In response to the European Chemical Agency’s (ECHA) proposal for the restriction of Per- and Polyfluoroalkyl Substances (PFAS) across the European Union, Euralarm has submitted a detailed position.

The proposal, initiated by Germany, the Netherlands, Denmark, Sweden, and Norway, covers an extensive range of PFAS applications, spanning across 1780 pages and incorporating 14 different sectors, including firefighting gases.

Understanding the Proposal’s Scope

ECHA’s proposal includes a variety of fluorinated gases and their blends, which are used in firefighting and covered under EN 15004 or ISO 14520.

Among these are gases like HFC-227ea, HFC-125, FK-5-1-12, and HB-55, which have wide-ranging applications in firefighting.

The sector of ‘Applications of fluorinated gases,’ which incorporates these firefighting gases, constitutes only 3% of the total applications in this category, a relatively minor fraction compared to other uses such as refrigeration and foam blowing.

Firefighting Applications and Derogation

Annex E of the restriction proposal acknowledges the unique requirements of firefighting applications.

It recognises that while alternatives to F-Gases exist, there are specific scenarios where these alternatives might not be viable, citing potential risks to human life and cultural assets.

Consequently, the proposal suggests an 18-month transitional period after its entry into force (EiF), followed by a 12-year derogation from the ban for firefighting applications.

PFAS regulation: The timeline ahead

The public consultation for this proposal commenced on 22 March 2023 and concluded on 25 September 2023.

The process involves opinion development in ECHA’s committees, a draft opinion consultation, and a legislative process in the European Parliament and Council, leading up to the EiF.

It’s anticipated that the EiF for legislation won’t be implemented before the end of 2025, indicating that fluorinated gases, not restricted by the F-Gas regulation, would be available at least until mid-2039.

Euralarm’s stance and future outlook

Euralarm supports ECHA’s position that the current proposal does not intend to mandate the removal of installed systems.

The organisation closely monitors the development process and has committed to keeping interested parties regularly informed about changes.

With over 5600 comments received from more than 4400 organizations, companies, and individuals during the consultation period, the stakeholder feedback will significantly influence the final opinions of ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC).

IFSJ Comment

The proposed ECHA regulation on limiting PFAS use in firefighting contexts marks an important moment in the EU’s approach to environmental and public safety policy.

Acknowledging the environmental concerns associated with PFAS, the proposal also highlights the challenge of aligning environmental goals with the practical requirements of fire safety.

The 12-year exemption for firefighting uses suggests a balanced approach, acknowledging situations where alternatives are currently unavailable and the critical need for protecting human lives and property.

Euralarm’s reaction, which calls for a transition period and maintaining existing systems, reflects the industry’s effort to adapt to new regulations while maintaining a focus on safety and reliability.

This development is notable for its role in demonstrating how environmental policies can be integrated with specific industry needs, aiming to maintain both ecological health and public safety.