CETS is actively working on the PFAS restriction proposal and its potential implications for the surface treatment sector.
Together with the CETS Board, a shared document has been prepared to identify the key concerns arising from the SEAC draft opinion and to support the development of a coordinated sector position.
CETS underlines that surface treatment should not be considered as one single homogeneous use. Different applications such as hard chrome plating, plastic etching, Ni-PTFE, PTFE-based hard anodising and fluoropolymer coatings have different functions, process conditions, performance requirements and substitution constraints.
A central concern is that alternatives are not generally demonstrated as available, technically suitable and validated at industrial scale for all uses. CETS also stresses that the PFAS restriction should not be used indirectly to impose a broader technology shift from Cr(VI) to Cr(III) or to other coating technologies without a proper technical and socio-economic assessment.
Where alternatives are not yet technically and economically feasible, CETS considers that long, review-based derogations are necessary. At the same time, capture, abatement, separation and destruction technologies should be considered as part of the regulatory toolbox, especially where emissions can be effectively controlled.
The interaction between the PFAS restriction and other regulatory frameworks is also critical. REACH, Cr(VI), occupational exposure limits, IED/STM-BREF requirements, CLP/OSH rules and worker-safety obligations must be assessed together to avoid conflicting or disproportionate requirements for companies.
CETS is also seeking to strengthen its institutional presence in RAC and SEAC activities, including through observer participation in relevant discussions. This is an important step to follow the development of key regulatory files more closely and to ensure that the specificities of the surface treatment sector are properly understood.