To place a substance on the SIN List, it is needed to assure that the substance fulfils the SVHC criteria set by the EU. Until February 2023, only individual PFAS had been assessed and added to the SIN List.
Following the growing consensus of the need to move beyond individual hazard assessments of chemicals and look more at the group level, PFAS were identified as the first larger group of chemicals where scientists and most other stakeholders agree on a group-wise assessment and management.
The most problematic property — the extreme persistence — is undoubtfully shared across the PFAS group. Other properties such as toxicity, mobility and bioaccumulation vary amongst the individual chemicals depending on the chemical structure. But there is no evidence suggesting there are any “safe” PFAS substances.
Figures between 5,000 and several millions of individual PFAS chemicals are mentioned. While ChemSec wants to send a clear message that every single PFAS should be phased out, the new PFAS update to the SIN List aims to narrow them down to the most relevant substances to start substitution work with.
We have therefore selected the PFAS substances that are registered for production or use in the EU and/or the US. By doing so, we have boiled the PFAS universe down to a few hundred substances and placed them on the SIN List. We used slightly different approaches for the EU and the US data respectively, as these two data sources have a different setup.
For the EU information, we used the ECHA registration database and its built-in search function. We searched using so-called SMILES (simplified molecular-input line-entry system) and searched for allregistered substances having a -CF2- or -CF3 SMILES code. After this, we manually went through these and sorted out the ones that did not fulfill the OECD PFAS definition.
We chose substances with full registrations or so-called NONS (registered before REACH) registrations and removed substances registered as chemical intermediates (substances never leaving the manufacturing facility). However, in two cases we also kept the intermediates; either when there was an overlap between EU intermediates and substances registered in the US or when the substance had a relevant use identified in the publication “An overview of the uses of per- and polyfluoroalkyl substances (PFAS)” from 2020.
For US information, we used the US EPA Chemical Data Reporting (CDR). We searched for any chemical name that included the word “fluoro”. We then removed all entries which did not have CAS# and/or a proper name or structure. After this, we made a manual verification of the remaining structures to make sure the substance would qualify according to the OECD PFAS definition.