 https://pubmed.ncbi.nlm.nih.gov/35678199/ | Sourced |
| The finding that there is no scientific rationale for concluding that fluoropolymers are of low concern; the link to polymerization aids; the limited options for recycling; and the claim that production and uses should be curtailed except for essential uses (Lohmann et al.) | Lohmann et al. (2020)Reference 23 https://pmc.ncbi.nlm.nih.gov/articles/PMC7700770/ | Sourced |
| That 3M announced on 20 December 2022 that it would exit PFAS manufacturing by the end of 2025 | 3M newsroomReference 24 https://news.3m.com/2022-12-20-3M-to-Exit-PFAS-Manufacturing-by-the-End-of-2025 | Sourced |
| That the manufacturer describes Neopulim S100 / S200 as containing no fluorine (PFAS-free) | Mitsubishi Gas Chemical Neopulim product pageReference 25 https://www.mgc.co.jp/eng/products/ac/neopulim.html | Sourced |
| The share of the 23 °C value that the PFA 340 value at 250 °C represents (tensile strength 48%, flexural modulus about 9.3%, or about 1/11, elongation at break 160%). For a hypothetical site producing 10,000 t a year, 0.0036% is 0.36 t/year and 0.01% is 1 t/year | Our calculation, based on typical values for one grade, PFA 340, and the assumed annual production of 10,000 t. The emission-limit values are a proposal and have not been adopted. The ratios compare two points and do not show changes at intermediate temperatures | Our calculation |
| The explanation that PVDF's higher dielectric constant relates to molecular polarity, the explanation of why the melting point changes with thermal history, the point that the material's strengths and the regulatory concern come from the same property, the three-layer breakdown of alternatives, the "unit of assessment" breakdown, the reading that polymerization aids do not appear in a property table, and how Figs. 1, 2, 3, 5 and 6 are drawn | Our summary and commentary based on published content. Not views expressed by the companies or institutions | Commentary |
| The characterization of Japan's CSCL as a system that designates individual substances rather than a PFAS group | Our reading of the wording of the Ministry of the Environment announcements | Commentary |
| The final scope, derogations and transition periods of the EU restriction, the content of the final rule adding U.S. exemptions, the content of SEAC's final opinion, and the content of the June 2026 items on ECHA's hot-topic page | Not stated, because they go beyond what could be confirmed at the time of research for this article (2 October 2026) and will be decided in later procedures | Not yet confirmed |
| Regulation of PFOS and PFHxS, U.S. state laws, drinking water standards and CERCLA, the EU Drinking Water Directive and Packaging Regulation, PTFE thermal decomposition products, fluoropolymer recycling technology, and what has happened since 3M's announced exit | Not stated, because they were not checked within the scope of this article | Commentary |
| That Figs. 1, 2, 3, 5 and 6 are explanatory drawings, and that the hero image and Fig. 4 are AI-generated images | Note by this article | Commentary |
Last updated 2 October 2026. Sources are limited to primary material (announcements by regulators, convention secretariats, manufacturers' product material and technical data sheets, peer-reviewed papers, and public information from standards bodies). Regulation is described by stage: proposed, under evaluation, adopted and in force. As of October 2026 the EU restriction proposal is at the stage where the committees are evaluating the proposal, and its final content has not been decided. Property values are manufacturers' stated or typical values for one grade each, given with test method, conditions and source, and no ranking is made. The final content of the EU restriction, the final rule adding U.S. exemptions, regulation of other substances such as PFOS and PFHxS, drinking water standards and fluoropolymer recycling technology are not stated here because they could not be confirmed within the scope of this article. The papers on the low concern of polymers are set out with their claims as they stand, and this article does not support either conclusion. Figs. 1, 2, 3, 5 and 6 are vector drawings; the hero image and Fig. 4 are AI-generated images, and none of them shows a real product or an experimental image.