These industries are central to European Union initiatives, such as the Green Deal, EU Chips Act and EU4Health, which could be heavily impacted by PFAS restrictions, Cefic said, adding that it is concerned that the six-month consultation period is too short to cover 10,000 substances used across many complex value chains.
Additionally, Cefic said not all parties, especially SMEs, have the resources to understand and assess the impact of this at national, EU and regional levels.
Cefic requested that the RAC considers the enforceability of the PFAS proposals, particularly in terms of ensuring a level playing field for EU companies.
"Attention is needed here to avoid non-EU materials being given preferential treatment over local versions for derogated products," it stated. The industry group pointed to the enforcement challenges associated with measuring the proposed concentration limits, across multiple media and product types.
Meanwhile, Cefic said it had commissioned a scientific overview of several PFAS, looking into their key "physico-chemical" characteristics, human-health hazards and ecological risk.
The study shows PFAS "are not all the same" and will soon by submitted for review under the PFAS consultation process, according to Cefic.
The industry body is also "inventorying" PFAS in the equipment used by the chemical industry, including the status of alternatives, where they exist. The inventory will assess the extensive use of PFAS in chemicals manufacturing and their role in ensuring the safe and efficient functioning of its factories.
"This study will support a request for a derogation on PFAS in chemical industry settings," Cefic said.