Tuttlingen/Düsseldorf - Even if it is repeatedly emphasized that it is only a proposal, the effects are already clearly noticeable: At the MEDICA Tech Forum, a panel discussed the impending PFAS ban. Meanwhile, the Enforcement Forum has published its comments on the ECHA website.
Yvonne Glienke (MedicalMountains GmbH), Dr. Martin Leonhard (SPECTARIS and Karl Storz SE & Co. KG), Dr. Stefan Löbbecke (Fraunhofer Institute for Chemical Technology ICT) and Dr. Carl Albrecht Dannenberg (Federal Institute for Occupational Safety and Health BAuA). BAuA is one of the national authorities that submitted the restriction proposal for per- and polyfluoroalkyl substances to ECHA. Dr. Carl Albrecht Dannenberg emphasized that this was a proposal that would not be passed one-to-one. The comments submitted by the end of September were used to form the opinions of the committees involved. Dr. However, Martin Leonhard emphasized that the effects are already being felt. The EU as an industrial location cannot afford to remain in limbo for three to four years. Just looking at the number of substances affected, Dr. Stefan faces a “Herculean task” for institutes and companies. The search for alternatives requires a lot of fluidity, pragmatism and sometimes looking beyond industry boundaries. Yvonne Glienke criticized the fact that the industry and patients were not more closely involved before the submission - the impact on medical care was simply not taken into account.
Dr. Carl Albrecht Dannenberg reminded that there will be another consultation. Once the draft opinion of the Socio-Economic Analysis Committee (SEAC) is available, comments on the restriction report or accompanying documents may be submitted within six months of publication. Subsequently, the European Commission, together with the Member States, will decide on the inclusion of the restriction proposal in Annex XVII of the REACH Regulation. According to the BAuA, this decision is expected to be made in 2025.
The further procedure at a glance:
Enforcement Information Exchange Forum
The Enforcement Information Exchange Forum, or Forum for short, reviewed the restriction dossier, summarized suggestions and published the comments on the ECHA website. The content - the name of the group says it all - primarily deals with specific questions about the implementation of a PFAS restriction. This includes, among other things, sample collection and preparation as well as analytical procedures. In addition, comments are made about unclear wording in the dossier, which could make implementation or monitoring more difficult in individual cases.
Phase II-A “Consultations”
