25 September 2023:
On 7th February 2023, the European Chemicals Agency (ECHA) proposed a restriction on the use of per- and poly-fluoroalkyl substances (PFAS), due to concerns over their environmental and health impacts. The restriction as proposed amounts to a blanket ban on PFAS substances, justified by a desire to avoid the substitution of one type of PFAS for another. Fluoropolymers are one of PFAS category present in certain flow batteries’ ionomer and ion exchange membranes as well as other components of the flow battery stack and accompanying subsystems. Therefore, the proposed restriction on the use of PFAS chemicals would have a big impact on certain flow batteries. Other types of flow batteries that do not contain PFAS chemicals such as organic flow batteries, would not be impacted by the proposed restriction.
Flow Batteries Europe (FBE) has taken the opportunity to provide feedback on the proposal and has submitted answers to ECHA’s public consultation. In doing so, we have set out our recommendations for how the proposed restriction must be changed.
FBE’s position
FBE calls on the ECHA to exempt fluoropolymers from the upcoming PFAS restriction, as they are not classified as hazardous under the EU Classification, Labelling and Packaging Regulation and play a crucial role in ensuring the stability, performance and safety of market-available flow batteries, that are amongst the technologies driving the EU’s ambitious climate goals.
If this exemption cannot be achieved, FBE calls for a derogation period of 13.5 years for the flow battery sector, to allow research, development and the long-term testing of alternatives to fluoropolymer use. Any outright and immediate ban on fluoropolymers would have a significant socio-economic impact on flow battery stakeholders and across the EU as a whole. Should the scope of the proposed restriction not change, FBE calls on the EU to prioritise the allocation of sufficient funding towards the research and development of PFAS-free flow batteries, and the sustainability and risk profile of current technologies.
Read our full position paper on PFAS restriction proposal here.
