This is part of AIAG's series recapping sessions from the 2024 Hybrid IMDS, Product Compliance & Sustainability Conference.
Where should you look for the data for per- and polyfluoroalkyl substances (PFAS) content? Where is PFAS in the materials, and why is PFAS being used in those materials to get it identified and reported in IMDS? The session “Understanding and Locating PFAS in IMDS” at the 2024 Hybrid IMDS, Product Compliance & Sustainability Conference addressed this important topic.
The presentation was given virtually by Monika Kotkowska, Senior Business Consultant and Regulatory Product Compliance Expert, DXC Technology; and in person by Deb Reining, Restricted Substances Compliance Manager, Cummins.
“PFAS is such a hot topic right now,” Kotkowska said. “Despite the usefulness, PFAS have a troubling, dark secret — they bring hostile environmental and health concerns that we are only beginning to understand.”
Let's dive into the highlights.
Finding PFAS in IMDS
It’s important to understand the products and suppliers likely to contain PFAS. ChemSec's PFAS Guide serves as a free starting point for identifying common applications within various industries or industry sectors. Additional information and resources are also available through the U.S. Environmental Protection Agency (EPA) PFAS page.
Global PFAS Production: Key Players and Initiatives
Twelve chemical companies are responsible for the majority of global PFAS production. Here’s the breakdown by company and percentage of total production.
Some major manufacturers have made progress in PFAS phase-out. For instance:
- 3M is targeting a global halt in PFAS-related product manufacturing by 2025, and production was down 20% in 2023.
- Arkema eliminated long-chain PFAS processing aids and is transitioning to non-PFAS surfactants by 2024.
- Chemours declared it is dedicated to fluorine chemistry innovation, pledging a 99% cut in fluorinated organic compound emissions, with a 40% reduction achieved by 2021.
- Solvay committed to phasing out fluorinated surfactants by 2026.
PFAS Applications in Automotive Components
“In the automotive industry, PFAS play a crucial role in many places,” Kotkowska said. PFAS are used in vehicles’ lubricants (Fluoropolymer); corrosion inhibitors (Monomeric PFAS: PFOS, PFOA, and PFHxS), coating (Fluoropolymer and Monomeric PFAS: FPOA, PFOS, and FTOHs); electronics (Fluoropolymer); and tires (Fluoropolymer).
Defining F-gases
PFAS are "forever chemicals” that are highly resistant to breakdown in the environment. There are three kinds: Nonpolymers, Polymers, and Fluorinated greenhouse gases (F-gases).
F-gases are human-made, strong greenhouse gases with a higher global warming potential than CO2. F-gases are used in many aspects of our daily lives, including refrigeration, air conditioning, heat pumps, medical inhalers, and aerosols.
F-gases Regulation
Because F-gases are a growing threat, 2014 Regulation (EU) No 517/2014 introduced quotas to reduce F-gas consumption, bans on F-gas and uses of F-gas, as well as requirements on leak rates from equipment and substitution to climate-friendly alternatives.
F-gas Regulation (EU) 2024/573 went into effect on March 11, 2024, and builds on predecessor regulation to implement a quota system to reduce amounts of F-gas, in conjunction with additional prohibitions, emissions restrictions, and capping of EU production to lead to a complete phaseout by 2050.
Finding PFAS in IMDS
“Don’t assume that you don’t have PFAS — find it,” Reining said. Using the Where-Used Analysis (WUA) is the most effective and comprehensive method when the PFAS information is entered correctly. You can search for PFAS on different levels within your product using the WUA’s built-in MDS tree filters and MDS search.
“Because there are a group of PFAS that don’t have any cast number, searching by CAS (Chemical Abstract Service) number helps you find a certain percentage of them, but use the searches that are already built to pick up those ones that you might have missed,” she said. “You may end up having to shorten your time range or you will hit the 500 limit. You might have to fight with it for a little bit to figure it out, but it’s possible to find everything that you have in your system.”
If you have a part that someone is specifically asking about, you can follow the same search process within the tree of your part using the search that’s inside the MDS. “Finding PFAS, you may need to go into the part to find out exactly what your percentages are, but you are able to find the group of parts that you have that has the PFAS in it, and then you can dig deeper into your products to identify exactly which PFAS you have associated with your product.”
There are several lists that include PFAS. All are relevant in automotive reporting.
Basic substance lists are grouped by regulation implementation dates and by definitions in different jurisdictions.
SAVE THE DATE FOR THE 2025 IMDS CONFERENCE
This topic and more will be covered at the 2025 Hybrid IMDS, Product Compliance & Sustainability Conference from October 8–10, 2025, at Suburban Collection Showplace in Novi, Michigan. Registration is now open, so don’t miss the early registration discount.
