September 2023 / Policy Papers - Responses to Public Consultations
Technical Contribution on the Annex XV Restriction Report for PFAS
In January 2023, a group of EU member states collectively submitted a proposal for restrictions to the European Chemicals Agency (ECHA) concerning per- and polyfluoroalkyl substances (PFAS).
ECHA describes this proposal as the broadest in history, and conducted a consultation on the proposed restrictions to gather input from stakeholders, including on missing applications, and to explore possible exemptions when non-PFAS alternatives are not available. PFAS play critical roles in multiple energy storage technologies which are essential to the transition towards decarbonised energy.
Due to these dependencies, finding PFAS alternatives is challenging and EASE recommends derogation periods of at least 13.5 years with a review clause to allow research and industry to develop alternatives. The reply detailing this recommendation is available on our website.
