APPROACH FOR PER- AND POLYFLUOROALKYL SUBSTANCES (PFAS) / TOTAL FLUORINE LAWS FOR FURNITURE
Background
PFAS (Per- and Polyfluoroalkyl Substances) are fluorinated organic chemicals containing at least one fully fluorinated carbon atom (i.e. at least one aliphatic -CF2- or -CF3 element). PFAS have been widely used in consumer proudcts because of their specific properties, such as fire resistance and dirt and water repellency.
However, their toxicity and bioaccumulation can cause serious and widespread health risks in both humans and animals. Therefore, many countries and regions have imposed restrictions on PFAS. Many U.S. states have enacted various laws to restrict PFAS or total fluorine in consumer products. ECHA also restricts PFOS, PFOA, etc Under REACH/POPs regulatuion.
Below are summaries of EU/UK and U.S. requirements that restrict PFAS from furniture.
Summary of EU/UK Requirements
High risk material such as fabric, coated materials, leather, paper, wood with waterproof, anti-stain, anti-oil or non-stick properties are suggested to test.
| Country /Region |
Products |
Requirement |
Effective Date |
EU, UK
POPs Regulation (Regulation (EU) 2019/1021) |
Substances, mixtures, articles |
(1) PFOA and its salts ≤ 0.025 mg/kg (25 ppb);
(2) PFOA-related compounds ≤ 1 mg/kg (1000 ppb) (sum) |
July 4, 2020 |
EU, UK
POPs Regulation (Regulation (EU) 2019/1021) |
Substances, mixtures, articles |
PFOS: ≤ 10 mg/kg (for substances, mixtures); < 0.1% (for semi-finished products or articles); < 1 μg/m2 (for textiles or other coated materials) |
July 15, 2019 |
EU, UK-NI
REACH Regulation (EC) No 1907/2006 Annex XVII Entry 68 |
Substances, mixtures, articles |
(1) C9-C14 PFCAs and their salts: < 0.025 mg/kg (25 ppb);
(2) C9-C14 PFCA-related substances: < 0.26 mg/kg (260 ppb) (sum) |
February 25, 2023 |
EU, UK
REACH SVHC |
Substances, mixtures, articles |
(1) Pentacosafluorotridecanoic acid: ≤ 0.1%;
(2) Tricosafluorododecanoic acid: ≤ 0.1%;
(3) Henicosafluoroundecanoic acid: ≤ 0.1%;
(4) Heptacosafluorotetradecanoic acid: ≤ 0.1%;
(5) APFO: ≤ 0.1%;
(6) PFOA: ≤ 0.1%;
(7) PFNA and its sodium and ammonium salts: ≤ 0.1%;
(8) PFDA and its sodium and ammonium salts: ≤ 0.1%;
(9) PFHxS and its salts: ≤ 0.1%;
(10) PFBS and its salts: ≤ 0.1%;
(11) 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides: ≤ 0.1%
(12) PFHpA and its salts: ≤ 0.1% |
Various, have applied |
EU/EEA
REACH Regulation (EC) No 1907/2006, Annex XVII |
Substances, mixtures, articles |
(1) Each PFAS (polymeric PFASs excluded): < 0.025 mg/kg (25 ppb);
(2) Sum of PFASs (polymeric PFASs excluded): < 0.25 mg/kg (250 ppb);
(3) Sum of PFASs (polymeric PFASs included): < 50 mg/kg (50 ppm);
(4) Total fluorine (F): 50 mg/kg (50 ppm) (If total fluorine (F) exceeds 50 mg/kg, the manufacturer, importer or downstream user shall upon request provide to the enforcement authorities a proof for the fluorine measured as content of either PFASs or non-PFASs) |
In proposal stage |
Summary of Recently Passed U.S. State Requirements
High risk material such as fabric, coated materials, leather, paper, wood with waterproof, anti-stain, anti-oil or non-stick properties are suggested to test.
| State |
Requirement |
Effective Date |
| Colorado |
Prohibited if intentionally introduced |
- January 1, 2025
(For Indoor textile furnishings and
Indoor upholstered furniture)
- January 1, 2027
(For utdoor textile furnishings;
Outdoor upholstered furniture)
|
| California |
1) Prohibited if either intentionally added that has a functional or technical effect, or
2) ≥ 100 ppm as total organic fluorine(Commencing January 1, 2025);
≥ 50 ppm as total organic fluorine(Commencing January 1, 2027) |
- January 1, 2025 (100ppm)
- January 1, 2027 (50ppm)
|
| Maine |
Prohibited if intentionally introduced |
January 1, 2030 |
| Washington CHCC |
PFOA and related substances, PFOS and its salts: Reporting if over PQL as intentionally added or over 100 ppm as contaminants |
Augest 21, 2011 |
| Vermont CHCC |
PFOA, PFOS and its salts, Perfluorohexane sulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), Perfluorononanoic acid (PFNA): Reporting if over PQL as intentionally added or over 100 ppm as contaminants |
- June 10, 2014
(For PFOA and PFOS and its salts)
- July 1, 2022
(For PFHxS, PFHpA and PFNA)
|
| Oregon HPCCCH |
PFOS and its salts: : Reporting if over PQL as intentionally added or over 100 ppm as contaminants |
January 1, 2018 |
| Maine |
PFOS or its salts: Reporting if over PQL as intentionally added or over 100 ppm as contaminants |
July 28, 2020 |
| Maine |
Peporting if intentionally introduced |
January 1, 2023 |
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