Technology Interchange—The Critical Importance of Fluoropolymers to the Powder Coatings Industry

By Jay West

There’s no doubt that per- and polyfluoroalkyl substances, or PFAS, are today’s hottest and perhaps most consequential chemical regulation topic. PFAS are a diverse group of chemistries characterized by the strong bond between fluorine and carbon. They can be solids, liquids, or gases. PFAS have been used for decades by a diverse array of industries, including powder coatings, for the performance and durability benefits they convey to many consumer and industrial products.

You are probably aware that PFAS have come under intense scrutiny by regulatory and legislative bodies around the world. To be sure, there are legitimate concerns around particular PFAS chemistries and their potential risks to human health and the environment. However, these reports largely focus on distinct subgroups of PFAS chemistries such as PFOA and PFOS, which many major PFAS producers around the world phased out in 2016. In some lab animal studies, exposure to PFOA and PFOS has been associated with developmental effects and liver damage, but there remains disagreement on the health effects of these chemistries by the regulatory community, including conflicting viewpoints between the U.S. Environmental Protection Agency (EPA) and the World Health Organization. Several governments, including Australia, Canada, the European Union, the United States, and several U.S. states have set regulatory guidance or limit values for PFOA, PFOS, and other non-polymeric PFAS in water, though the values and list of substances covered does not always overlap. Moreover, parties to the Stockholm Convention on Persistent Organic Pollutants are examining potential health concerns associated with other types of non-polymeric PFAS, and any Stockholm Convention to manage those substances would have global implications.

In the last few years, interests in PFAS have moved beyond potential exposure via environmental media to potential exposure from PFAS used in products, both consumer and industrial. Several regulatory bodies, including many U.S. states, are going beyond distinct molecules by defining PFAS very broadly as any molecule with a carbon-fluorine bond. Such a one-size-fits-all approach would potentially indict a distinct group of PFAS known as fluoropolymers, an important group of PFAS for the powder coatings industry which are a highly effective family of solid plastic resins, recognized internationally as non-toxic, that do not dissolve or move in water, spread through the air, or get absorbed into the body.

Health effects of newer PFAS chemistries are still being evaluated, including through the EPA’s PFAS Strategic Roadmap. PFAS in commerce today are supported by a body of scientific health and safety data and have been subject to review by regulators prior to introduction into commerce. Even after this review, they are subject to ongoing oversight by EPA.

Fluoropolymer Benefits in Powder Coatings
Fluoropolymer chemistries play a key role in the powder coatings industry by providing a unique combination of properties that significantly enhance the resilience, durability, and environmental sustainability of coated products and surfaces (see Figure 1). This specialized class of polymers is renowned for its superb resistance to chemicals, heat, weather, and abrasion, making it ideal for a wide range of applications where robust protective coatings are essential.

The unique resilience and durability qualities that fluoropolymers contribute to powder coatings should not be overlooked, as their strong carbon-fluorine bonds make them highly resistant to harsh conditions such as extreme temperatures, UV exposure, moisture, and exposure to corrosive chemicals, solvents, or cleaning agents. Fluoropolymers help coatings to maintain their integrity and performance over extended periods, which is of particular value to downstream users in the automotive, consumer products, medical, aerospace, and construction industries.

Further highlighting the value of fluoropolymers to the powder coatings industry, relative to potential alternative substances, is their long legacy of use and proven track record of elite performance in the most demanding applications and environments. There is a very good reason why powder coatings manufacturers have significantly invested in the infrastructure and expertise for safely handling and managing fluoropolymer coatings, and this is because fluoropolymers are unmatched in the exceptional benefits they provide.

The Performance Fluoropolymer Partnership’s (PFP) white paper titled, Infrastructure and Construction Applications, illustrates a wide range of applications where fluoropolymers in surface coatings play a critical role in the infrastructure and construction industries.


Looming Regulatory Threats
Due to the broad definition of “PFAS” found in many regulations, fluoropolymer users need to understand whether and how different PFAS regulations could affect their business. The ability to manufacture, import, or use fluoropolymers in the future could be challenging as the regulatory landscape surrounding PFAS in the U.S. and abroad continues to evolve. States such as Maine, Minnesota, and Colorado have passed legislation that would restrict the use of any PFAS, including fluoropolymers, in several categories of consumer products. Many states are also adopting “currently unavoidable use” tests that require the manufacturer of a product containing intentionally added PFAS to prove that there are no commercially viable alternatives that would serve the same purpose as the PFAS. If the manufacturer cannot, its ability to use PFAS in the future would be banned.

In the European Union, five countries have proposed the prohibition of all PFAS manufacturing, importation, and use. The proposal is slowly winding its way through the regulatory process set out by Europe’s flagship chemicals law, REACH (Registration, Evaluation, Authorisation, and Restriction of Chemicals). While the timeline for a final regulation is highly uncertain, deliberative committees of risk assessment and socio-economic impact experts from European member states have already begun the process of systematically examining nearly every use of PFAS in Europe and recommending its phase out or continued (possibly time limited) manufacturing and use.

What about the EPA? To date, the EPA’s PFAS-related activities have focused largely on sites where either soil or water have been contaminated by PFAS manufacturing or widely dispersive uses. EPA is not taking a product-by-product regulatory approach seen in many U.S. states and Europe. However, EPA is proposing regulations under the Toxic Substances Control Act that would raise the bar for manufacturing or importing new PFAS substances, which could have a chilling effect on innovation in industries important for national defense and economic competitiveness.

Regardless of the regulatory approach, the PFP advocates for fluoropolymers to be treated separately from other PFAS. All PFAS chemistries are not the same; therefore, grouping them into one vast family is the wrong approach. Doing so would lead to the subsequent ensnarement of fluoropolymers, which are large, stable, inert molecules that have been demonstrated to not possess the toxicity and bioaccumulation properties of some PFAS. In fact, in a 2022 ACC white paper titled, A Critical Review of the Application of Polymer of Low Concern Regulatory Criteria to Flouropolymers II: Fluoroplastics and Fluoroelastomers, the vast majority of fluoropolymers on the global market were shown to meet criteria used to identify polymers of low concern for potential risk to human health or the environment. Fluoropolymers are not water soluble and, as a result, are not found in sources of drinking water, a driving factor for many PFAS-related laws and regulations.

The fluoropolymer industry supports strong, science- based regulations of PFAS chemistries and is dedicated to responsible production, use, and management in a manner that protects the public health and our environment. We also believe that fluoropolymers should be considered separately, if not exempt, from policies that seek to control potential risks from smaller, environmentally mobile PFAS, concerns about which are really driving the debate. They are not PFOA or PFOS and do not transform into them in the environment. Fluoropolymers are a fundamentally different type of PFAS chemistry, and poorly crafted, overly broad policies can create unnecessary market uncertainty, patchworks of regulations, or, in the worst case, scientifically unsupportable restrictions on manufacturing and use.

“Available” Alternatives?
Some voices in the PFAS debate claim that PFAS alternatives are readily available. Substitution should be easy, right? We beg to differ. If viable alternatives existed that provide the same exceptional qualities of fluoropolymers, they would very likely be in use. Fluoropolymers are generally more expensive than potential alternatives and are therefore used when other substances cannot meet performance requirements. Fluoropolymers improve the functionality, reliability, and durability of products. They help manufacturers’ products meet multiple standards (e.g., safety, emissions, performance) and the rigorous testing and qualification processes those standards require. Their unique combination of properties cannot be easily matched by drop-in substitutes, and regulatory restrictions could require product reformulation and perhaps the modification of entire production lines and facilities.

Evaluating whether an alternative is “available” must account for the extent to which an alternative is already proven in a particular application and whether existing supply chains for the potential alternative can support increased demand. This includes demonstrating that a proposed alternative performs a required function at least as well as the incumbent substance and that the use of a potential alternative will not substantially increase the cost of the product at issue. An alternative is not “available” if it doesn’t perform, isn’t available at scale, and increases costs, both manufacturing costs and the costs of potentially increased replacement and repair.

Make Your Fluoropolymer Story Heard
Like it or not, the powder coatings industry is a stakeholder in the PFAS debate. While fluoropolymer manufacturers will continue to push for federal and state policies that prioritize and focus on the PFAS chemistries that may pose a potential risk to the health of humans or the environment, the engagement of fluoropolymer processors and users will be absolutely critical to help inform and guide smart, science-based regulations.

To that end, state and federal lawmakers and regulators need to hear not just from fluoropolymer manufacturers, but from all voices in the fluoropolymer value chain. It is important for all companies with a stake in the future availability of fluoropolymers to become involved in the policy debate through trade association advocacy, direct interaction with government regulators and elected representatives, or (preferably) both. Tell them why you use fluoropolymers (and not something else) in your products. Tell them why poorly considered, overly broad policies could compromise your company, your customers, and the jobs and taxes you generate.

Stay informed, active, and engaged, especially regarding the REACH proposal in the EU and key state activities such as in Maine and Minnesota. It is critical that these regulatory bodies be informed and reminded of the important uses and safety of fluorotechnology chemistries. Whether they have extensive business in the EU or not, U.S. companies need to be aware of the proposals being considered in Europe and engage to inform that process.

Similarly, stakeholders should also pay close attention to potential moves being made in the U.S. at the federal and state levels to consider any similarly faulty proposals that would group all PFAS chemistries into one monolithic class for the purposes of evaluation and regulation. Key downstream user engagement will be important to help inform and guide smart, science-based regulation of this important chemistry in the United States and abroad. The American Chemistry Council, NAFRA, the U.S. Chamber of Commerce, and others can be valuable resources.

Making sure decision-makers hear your company’s fluoropolymer story and understand the benefits your products bring is the most important step your company can take to help ensure that fluoropolymers and the products that depend on them aren’t collateral damage in the fast- paced—and probably getting faster—PFAS policy space.

Jay West is executive director, Performance Fluoropolymer Partnership within the American Chemistry Council.