A critical review of the application of polymer of low concern regulatory criteria to fluoropolymers II: Fluoroplastics and fluoroelastomers

Abstract

Fluoropolymers are a distinct class of per‐ and polyfluoroalkyl substances (PFAS), high molecular weight (MW) polymers with fluorine attached to their carbon‐only backbone. Fluoropolymers possess a unique combination of properties and unmatched functional performance critical to the products and manufacturing processes they enable and are irreplaceable in many uses. Fluoropolymers have documented safety profiles; are thermally, biologically, and chemically stable, negligibly soluble in water, nonmobile, nonbioavailable, nonbioaccumulative, and nontoxic. Although fluoropolymers fit the PFAS structural definition, they have very different physical, chemical, environmental, and toxicological properties when compared with other PFAS. This study describes the composition, uses, performance properties, and functionalities of 14 fluoropolymers, including fluoroplastics and fluoroelastomers, and presents data to demonstrate that they satisfy the widely accepted polymer hazard assessment criteria to be considered polymers of low concern (PLC). The PLC criteria include physicochemical properties, such as molecular weight, which determine bioavailability and warn of potential hazard. Fluoropolymers are insoluble (e.g., water, octanol) solids too large to migrate into the cell membrane making them nonbioavailable, and therefore, of low concern from a human and environmental health standpoint. Further, the study results demonstrate that fluoropolymers are a distinct and different group of PFAS and should not be grouped with other PFAS for hazard assessment or regulatory purposes. When combined with an earlier publication by Henry et al., this study demonstrates that commercial fluoropolymers are available from the seven participating companies that meet the criteria to be considered PLC, which represent approximately 96% of the global commercial fluoropolymer market. Integr Environ Assess Manag 2023;19:326–354. © 2022 The Authors. Integrated Environmental Assessment and Management published by Wiley Periodicals LLC on behalf of Society of Environmental Toxicology & Chemistry (SETAC).

Key Points

• Fluoropolymers have well‐established safety profiles are thermally, biologically, and chemically stable, negligibly soluble in water, nonmobile, nonbioavailable, nonbioaccumulative, and nontoxic.

• This study describes 14 fluoropolymers, including fluoroplastics and fluoroelastomers, and presents data to demonstrate that they satisfy the widely accepted polymer hazard assessment criteria to be considered polymers of low concern (PLC).

• This study, combined with a prior 2018 study of four fluoropolymers, demonstrates that 18 commercial fluoropolymers are available that meet the PLC criteria representative of approximately 96% of the global commercial fluoropolymer market.

• The study results demonstrate that fluoropolymers are clearly a distinct and different group of per‐ and polyfluoroalkyl substances (PFAS) and should not be grouped with other PFAS for hazard assessment or regulatory purposes.

Applications, Fluoropolymers, Low concern, PFAS, Property Combinations

INTRODUCTION

“Fluoropolymers are high MW polymers with fluorine atoms directly attached to their carbon‐only backbone” (Ebnesajjad, 2017). The carbon–fluorine (C–F) bond is the strongest bond between carbon and another atom and imparts unique, outstanding, and beneficial properties and extraordinary functional performance to fluoropolymers (Ameduri, 2020; Ameduri & Sawada, 2017a, 2017b; Banks et al., 1994; Fluoropolymer Products Group of Plastics Europe [FPG], 2021a; Scheirs, 2007). These properties include chemical, biological, and thermal stability, heat and chemical resistance, unique dielectric properties, and durability. Additional fluoropolymer properties include fire resistance, weather resistance, nonwetting, and nonstick. Fluoropolymers are regarded as irreplaceable in many applications because their unique combination of specific properties, which are critical to ensure optimal performance in many applications, cannot be achieved or guaranteed by alternative materials (FPG, 2021a, 2017; Henry et al., 2018; Performance Fluoropolymer Partnership of the American Chemistry Council [PFP], 2020).

Per‐ and polyfluoroalkyl substances (PFAS), a universe of substances with widely diverse properties that have been used in industrial and consumer applications since the 1950s, include fluoropolymers as a distinct class (Buck et al., 2011; Henry et al., 2018). A single, globally harmonized definition for PFAS has not yet been agreed upon. PFAS have been defined differently based on their structure and atomic composition (Buck et al., 2021; Wallington et al., 2021). For example, the USEPA's working PFAS structure definition is “a structure that contains the unit R‐CF₂‐CF(Rʹ)(R″), where R, Rʹ, and R″ do not equal “H” and the carbon–carbon bond is saturated (note: branching, heteroatoms, and cyclic structures are included” (USEPA, 2021a). The European Chemicals Agency (ECHA) employed a much broader PFAS structural definition (ECHA, 2020). A recent Organisation for Economic Cooperation and Development (OECD) report, which defined PFAS as fluorinated substances that contain in their structure at least one fully fluorinated methyl or methylene carbon atom (without any H/Cl/Br/I atom attached to it), that is, with a few noted exceptions, any chemical with at least a perfluorinated methyl group (–CF₃) or a perfluorinated methylene group (–CF₂–; OECD, 2021). This report acknowledges that the term “PFAS” is broad, general, and nonspecific, which does not inform whether a compound presents risk or not, but only communicates that the compounds under this term share the same structural trait of having a fully fluorinated methyl or methylene carbon moiety. Further, the report highlights that, among the substances defined as PFAS, there are distinct substances with very different properties: polymers and nonpolymers; solids, liquids and gases; persistent and nonpersistent substances; highly reactive and inert substances; mobile and insoluble (immobile) substances; and (eco) toxic and nontoxic chemicals. In addition, the report recognizes that PFAS have diverse molecular structures (e.g., neutral, anionic, cationic, or zwitterionic; with or without aromatic rings; nonpolymers or polymers; low or high molecular weight (MW), and thus diverse physical, chemical, and biological properties (e.g., involatile or volatile; water soluble or water insoluble; reactive vs. inert; bioaccumulative or nonbioaccumulative) and as such highly recommends that such diversity be properly recognized and communicated in a clear, specific, and descriptive manner when communicating about PFAS.

There is considerable media and public confusion and misunderstanding regarding PFAS, as the many different chemicals and groups are often not clearly differentiated under the broad term PFAS. Per‐ and polyfluoroalkyl substances, a large, diverse group of substances with vastly different properties, is too broad to allow effective, science‐based assessment and regulation of chemical compounds as an entire group. This point has been raised in recent publications that suggest approaches to effectively group PFAS for regulatory assessment (American Chamber of Commerce in Europe [Amcham], 2020a; Buck et al., 2021; Bundesverband der Deutschen Industrie e.V. [BDI], 2021; Fiedler et al., 2020; Miller et al., 2020; Orgalim, 2021; Royal Society of Chemistry [RSC], 2021; Sha et al., 2019; Wallington et al., 2021). A clear understanding of the origin of PFAS found in the environment, the PFAS that are commercially relevant (Buck et al., 2021), and assessment of their properties are needed to be able to determine which classes of PFAS require management action. PFAS must be assessed based on their chemical, physical, thermal, and biological property differences and uses (Amcham, 2020a; BDI, 2021; Buck et al., 2021; RSC, 2021; Wallington et al., 2021). As regulatory frameworks, such as the EU REACH regulation, continue to evolve, more work is needed to distinguish clearly among PFAS based on their properties to assure that regulations are appropriate in scope, proportionate, and are science‐based.

Per‐ and polyfluoroalkyl substances are divided into two primary categories: nonpolymers and polymers (Buck et al., 2011). Polymeric PFAS, generally known as “fluorinated polymers,” include fluoropolymers (discussed here), perfluoropolyethers (PFPE), and side‐chain fluorinated polymers (SCFP; Buck et al., 2011; Henry et al., 2018 and Supporting Information: Figure 6.1). This article deals strictly with fluoropolymers. Neither PFPE nor SCFP are discussed here.

The nonpolymer category includes perfluoroalkyl substances and polyfluoroalkyl substances. Certain nonpolymer PFAS substances, for example, short‐ and long‐chain per‐ and polyfluoroalkyl carboxylic acids and sulfonic acids, received regulatory scrutiny recently due to their toxicity, as well as their persistence, potential to bioaccumulate, and/or mobility in the environment. Regulatory processes have been launched worldwide to address these concerns related to specific nonpolymer PFAS. These targeted regulatory measures have evolved increasingly into restrictions on the entire family of PFAS. For example, five Member States of the European Economic Area have initiated a procedure to prepare a joint restriction proposal under the EU REACH Regulation to limit the risks to human health and the environment from the manufacture and use of all substances in the PFAS family based on structure alone (ECHA, 2020). Although fluoropolymers fit the PFAS structural definition, they have vastly different physicochemical, environmental, and toxicological properties than other PFAS in addition to substantial societal benefits and importance (Fluoropolymer Products Group of Plastics Europe [FPG], 2017, 2021a). For these reasons, fluoropolymers should be considered separately and not aggregated with all other PFAS for regulatory action. Concurrently, the USEPA prepared a PFAS Strategic Roadmap laying out how it plans to evaluate and potentially regulate PFAS (USEPA, 2021a). Recognizing that there are many PFAS very diverse in their physical form, chemical structure and composition, functional characteristics, and toxicity profiles, USEPA “is conducting new research to better understand the similar and different characteristics of specific PFAS and whether and how to address groups and categories of PFAS.”

Fluoropolymers have documented safety profiles, are thermally, biologically, and chemically stable, negligibly soluble in water, nonmobile, nonbioavailable, nonbioaccumulative, and nontoxic (Henry et al., 2018). Some fluoropolymers have been demonstrated to meet the “polymers of low concern” (PLC) criteria, and as such do not present notable concern for human health or the environment (Henry et al., 2018). PLC criteria were developed over time within regulatory frameworks around the world as an outcome of chemical hazard assessment processes, which identified physical–chemical properties of polymers that determine polymer bioavailability and thereby report a polymer's potential hazard. For example, many of the physicochemical properties, such as MW, limit the ability of a polymer to cross the cell membrane and therefore limit its bioavailability (Kostal, 2016; Lipinski et al., 2001; USEPA, 2012). The USEPA built on this knowledge to adopt a polymer exemption rule to exempt low‐hazard polymers from certain regulatory notification requirements under the Toxic Substances Control Act's (TSCA) new chemicals program (United States Federal Register [USFR], 1984). An OECD expert group on polymers reached consensus on these criteria and their respective metrics, documenting the data required for a polymer to qualify as a PLC to human health and the environment (OECD, 1993). Subsequently, an additional OECD work group concurred that PLC have “insignificant environmental health and human health impacts” (OECD, 2009). In addition, the European Commission commissioned a report (BIO by Deloitte, 2015) wherein several member countries agreed on the polymer properties predictive of adverse human health and environmental hazard. The report outlined eligibility criteria for a polymer to be considered a PLC. In 2019, the industry‐led European Centre for Ecotoxicology and Toxicology of Chemicals (ECETOC) developed a “Conceptual Framework for Polymer Risk Assessment” (“CF4Polymers”; ECETOC, 2019). CF4Polymers provides guiding elements to be considered in assessing potential ecological and human health hazards and risks posed by polymer substances. CF4Polymers also considers specific life‐cycle stages of polymer products and their associated routes of exposure. The authors of the CF4Polymers framework support the PLC approach as a means to accomplish polymer risk assessments. They specifically support the findings of Henry et al. (2018) and state that they are “…unaware of scientific evidence to justify generally assigning fluoropolymers the same level of regulatory concern as other PFAS” (ECETOC, 2019). In 2020, the European Commission contracted a study to propose criteria for the identification of polymers requiring registration (PRR) under REACH (Wood, 2020a). The Wood report states that the authors consider that fluoropolymers meet the criteria to be considered PLC, “following the recommendations of Henry et al.” Considerable debate and comment on proposals have been put forward as the process and discussion advances (American Chamber of Commerce in Europe [Amcham], 2020b; FPG, 2021a; Hafer, 2021).

Four major fluoropolymers have previously been demonstrated to meet the criteria as PLC (Henry et al., 2018). This 2018 study raised interest in gathering similar data for additional commercial fluoropolymer products, both in scope and polymer type. In this study, seven global fluoropolymer manufacturers from the USA, Europe, and Asia collaborated to gather and present data for 14 additional fluoropolymers. In addition to information describing chemical composition, uses, performance properties, and functionalities of the 14 fluoropolymers, author company data for each of the PLC criteria are presented and discussed. The results demonstrate that each of the 14 commercially manufactured fluoropolymers in this study satisfy the widely accepted assessment criteria to be considered PLC and merit such designation. The study results add further evidence to demonstrate that fluoropolymers are demonstrably different and should not be grouped with other PFAS for hazard assessment or regulatory purposes.

USES, PERFORMANCE PROPERTIES, AND FUNCTIONALITY OF FLUOROPLASTICS AND FLUOROELASTOMERS IN THIS STUDY

The fluoropolymers described and evaluated in this study are high‐performance materials used in commercial and industrial applications. Described herein are the industries and sectors (Table 1) and the performance properties and functionalities (Table 2) of the study fluoropolymers. The unparalleled combination of properties makes fluoropolymers critical materials for a broad range of applications and industrial sectors including automotive, aerospace, energy production and storage, and electronics (Table 1). Fluoropolymers are an important driver of the European Green Deal (FPG, 2021a) and UN Sustainability Development Goals (United Nations [UN], 2021), supporting smart mobility, clean energy, and sustainable industry. They are used in various components of renewable energy installations, such as hydrogen and photovoltaic panels and facilitate advanced energy storage and conversion technologies such as lithium‐ion batteries (FPG, 2021a). Fluoropolymers are (i) durable, stable, and mechanically strong in harsh conditions; (ii) chemically inert, meeting the requirements for low levels of contaminants and particulates in manufacturing environments that are critical to the food and beverage, pharmaceutical, medical, and semiconductor industries; and (iii) biocompatible, nonwetting, nonstick, and highly resistant to temperature, fire, and weather (Table 2). Fluoropolymers are the preferred choice of material because of their unique combination of properties that are not achievable from other materials or via other functions. As a result, fluoropolymers have become a critical mainstay for our society providing vital, reliable functionality to a broad range of industrial and consumer products.

Table 1

Fluoropolymer end uses and industries

Industries	Transportation		Health care		Chemical		Consumer			Telecommunications		Textiles	Infrastructure	Renewable energy
End uses	Automotive	Aerospace	Pharma‐ceuticals	Medical devices	Oil and gas	Chemical process industry (CPI)	Production of goods	Protection and packaging	Filtration	Electronics and semiconductors	Internet and wireless communications	Technical textiles	Construction and architecture	Energy production	Hydrogen production	Energy storage
Fluoroplastics
PVDF homopolymer	•	•	•	•	•	•	•	•	•	•	•	•	•	•	•	•
PVDF copolymer	•	•	•	•		•	•	•	•	•	•	•	•		•	•
ECTFE copolymer	•	•	•		•	•				•	•		•
ECTFE terpolymer			•		•	•
PCTFE		•	•							•
FEVE	•	•								•			•
EFEP	•			•		•				•
CPT	•									•
THV	•	•	•			•	•	•	•	•			•	•		•
Fluoroelastomers
FEPM	•	•	•	•	•	•	•			•			•	•
FKM	•	•	•	•	•	•	•	•		•		•	•	•	•	•
FFKM		•	•	•	•	•	•			•
Specialty
Amorphous		•	•	•		•				•	•				•	•
Ionomer	•			•		•			•	•				•	•	•

Note: See also Chapter 5 in the Supporting Information.

Abbreviations: CPT, chlorotrifluoroethylene‐tetrafluoroethylene; ECTFE, ethylene‐chlorotrifluoroethylene; EFEP, ethylene‐tetrafluoroethylene‐hexafluoropropylene; FEPM, trifluoroethylene‐propylene copolymer; FEVE, fluoroethylene‐vinyl ether; FKM, HFP‐VF2 polymer and HFP‐VF2‐TFE polymers; FFKM, TFE‐PMVE perfluoroelastomer; PCTFE, polychlorotrifluoroethylene; PVDF, polyvinylidene fluoride; THV, TFE‐HFP‐VF2.

Table 2

Fluoropolymer properties and functionality

	Durable				Inert—Stable
See Supporting Information: Chapter 2 for property descriptions	Mechanical strength	Wear resistance	Flexibility	Low coefficient of friction	Resistance to chemicals	Weatherability	Cryogenic properties (lower than −50 °C)	High operating temperature range	High limiting oxygen index
Fluoroplastics
PVDF Homopolymer	•	•		•	•	•		•	•
PVDF Copolymer	•	•		•	•	•		•	•
ECTFE Copolymer	•	•		•	•	•	•	•	•
ECTFE Terpolymer		•		•	•	•		•	•
PCTFE	•	•		•	•	•	•	•	•
FEVE	•	•	•	•	•	•		•	•
EFEP	•	•		•	•	•	•	•	•
CPT				•	•	•	•	•	•
THV			•		•	•		•	•
Fluoroelastomers
FEPM	•	•	•		•	•		•	•
FKM	•	•	•		•	•		•	•
FFKM	•	•	•		•			•	•
Specialty
Amorphous			•	•	•			•	•
Ionomer			•		•				•

	Functional
See Supporting Information: Chapter 2 for property descriptions	Electrical insulator—high data transmission rate	Ionic conductivity	Piezo‐electrical properties	Barrier properties	Nonstick properties	Ultra high purity grades for clean applications	Optical clarity	Low refractive index—used for optical effects	Polymer processing additive (PPA)a
Fluoroplastics
PVDF Homopolymer			•	•		•		•	•
PVDF Copolymer			•	•				•	•
ECTFE Copolymer	•			•
ECTFE Terpolymer				•
PCTFE				•	•	•	•	•
FEVE				•			•
EFEP				•	•		•	•	•
CPT				•	•	•	•	•
THV				•			•	•	•
Fluoroelastomers
FEPM	•			•
FKM				•	•				•
FFKM	•			•		•
Specialty
Amorphous	•	•		•	•	•	•	•
Ionomer	•	•		•			•

Note: See Chapter 5 in the Supporting Information.

Abbreviations: CPT, chlorotrifluoroethylene‐tetrafluoroethylene; ECTFE, ethylene‐chlorotrifluoroethylene; EFEP, ethylene‐tetrafluoroethylene‐hexafluoropropylene; FEPM, trifluoroethylene‐propylene copolymer; FEVE, fluoroethylene‐vinyl ether; FKM, HFP‐VF2 polymer and HFP‐VF2‐TFE polymers; FFKM, TFE‐PMVE perfluoroelastomer; PCTFE, polychlorotrifluoroethylene; PVDF, polyvinylidene fluoride; THV, TFE‐HFP‐VF2.

a

Polymer Processing Additives (PPA): also known as Polymer Processing Aid, Extrusion Process Aids or Polymer Processing and Recycling Aids.

Three fluoropolymer types are included in this study: fluoroplastics, fluoroelastomers, and specialty fluoroplastics. Here, we describe briefly each included in this study. Additional details about each polymer are provided in the Supporting Information: Chapter 5.

Fluoroplastics

The fluoroplastics included in this study are: polyvinylidene fluoride (PVDF) homopolymer, PVDF copolymer, ethylene‐chlorotrifluoroethylene (ECTFE) copolymer, ECTFE terpolymer, polychlorotrifluoroethylene (PCTFE), fluoroethylene‐vinyl ether (FEVE), ethylene‐tetrafluoroethylene‐hexafluoropropylene (EFEP) terpolymer, chlorotrifluoroethylene‐tetrafluoroethylene (CPT) terpolymer, and tetrafluoroethylene, hexafluoropropylene, vinylidene fluoride (TFE‐HFP‐VF2 [THV]) terpolymer as well as the specialty fluoroplastics, amorphous fluoropolymers, and fluorinated ionomers. Typical monomers used in the manufacture of fluoroplastics include tetrafluoroethylene (TFE), hexafluoropropylene (HFP), vinylidene fluoride (VDF or VF2), chlorotrifluoroethylene (CTFE), vinyl fluoride (VF), trifluoroethylene (TrFE), and perfluoroalkyl vinyl ethers (PAVEs), which include trifluoromethyl trifluorovinyl ether (PMVE), pentafluoroethyl trifluorovinyl ether (PEVE), and heptafluoropropyl trifluorovinyl ether (PPVE). In some copolymers, monomers that do not contain fluorine attached to the olefinic carbons may be used. These include ethylene, propylene, perfluoroalkyl‐substituted ethylenes, and others (Ebnesajjad, 2000, 2003; Grot, 2011).

Fluoroelastomers

The fluoroelastomers included in this study are: trifluoroethylene‐propylene copolymer (FEPM), HFP‐VF2 polymer and HFP‐VF2‐TFE polymers (FKM), and TFE‐PMVE perfluoroelastomer (FFKM). Typical monomers used in the manufacture of fluoroelastomers include VDF, HFP, TFE, CTFE, PAVEs, as well as propylene,1‐hydropentafluoropropene (HPFP), and 2,3,3,3‐tetrafluoropropene (HFO‐1234yf; FPG, 2021a). Although fluoroelastomers are based on many of the monomers that are also used for the synthesis of fluoroplastics, they are different because of the specific composition, flexibility with subambient glass transition temperatures, as well as their elastomeric properties, resulting from the cross‐linking process. Cross‐linking, known as curing or vulcanizing, is a hardening process to form chemical bonds between polymer chains that gives polymers their elasticity (Améduri et al., 2001; Drobny, 2016).

PVDF homo‐ and copolymers

Polyvinylidene fluoride fluoropolymers are specified by end users across the world for their outstanding combination of properties. Because they have high temperature resistance, low permeability, and high mechanical strength, and provide chemical resistance to a wide range of aggressive chemicals, PVDF fluoropolymers are used as a contact surface for the production, storage, and transfer of corrosive fluids (chemically resistant to halogens and acids) in the chemical processing industry, oil and gas transportation, and cables industry (Arkema, 2021a; Gujarat Fluorochemicals Limited, 2018, 2022; Solvay, 2021a). The outstanding resistance to sunlight/UV exposure make PVDF suitable for architectural coatings. The outdoor aging and weathering properties of PVDF resin led to its use in long‐lasting paints for coating metal sheet for the past 50 years. PVDF resins can also be used to protect thermoplastics through coextrusion or film lamination techniques to obtain antigrime and antigraffiti surfaces with exceptional weathering properties. PVDF fluoropolymers also exhibit radiation resistance, desirable burn characteristics, flame, and smoke properties, easy processing on industry‐standard equipment, and easy postprocessing steps, such as welding and fabrication. PVDF is used as a binder in lithium‐ion batteries as well as PVDF film for solar power panels because of its high thermal and electrochemical stability, its stability under harsh environmental conditions, and its strong adhesion properties are critical to achieving environmental goals.

ECTFE (co‐ and terpolymers)

Ethylene chlorotrifluoroethylene (ECTFE) is a semicrystalline and melt‐processable fluoropolymer obtained by the copolymerization of the two monomers, ethylene and chlorotrifluoroethylene, with an essentially 1:1 alternating structure (Ebnesajjad, 2017). Due to its chemical structure, ECTFE offers a unique combination of properties including chemical resistance, high thermal rating, and very good mechanical properties (Solvay, 2021b). ECTFE terpolymer with added hexafluoroisobutylene monomer displays enhanced stress‐cracking performances resulting from chain‐structure modifications of the polymer. ECTFE is used widely in anticorrosion applications such as coatings or in self‐supporting construction (pipes) and architectural films (Solvay, 2021c). One of the principal advantages of ECTFE fluoropolymer is the ease with which it can be processed. It is a true thermoplastic that can be handled by conventional techniques of extrusion as well as by blow, compression, injection, rotational, and transfer molding. Powder coating methods are also applicable. ECTFE embodies an exemplary trade‐off among general properties, offering high chemical and mechanical resistance combined with easy processing of the resin.

PCTFE

Polychlorotrifluoroethylene is a homopolymer of chlorotrifluoroethylene. PCTFE is melt processable and can be extruded or molded (Satokawa, 1990). PCTFE has outstanding mechanical properties, especially hardness, and chemical resistance compared with PTFE and PFA, although it is slightly inferior to PFA and FEP in heat resistance and chemical resistance (Daikin, 2021a; Satokawa, 1990). PCTFE has been applied widely in the semiconductor industries and aerospace industries (Curbell, 2021; Daikin, 2021a). In addition to distinguished thermal and chemical stability, it has very low moisture absorption and permeation; therefore, PCTFE is used in pharmaceutical packaging (Honeywell, 2021).

FEVE

Fluoroethylene‐vinyl ether fluoropolymer resins are manufactured by copolymerization of fluoroethylene monomer and a vinyl ether monomer and consist of alternating fluoroethylene and alkyl vinyl ether segments (AGC Chemicals Company, 2021a; Parker & Blankenship, 2015). They were developed in 1982 as the first solvent‐soluble fluoropolymers in the world (Darden & Parker, 2021; Kojima & Yamabe, 1984; Munekata, 1988; Yamabe et al., 1984). The alternating fluorinated segments provide outstanding UV stability, weather resistance, and chemical resistance, while the vinyl ether segments provide solvent compatibility and cross‐linking sites (Parker & Blankenship, 2015; Scheirs, 2007). FEVE resins are used to make ultraweatherable coatings for architectural, aerospace, automotive, bridge, and industrial maintenance markets (Hoshino & Morizawa, 2017).

EFEP

Ethylene‐tetrafluoroethylene‐hexafluoropropylene is a terpolymer of ethylene, tetrafluoroethylene, and hexafluoropropylene. It was designed to have many of the properties of ETFE. It has a lower processing temperature, which allows it to be coextruded with conventional thermoplastic polymers such as polyamide, ethylene vinyl alcohol (EVOH), and modified polyethylene. EFEP can be extruded, injection molded, and blow molded, and it is used in many applications such as those identified in Supporting Information: Chapter 4.7 (Daikin, 2011a). EFEP is a melt‐processable resin with good processability because of its low melting point. It also has excellent mechanical properties, provides chemical resistance, low permeability, exceptional weatherability, and good heat resistance. Other prominent features include inherent flame retardancy as well as good optical properties given that EFEP is highly transparent and has both a low dielectric constant and loss tangent.

CPT

Chlorotrifluoroethylene‐tetrafluoroethylene is a terpolymer of chlorotrifluoroethylene, tetrafluoroethylene, and perfluoroalkyl‐vinyl‐ether. It is a melt‐processable polymer and resin, which is readily processed because of its lower melting point. It can be melt‐molded as a thermoplastic resin by extrusion, injection, and compression molding. CPT is a modified perfluoroalkoxy fluoropolymer (PFA), which utilizes chlorotrifluoroethylene to provide low permeability to PFA, and it has many outstanding properties as a hybrid polymer of PFA and PCTFE as shown below. It has demonstrated permeation resistance to organic solvent, chemicals, water vapor, and gasoline (Daikin, 2011b). CPT offers superior permeation resistance against gasoline and flexible fuel and can be part of construction meeting the LEV III requirements (US environmental protection regulations in this automotive application). CPT also has notable barrier properties against many kinds of organic solvents and strong acids, especially HF, HCl, and HNO₃. This is very useful for semiconductor applications (Daikin, 2021b). In addition to the features noted above, CPT also provides heat resistance, excellent weatherability, flame retardancy, and good optical properties owing to its high transparency.

THV

THV fluoropolymers are a group of fluorinated thermoplastic polymers composed mainly of tetrafluoroethylene (text-decoration:underlineFE), hexafluoropropylene (text-decoration:underlineFP), and vinylidene fluoride (text-decoration:underlineDF; Domininghaus, 1998; Hintzer & Schwertfeger, 2014; Hull et al., 1997). The melting point of the different grades ranges from approximately 100 °C to nearly 250 °C. THV fluoropolymers are easy to process due to their broad processing windows. Different THV grades exhibit high flexibility, high transparency, bondability to fluorinated and nonfluorinated materials, and very good permeation resistance against fuels and other chemicals. The polymers are used as a barrier layer in fuel hoses, for transparent films and tubing, as matrix materials in composites, and the bonding layer in multilayer construction (Dams & Hintzer, 2017; Hull et al., 1997). The high transparency of the special film makes it an ideal adhesive film for laminated glass and the optimal protective film for surfaces. THV grades compete against other fluorothermoplastic materials for applications that require transparency and low refractive index as well as with fuel barrier materials. Commercial nonfluorinated materials cannot be used as substitutes for THV because of the unique combination of properties. Polymethylmethacrylate (PMMA) is used in conjunction with THV to provide differences in refractive index to create the total reflection needed for polymer optical fibers (Park et al., 2008). Transparent polymers, such as PMMA or polycarbonate, do not have the same chemical resistance or UV resistance to compete directly with THV.

FEPM

Trifluoroethylene‐propylene copolymer elastomers, ASTM D1418, are high MW fluoropolymers with alternating tetrafluoroethylene and propylene segments (Kojima et al., 1977). They are also known as TFE‐P copolymers. Various articles can be produced by means of compression molding, extrusion, injection molding, and calendering. FEPM elastomers are compounded and cured (cross‐linked) to deliver unique and valuable properties by providing exceptional heat resistance with a continuous service temperature higher than 200 °C, outstanding chemical resistance with little or no deterioration even in contact with strong acids, bases, and oxidants at high temperatures, steam resistance, and high electrical resistivity on the order of 10¹⁵–10¹⁶ Ω/cm (bulk resistivity). Formulated FEPM components are now used worldwide in many critical industrial applications where they must function safely in harsh environments, thereby extending the life of critical components and reducing downtime and costly repairs. FEPM elastomers are used in a range of applications including thermal power plants, oil and gas industry, ocean development, chemical and nuclear plants, automotive, aerospace, heavy‐duty diesel, electronics, machinery, renewable energy, food processing, and medical. Their noted heat and chemical resistance make them especially valuable in oil and gas extraction (downhole) applications, where reliability is essential to cost effective and environmentally responsible production (Hull, 1983). FEPM elastomers are also used in high‐performance wire and cable applications as insulating materials with the highest heat resistance, for example, lightweight, high‐voltage automotive cables and motor cables for Japanese high‐speed bullet trains (AGC Chemicals Company, 2021b).

Fluoroelastomers (FKM)

FKM are a family of fluoroelastomer materials defined by ASTM international standard D1418 (ASTM, 2021). FKM fluoroelastomers contain vinylidene fluoride (VDF) as a monomer combined with a variety of other fluoromonomers to create a palette of polymers with properties tailored for specific uses (Dams & Hintzer, 2017; Drobny, 2016; Van Cleeff, 1997; Worm & Grootaert, 2001). Cross‐linked FKM fluoroelastomers are amorphous polymers designed for demanding service applications in hostile environments characterized by broad operating temperature ranges in contact with industrial chemicals, oils, or fuels (Worm & Grootaert, 2001). FKM fluoroelastomers are used mainly in fabricated parts (e.g., o‐rings, gaskets, seals) to provide barriers against a wide range of fluids under severe service conditions (Drobny, 2016). Their design allows stable extrusion and molding processes and fitting in a wide range of processing constraints, reducing the risk of failure and increasing productivity. FKM fluoroelastomers provide high temperature and aggressive fluids resistance and retention of properties over a wide and demanding range of operating use conditions (high and low temperatures) for sealing and fluid transport applications, offering far superior performance than hydrocarbon elastomers. Applications include aerospace, automotive, oil and gas, chemical processing, electrical, office equipment, food, pharmaceuticals, and consumer wearables. Additionally, uncured FKM fluoroelastomers are used as a polymer processing additive (PPA) or polymer extrusion aids in small amounts (50–2000 ppm) dispersed in polyolefins such as high‐density polyethylene (HDPE) and linear low‐density polyethylene (LLDPE), significantly improving their film extrusion characteristics, reducing melt fracture and die build‐up, as well as increasing productivity, minimizing energy and water footprint, and enabling the extrusion of thin films (Lavallée, 2020; Shell, 2020).

FFKM

Perfluoroelastomers, designated by ASTM D1418 as FFKM, are a fully fluorinated class of elastomers that are typically made up of tetrafluoroethylene (TFE), a perfluoro (alkyl vinyl ether; PAVE), and a cure site monomer(s) (Ohkura & Morizawa, 2017). FFKM elastomers offer superior chemical and temperature resistance, excellent resistance to gas and liquid permeation, and resistance to weather and ozone with operating temperatures ranging from −40 °C to 325 °C (Drobny, 2016; Greene‐Tweed, 2021a, 2021b). These polymers can also be compounded to meet the special requirements of upstream, midstream, and downstream oil and gas exploration due to their superior properties (Barnwell, 2021; Daemar, 2021). Because of these properties, FFKM elastomers are used in a wide variety of applications such as critical sealing solutions for the aerospace, pharmaceutical, medical, chemical processing, semiconductor, and oilfield industries (Atkinson, 2018; Marshall, 2017).

Amorphous fluoropolymers

Amorphous fluoropolymers are copolymers of TFE and specialty monomers that yield linear, high molar mass noncrystalline polymers (AGC Chemicals Company, 2021c; Gangal & Brothers, 2010; Hintzer et al., 2013; Korinek, 1994; Resnick & Buck, 1997, 1999). Amorphous fluoropolymers have the outstanding chemical and thermal stability and surface properties of semicrystalline perfluoropolymers as well as the unique properties associated with amorphous materials such as optical clarity and high gas permeability. The optical properties are outstanding, with more than 90% transmission, and thereby low dissipation, over a wide range of wavelengths (e.g., 200–2000 nm). TFE/PDD (2,2‐bistrifluoromethyl‐4,5‐difluoro‐1,3‐dioxole) copolymers have the lowest refractive index known for a solid organic polymer (Groh & Zimmermann, 1991). This unique combination of properties makes amorphous fluoropolymers unmatched for uses in degassing, fiber optics, photolithography, antireflective coatings, passivation and protective coatings for medical, military, and aerospace devices, as well as electronic applications (Gangal & Brothers, 2010; Hintzer et al., 2013).

Fluorinated ionomers

Fluorinated ionomers are copolymers of TFE and a perfluorovinylether monomer containing an ionic group, typically a sulfonic acid or carboxylic acid (Grot, 2011, 2013). Fluorinated ionomers can be extruded or cast into film and converted into ion exchange materials (IXMs). IXMs come in a variety of useful forms offering a broad range of solutions for different applications (AGC Chemicals Company, 2021d; Asahi‐Kasei, 2021; Chemours, 2021a). These forms include ion exchange membranes (IEMs), dispersions, and resins. IEMs must possess the required ion transport properties for the electrochemical cell in which they reside to perform well and work effectively. Some of these properties include high ionic conductivity, chemical resistance, high operating temperature range, low permeability, and balanced durability and performance (Chemours, 2021b).

Ion exchange membranes (IEMs) stand to play a noteworthy role in today's modern world (Chemours, 2021b) and as such, are utilized in a wide range of applications and end‐use industries including electrochemical processing, energy production, and hydrogen production. IEMs revolutionized the chlor‐alkali industry (Grot, 2013), the manufacture of primarily caustic soda and chlorine, by eliminating the use of hazardous materials such as mercury and asbestos (Asahi‐Kasei, 2021) and, in doing so, reducing energy consumption. Water electrolysis, the process of converting water into hydrogen and oxygen, relies on IEM technology. Although this process requires electricity, renewable energy sources such as solar or wind power can be utilized, allowing the potential for hydrogen to be a “clean” energy source (Science Center, 2021). Hydrogen fuel cells, some of which use a type of IEM known as a proton exchange membrane, can then convert hydrogen to electricity, a crucial technology to reach the stated target of the EU New Green Deal (EC, 2021).

STUDY METHODOLOGY AND DATA

Seven global fluoropolymer manufacturers (AGC Chemicals Americas, Arkema, The Chemours Company, Daikin Industries, Gujarat Fluorochemicals Limited, Solvay Specialty Polymers, and 3M Company) participated in this study and contributed data, writing, critique, and analysis. The companies noted above are members of the US‐based Performance Fluoropolymer Partnership (PFP) and/or EU‐based Fluoropolymer Product Group (FPG).

This study provides data on 14 fluoropolymers, building on a prior study (Henry et al., 2018). The study was chartered within two global industry groups. Participants put forward candidate fluoropolymers of notable commercial importance for the study and provided company and published data that address the PLC criteria. Thirteen PLC criteria that relate to the polymer structure and properties, including three to physicochemical properties and five to stability, set forth in BIO by Deloitte (2015) and presented in prior work on four fluoropolymers (Henry et al., 2018), are addressed in this study (Figure 1). These criteria are briefly described in Table 3 with further description provided in Supporting Information: Chapter 3 and in the prior work (Henry et al., 2018). Participants provided company and published data and a description of methods and/or public references to demonstrate the origin of the data provided. These methods and references are provided in detail in Supporting Information: Chapter 4. The PLC criteria data were compiled and are presented in Tables 4 and 5.

Figure 1

OECD polymer of low concern (PLC) criteria add (C) 2021 W.L.Gore & Associates

Table 3

Polymer of low concern (PLC) criteria descriptions

(See Supporting Information: Chapter 3 for additional details)
Criterion	Description
Polymer composition	The polymer composition criterion requires structure and elemental composition of the polymer be described and identified (e.g., by Chemical Abstracts Service [CAS] number).
Molecular weight, number average molecular weight, MW distribution, and % oligomer <1000 Da	The number average molecular weight (Mn) and oligomer content are the most commonly used criteria for PLC assessment. The EU assessment report (BIO by Deloitte, 2015) states that the “most potential health concern polymers have a number average molecular weight, Mn, <1000 Da and oligomer content >1%.” The higher the oligomeric content, the more likely a polymer is to be a health or ecotoxicological (OECD, 2009, p. 9).
	Molecular weight (MW) is an important predictor of biological effect because large molecules (>1000–10 000 Da) are too large to penetrate cell membranes (Supporting Information: in Beyer, 1993, p. 14). Because large molecular weight polymers cannot enter the cell, they cannot react with “target organs,” such as the reproductive system, and are not bioavailable. “Therefore, as the Mn of a polymer increases, a reduced incidence of potential health concern effects might be expected” (OECD, 2009, p. 20).
	An additional PLC consideration is the weight percentage of oligomers that are <1000 Da. Oligomers may be composed of, for example, dimers, trimers, and tetramers, meaning they have 2‐ monomer, 3‐ monomer, and 4‐monomer units, respectively. The EU report (BIO by Deloitte, 2015) concluded that most potential health concern polymers have Mn of <1000 Da and oligomer content of >1%: “…the distribution of potential health concern polymers exhibited an increased incidence of higher oligomer content that began at 5% for <1000 Da and 2% for <500 Da oligomeric content” (OECD, 2009, p. 24).
	Molecular weight distribution (MWD), also known as “polydispersity index,” measures the heterogeneity of size of polymer molecules in a polymer. The MWD is an important parameter for predicting potential biological effects of polymers because, although Mn may be a large value, low MW oligomers <1000 Da may be present, which could penetrate the cell.
Ionic character	Electrical charge or ionic character can be anionic, cationic, amphoteric, or nonionic. Specifically, cationic polymers have been associated with aquatic toxicity (Auer et al., 1990; USEPA, 1997a).
Reactive functional groups and RFG ratio to MW	A “reactive functional group” (RFG) is defined as an atom or associated group of atoms in a chemical substance that is intended or can be reasonably expected to undergo facile chemical reaction (USFR, 2012). Some highly reactive functional groups (or a high ratio of RFGs per mole) have been associated with adverse human health and ecotoxicology (e.g., acrylates, methacrylates, isocyanates, anhydrides, aziridines; USEPA, 2010).
	The functional group equivalent weight (FGEW) is used to determine if the RFGs in a polymer are substantially diluted by polymeric material to allow the polymer to be a PLC (USEPA, 1997). The FGEW of a polymer is defined as the ratio of the Mn to the number of functional groups in the polymer. The FGEW is used as an indication of the degree of reactivity of the polymer; the lower the FGEW, the more reactive the polymer and the greater the potential for health and environmental impact (OECD, 2009, p. 10).
Low MW leachables	Low MW leachables are chemical molecules, either inorganic or organic, that migrate (i.e., leach) out of the polymer. These could be residual monomers or oligomers resulting from incomplete polymerization processes, surface residues, or other chemicals used in the manufacturing processes (e.g., initiators, catalysts, chain transfer agents, surfactants).
	Low MW leachables are critically important to the potential for a polymer to affect health and the environment, given that they may be able to migrate out of the polymer and cross cell membranes to potentially react with biomolecules. A report to the EU (BIO by Deloitte, 2015) concluded that “Polymers with <1% MW < 1000 Da and low water extractability are not able to cause systemic effects which are toxicologically or ecotoxicologically relevant.”
	Monomers, by nature, are reactive. Unreacted monomers left in a polymer may migrate out of the polymer to react with biomolecules to cause potential adverse effects. Regulatory authorities (BIO by Deloitte, 2015) and the OECD Expert Group on Polymers (OECD, 2009) agree that the residual monomer content of a polymer is critical to determining if it qualifies as a PLC.
Particle size	Particle size is also a PLC criterion. Particles that are small enough to reach the deep lung upon inhalation are often associated with adverse health effects. Therefore, to qualify as a PLC, median mass aerodynamic diameter (MMAD) of the polymer particle size should be >5 µm.
Structural and elemental composition	In the US, Chemical Categories of Concern are the result of the review of new chemicals by the USEPA under the TSCA (see https://www.epa.gov/reviewing-new-chemicals-under-toxic-substances-control-act-tsca/chemical-categories-used-review-new). The categories describe the molecular structure, boundary conditions such as MW, equivalent weight, the log of the octanol–water partition coefficient, log P, or water solubility, and standard hazard (mammalian and ecological) and (environmental) fate tests to address concerns.
Elemental composition	The elemental composition is a factor in the assessment of the eligibility of polymers for reduced notification requirements. The exclusion of polymers under this step is not a conclusion of hazard but a determination that the elemental composition does not fall within the parameters of the polymer set under which this rule was formulated, and consequently, these polymers would have to follow the standard notification and review process. These elemental requirements differ across jurisdictions as covered in the report to the EU on global regulatory approaches to polymer assessment (BIO by Deloitte, 2015). For example, in the EU under REACH it is proposed that polymers composed from among these elements, covalently bound to C, have reduced hazard: H, N, O, Si, S, F, Cl, Br, or I (BIO by Deloitte, 2015). In contrast, the USEPA Polymer Exemption Rule states that a polymer is eligible for reduced agency review when it has at least two of the following elements: C, H, O, N, S, or Si (USFR, 1995).
Water and lipid solubility and the octanol–water partition coefficient	Water solubility is the extent to which a compound will dissolve in water. According to the OECD (2009) meeting of the Expert Group on Polymers, polymers with “negligible” water solubility, or those described as “hydrophobic” have been represented with a water solubility of 0.000001 mg/L (1 × 10–6  mg/L; assigned arbitrarily; OECD, 2009). That is equivalent to 1 ppt, a very conservative definition.
	Polymers with water solubility <10 mg/L showed generally low health concerns.
	The octanol–water partition coefficient (Kow) is another criterion to assess chemicals and their environmental and health impact. The Kow is a physical–chemical property at equilibrium to represent the lipophilic or hydrophilic nature of a chemical, the distribution of a compound in octanol, representing the lipophilic nature, to its solubility in water, representing the aqueous nature. The higher the Kow, the more lipophilic the compound. Typically, a Kow >5000 or a log Kow >5 means high lipophilicity and, thus, a high potential to bioaccumulate or bioconcentrate. According to the Stockholm Convention, a bioconcentration factor of >5000 and a log Kow >5 is used as a criterion for bioaccumulation.
Stability	Stability is resistance to physical, chemical, or biological transformation. Loss of stability in the polymer breaks it down into smaller pieces, producing low MW species. As was previously described in the Polymer of Low Concern section under the molecular weight, number average molecular weight, MW distribution, and % oligomer <1000 Da heading, molecules with Mn <1000 Da are capable of crossing cell membranes, making unstable polymers potentially hazardous to health and the environment.
Abiotic stability	Polymers are stable; monomers are not. Abiotic degradation may involve sunlight, water, or oxygen. Photochemical transformation is a reaction involving the radiation energy of sunlight (ultraviolet radiation) that may break a bond in a molecule to change it to another chemical entity. Hydrolytic degradation of polymers is another potential way to break the polymer bonds, creating smaller oligomers that may be bioavailable. Chemical oxidation is a reaction involving the loss of electrons from one atom to another.
Biotic stability: aerobic, anaerobic, and in vivo	Biotic stability is assessed by whether the polymer is degraded by microorganisms under oxygenated (aerobic) or anoxic (anaerobic) conditions; in vitro and in vivo stability studies demonstrate this. In vivo biodegradation involves the breaking of the polymer bonds by the action of bacteria, enzymes, and oxidants within the organism.
Thermal stability	Thermal stability of a polymer can be assessed when used as intended under normal, foreseeable use conditions or in extreme temperatures during disposal, such as by incineration. Thermal stability testing may involve Thermogravimetric Analysis (TGA), which determines mass loss over time and temperature of a test substance.

Table 4

Fluoroplastics and PLC criteria

	Fluoroplastics
Supporting Information Data: Chapter	4.1	4.2	4.3	4.4	4.5
	PVDF	PVDF‐HFP copolymer	ECTFE	ECTFE	PCTFE
	Polyvinylidene fluoride	Vinylidene fluoride, hexafluoropropene copolymer	Ethylene, chlorotrifluoroethylene copolymer	Ethylene, chlorotrifluorethylene, hexafluoroisobutylene terpolymer	Polychlorotrifluoroethylene
PLC assessment criteriona	CAS 24937‐79‐9	CAS 9011‐17‐0	CAS 25101‐45‐5	CAS 54302‐04‐04	CAS 9002‐83‐9
Structure	–(CF2–CH2)n–	–(CF2–CH2)n–[CF(CF3) –CF2]m–	–(CF2–CFCl–CH2–CH2)n–	–(C4H2F6)n–(C2H4)m–(C2ClF3)i–	–(CF2–CFCl)n–
Polymer composition   (must have C, H, Si, S, F, Cl, Br, or I covalently bound to carbon)	Yes	Yes	Yes	Yes	Yes
Molecular weight (Mn)b   (Mn >1000 Da and oligomer content <1%)	70 000–300 000	80 000–300 000	Mn >50 000	Mn >50 000	70 000–400 000 average based on grade type
Molecular weight distribution   Mwc ÷ number average Mn	2–3	2–3	1.1	1.7	3
Wt% oligomer   (<5% for <1000 Da oligomers, <2% for <500 Da oligomers)	Negligible	Negligible	Negligible	Negligible	Negligible
Ionic character	Neutral	Neutral	Neutral	Neutral	Neutral
Reactive functional groups (RFGs)d and functional group equivalent weight (FGEW)	None and N/A	None and N/A	None and N/A	None and N/A	None and N/A
Low molecular weight leachables	No active leachables by USP class VI (121 °C)	No active leachables by USP class VI (121 °C)	No active leachables by USP class VI (121 °C)	No active leachables by USP class VI (121 °C)	Negligible
Residual monomers	<50 ppb	<50 ppb	<50 ppb	<50 ppb	<0.1 wt%
Ratio of residual monomers to molecular weight (typical value)	~10−12–~10−13	~10−12–~10−14	~10−13	~10−13	<10−5
Structural similarities to RFG of concern	None	None	None	None	None
Reference standard	ASTM D3222‐18a	ASTM D5575‐18	ASTM D3275‐81	ASTM D3275‐81
Physical–chemical properties
Water solubility and octanol/water partition coefficient, Kow	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A
Particle size   (median mass aerodynamic diameter, MMAD, should be >5 µm)	Powders: 5–300 µm pellets: 2–4 mm	Powders: 5–300 µm pellets: 2–4 mm	D50%: 50–70 µm (typical)	D50%: 50–70 µm (typical)	Pellet: 2‐4 μm, flake: 0.54 mm powder: 5–300 micron
Stability
Hydrolysis, light (hν), Oxidation, biodegradation (aerobic and anaerobic)	Stable	Stable	Stable	Stable	Stable
Thermal stability at normal foreseeable use maximum continuous temp. (°C)	150 °C	150 °C	150 °C	150 °C	120 °C
Meets aPLC criteria (Yes or No)	Yes	Yes	Yes	Yes	Yes
Fluorinated polymerization aid (PA) used? (Yes or No)	No	No	No	No	No
Recommended processing/application (use) temperature (T°C)	Processing: 200 °C–250 °C Use max temp: 150 °C	Processing: 180 °C–250 °C Use max temp: 100 °C–140 °C depending on HFP content	Processing: 250 °C–280 °C Use max. Temp: 150 °C	Processing: 250 °C–280 °C Use max. Temp: 150 °C	Molding: 230 °C –330 °C and Use Max same as above at 120 °C

	Fluoroplastics
Supporting Information Data: Chapter	4.6	4.7	4.8	4.9
	FEVE	EFEP	CPT	THV
	Fluoroethylene‐vinyl ether copolymer	1‐Propene, 1,1,2,3,3,3‐hexafluoro‐, polymer with ethylene and 1,1,2,2‐tetrafluoroethylene	1,1,1,2,2,3,3‐Heptafluoro‐3‐[(trifluoroethenyl)oxy]propane polymer with chlorotrifluoroethylene and tetrafluoroethylene	1‐Propene,1,1,2,3,3,3‐hexafluoro‐polymer with 1,1‐difluoroethylene and tetrafluoroethylene
PLC assessment criteriona	cbi	35560‐16‐8	116018‐07‐6	25190‐89‐0
Structure	cbi	–(CH2–CH2)n–(CF2–CF2)m–[CF2–CF(CF3)]l–	–(CF2–CF2)n–(CFCl–CF2)m–[CF2–CF(ORf)]l–	–(CF2CH2)x–(CF2–CF–CF3)y–(CF2–CF2)z
Polymer composition   (must have C, H, Si, S, F, Cl, Br, or I covalently bound to carbon)	Yes	Yes	Yes	Yes
Molecular weight (Mn)b   (Mn >1000 Da and oligomer content <1%)	7000–46 000	130 000	200 000–300 000	131 000
Molecular weight distribution   Mwc ÷ number average Mn	2.0–4.0	4	2–5	1.8
Wt% oligomer   (<5% for <1000 Da oligomers, <2% for <500 Da oligomers)	Mn <1000 range of <3.5% and Mn <500 is <0.7%	Negligible; <0.1 wt% oligomer content	Negligible; <0.1 wt% oligomer content	wt.% <1000: None
Ionic character	Neutral	Neutral	Neutral	Neutral
Reactive functional groups (RFGs)d  and functional group equivalent weight (FGEW)	None and N/A	None and N/A	None and N/A	None and N/A
Low molecular weight leachables	Negligible; cross‐linked as final product	Negligible	Negligible	No active leachables by USP class VI (121 °C)
Residual monomers	0.12%–1.43% non‐fluorinated	Negligible	Negligible	None detected
Ratio of residual monomers to molecular weight (typical value)	10−7–10−8	<10−5	<10−5	~10−13
Structural similarities to RFG of concern	None	None	None	None
Reference standard		ASTM D7472	ASTM D7471
Physical–chemical properties
Water solubility and octanol/water partition coefficient, Kow	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A
Particle size   (median mass aerodynamic diameter, MMAD, should be >5 µm)	Solution or flake 150 nm for emulsion	2–4 mm (pellets)	2–4 mm (pellets)	Pellets ~400–750 µm
Stability
Hydrolysis, light (hν), oxidation, biodegradation (aerobic and anaerobic)	Stable	Stable	Stable	Stable
Thermal stability at normal foreseeable use maximum continuous temp. (°C)	220 °C	130 °C; low melting point 160 °C–190 °C and high decomposiiton temperature of 357 °C–380 °C	200 °C; low melting point 239 °C–251 °C and high decomposition temperature of >400 °C	Continuous use is expected ~room T. (<100 °C as host resin melts at 120 °C); No expected degradation; fluoropolymer degrades >350 °C by TGA
Meets aPLC criteria (Yes or No)	Yes	Yes	Yes	Yes
Fluorinated polymerization aid (PA) used? (Yes or No)	No	No	No	Yes and No
Recommended processing/application (use) temperature (T°C)	180 °C–200 °C	Molding temperature: 200 °C–280 °C; Use max as noted above	Molding temperature: 310 °C–330 °C; Use max as noted above	Melt processing: <350 °C Application: <100 °C (in LLDPE)

Abbreviations: ECTFE, ethylene‐chlorotrifluoroethylene; HFP, hexafluoropropylene; PCTFE, polychlorotrifluoroethylene; PLC, polymer of low concern; PVDF, polyvinylidene fluoride.

a

See OECD (2009) and BIO by Deloitte (2015) for details on characteristics of a “Polymer of Low Concern” and Supporting Information: Chapter 3.

b

Molecular Weight is number average molecular weight which is defined as the total weight of the polymer divided by the total number of molecules. It is the mole fraction of molecules in a polymer sample.

c

Molecular weight is weight average molecular weight which is determined by summing the weights of all the chians and then dividing by the total number of chains. It is the weight fraction of molecules in a polymer sample.

d

For definition of reactive functional group, lists of low‐, moderate‐, and high‐concern functional groups and FGEW limits, see USEPA polymer exemption guidance manual, BIO by Deloitte (2015, pp. 191–192), and USEPA (2010). See Supporting Information.

Table 5

Fluoroelastomers and specialty fluoroplastics—PLC criteria

	Specialty fluoroplastics		Fluoroelastomers
Supporting Information Data: Chapter	4.13	4.14	4.10	4.11	4.12
	Amorphous	Ionomer	FEPM	FKM	FFKM
	Perfluoro(alkenyl vinyl) ether polymer	Sodium or potassium salts of perfluorosulfonic acid/TFE copolymer or perfluorocarboxylic acid/TFE copolymer	Tetrafluoroethylene‐propylene copolymer	1‐Propene,1,1,2,3,3,3‐hexafluoro‐polymer with 1,1‐difluoroethylene copolymer and terpolymers	Tetrafluoroethylene‐trifluoromethyl trifluorovinyl ether copolymer
PLC assessment criteriona	37626‐13‐4	9002‐84‐0, 1314‐23‐4, 409‐21‐2, 111173‐25‐2	27029‐05‐6	9011‐17‐0, 26425‐79‐6, 25190‐89‐0	26425‐79‐6
Structure	See Supporting Information	See Supporting Information	See Supporting Information	Supporting Information	‐(CF2CF2)x ‐[CF2‐CF(OCF3)]y‐(Cure Site Monomer)z
Polymer composition   (must have C, H, Si, S, F, Cl, Br, or I covalently bound to carbon)	Yes	Yes	Yes	Yes	Yes
Molecular weightb   (Mn >1000 Da and oligomer content <1%)	150 000–300 000	>100 000	Various grades vary between 146 000–275 000	30 000–340 000	10 000–1 000 000
Molecular weight distribution   Mwc ÷ number average Mn	1.4–2.5	1.0–2.4	Various grades give various ratios from 1.4 to 3.3	1.2–2.4	1.2–3.5
Wt% oligomer (Figure MWD)   (<5% for <1000 Da oligomers, <2% for <500 Da oligomers)	Negligible	Negligible	<0.01%	Negligible to <1%	Negligible
Ionic character	Neutral	Neutral	Neutral	Neutral	Neutral
Reactive functional groups (RFGs)d	None and N/A	None and N/A	None and N/A	None and N/A	None and N/A
Functional group equivalent weight (FGEW; typical value)	>105	>105	>105	>104–105	>104
Low molecular weight leachables	<1 ppm	<1 ppm	No active leachables	<0.4 ppm to <1 ppm	No active leachables
Residual monomers	<1 ppm	<1 ppm	No residual monomers Only cross‐linking agent at <1 ppm	<50 ppt to <5 ppm	<50 ppb
Ratio of residual monomers to molecular weight (typical value)	>10−5	>10−5	10−11–10−12	>10−10–10−13	0.25 ppt as Mn = 105 (for representative FKM)
Structural similarities to RFG of concern	None	None	None	None	None
Reference standard				ASTM D 1418
Physical–chemical properties
Water solubility and octanol/water partition coefficient, Kow	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A	Insoluble/practically insoluble and N/A
Particle size  (median mass aerodynamic diameter, aerodynamic diameter, MMAD, should be >5µm)	Solution, sheet or pellets	(1) Aqueous dispersion casting (as a film) followed by annealing or (2) Melt extrusion as a membrane (reinforced)	Sheet or crumb	Sheet or block; powders 300–350 µm stability increased/enhanced when cross‐linked	Sheet or block; or “crumb”
Stability
Hydrolysis, light (hν), oxidation, biodegradation (aerobic and anaerobic)	Stable	Stable	Stable	Stable	Stable
Thermal stability at normal foreseeable use maximum continuous Temp (°C)	>250 °C	Sulfonic acid polymer: maximum operating temperature of 175 °C under anhydrous conditions, 220 °C –240 °C in aqueous systems carboxylic acid polymer: use below 120 °C	200 °C	180 °C	200 °C–300 °C
Meetsa PLC criteria (Yes or No)	Yes	Yes	Yes	Yes	Yes
Fluorinated polymerization aid (PA) used? (Yes or No)	Yes and No	Yes and No	No	Yes and No	Yes and No
Recommended processing/application (use) temperature (T°C)	<280 °C	Sulfonic acid polymer: maximum operating temperature of 175 °C under anhydrous conditions, 220 °C–240 °C in aqueous systems carboxylic acid polymer: use below 120 °C	−60 °C–204 °C (AFLAS Technical Document)	Melt processing: <300 °C 160 °C–320 °C (cross‐linking temperature)	160 °C–320 °C (cross‐linking temperature)

Abbreviations: FEPM, trifluoroethylene‐propylene copolymer; FKM, HFP‐VF2 polymer and HFP‐VF2‐TFE polymers; FFKM, TFE‐PMVE perfluoroelastomer; PLC, polymer of low concern.

a

See OECD (2009) and BIO by Deloitte (2015) for details on characteristics of a “Polymer of Low Concern.”

b

Molecular weight is number average molecular weight.

c

Molecular weight is weight average molecular weight.

d

For definition of reactive functional group, lists of low‐, moderate‐, and high‐concern functional groups and FGEW limits, see USEPA polymer exemption guidance manual, BIO by Deloitte (2015, pp. 191–192), and USEPA (2010). See Supporting Information.

The data assessment was done in two ways: Companies could self‐assess the PLC data if they had the technical resources to do so or they could submit their PLC data to a third‐party contractor for an independent technical review. The third‐party consultant hired by PFP was GSI Environmental Inc. The objective was to be able to publish the references and methods behind the PLC data provided for each fluoropolymer in the study. In cases where the data and/or methods contained confidential business information, the third‐party consultant independently evaluated the information supplied before it was shared in a blinded, aggregate form with the participating project companies. In several cases—FKM, PVDF, and ionomers—several companies submitted data for the same fluoropolymer. The data were combined and are presented in Tables 4 and 5. There is no intentional company attribution for the data presented.

The following describes further how the study data were generated and compiled.

• A third‐party consulting company (GSI) was engaged to comment independently on data, methods, and references initially supplied by study participants for their respective fluoropolymers. Several study participants used this third‐party consultant.

• Following the initial third‐party assessment and assembly of the master data Tables 4 and 5 as well as the FKM data in Supporting Information: Table 4.11, a series of subsequent assessments were conducted (within PFP) until all data cells in the tables cited above were backed up with a narrative, a testing method, and/or references where publicly available.

• Where several companies have provided data on the same fluoropolymers, the table data presented provide a multicompany compilation and assessment along with appropriate methods and references.

• Individual companies supplying data are identified as authors, but there is no direct attribution regarding which company supplied which data for this study.

PLC ASSESSMENT RESULTS

This study was conducted on commercial fluoropolymer products using the PLC criteria to characterize their potential hazard. Figure 1 illustrates the PLC criteria used (BIO by Deloitte, 2015; Henry et al., 2018). The pictured criteria encompass structure, physicochemical property, and stability criteria evaluated in the study. Data informing structure criteria, MW, Mn, and MW distribution (MWD), physicochemical property criteria, water and lipid solubility and K_ow, and stability criteria are presented in Tables 4 and 5. The study also gathered structural data on (a) residual monomers, (b) ratio of residual monomers to MW, (c) structural similarities to reactive functional groups (RFGs) of concern, and (d) thermal stability at normal foreseeable maximum continuous use temperatures. Brief descriptions of PLC criteria are provided in Table 3 with additional details, including references for each criterion in Supporting Information: Chapter 3. An additional data point gathered was whether the fluoropolymer(s) presented utilized a fluorinated polymerization aid (PA) during manufacture. The study results are presented in Tables 4 and 5 and summarized below.

Polymer composition: Each of the fluoroplastics, specialty fluoroplastics, and fluoroelastomers assessed in this study met the criterion of polymer composition whereby either fluorine (F) and/or chlorine (Cl) must be covalently bound to the carbon‐only polymer backbone.

MW and MWD: All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the criteria for MW (Mn >1000 Da) and MWD (1–3). The data demonstrate the fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study are high‐MW solid polymers with fairly narrow MWD and negligible to low wt% oligomer content. The MW for fluoroplastics in Table 4 and specialty fluoroplastics in Table 5 ranged from 50 000 to 300 000, and the MWD ranged from approximately 1.4 to 3. We note that FEVE was measured in its uncured state and that, upon curing, its MW increased significantly. The MW and MWD were determined in a variety of ways depending on the fluoropolymer and its solubility (or insolubility) in various solvents. The MW and MWD data for fluoroelastomers and specialty fluoroplastics in the study are presented in Table 5. The MW and MWD varied because of the various grades of fluoroelastomers ranging from 100 000 to 250 000 with some less than (down to 10 000) and greater than (up to 500 000). MWD was on the order of 1.4 to 3.5. Fluoroelastomer MW is lower for uncured fluoroelastomer versus cured fluoroelastomer. Cured fluoroelastomer is the form used in many formed‐use applications (e.g., gaskets and o‐rings). The methods and references for MW and MWD data are presented in the Supporting Information: Chapter 4 with the specific chapter noted in Tables 4 and 5. Methods included size exclusion chromatography (SEC), gel permeation chromatography (GPC) along with osmotic pressure, and parallel plate rheometry methods.

Weight % oligomer: The criteria for wt% oligomer are less than 5% oligomer content for Mn less than 1000 Da, and less than 2% oligomer content for Mn less than 500 Da (BIO by Deloitte, 2015; Henry et al., 2018; see also the Supporting Information). All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the wt% oligomer criteria. Many polymers in the study were reported as “negligible” for oligomers based on analyses conducted. Polymers in the study not cited as negligible have reported numerical data presented in Tables 4 and 5. In addition to SEC and GPC, analytical methods employed included a weight loss upon heating method and the FDA 21 CFR 177.1380 method. The methods and references for wt% oligomer are presented in the Supporting Information: Chapter 4 with the specific chapter noted in Tables 4 and 5.

Ionic character: The fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study are neutral polymers, either containing no ionic groups or may contain anionic at the terminus of their high MW polymer chains as noted in the prior study of fluoropolymers (Henry et al., 2018). Notably different are fluorinated ionomers, which have neutralized (salts) sulfonic acid or carboxylic acid groups pendant to the polymer backbone and as such are neutral and not ionically charged in their polymeric solid form and are low in toxicity and not dermally irritating on skin contact (USEPA, 1997). None of the evaluated polymers in the study have cationic nature. The methods and references for ionic character are presented in the Supporting Information: Chapter 4 with the specific subchapter noted in Tables 4 and 5.

RFG, functional group equivalent weight (FGEW) and structural similarities to RFG of concern: All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the RFG and FGEW criteria. The polymers in this study do not contain the reactive functional groups set forth in the PLC criteria (e.g., acrylates, alkoxysilanes, amines, aziridines, carbodiimides, and so forth; see Supporting Information: Chapter 3). Given that the polymers in this study have no RFGs, the FGEW values in Tables 4 and 5 are very large numbers (such as >10⁴−10⁵) or the value given is not applicable due to the lack of RFGs altogether. Even the polymers with some functional groups present (e.g., fluorinated ionomers) are not reactive. For example, the FEVE polymerization process leads by design to a polymer with neutral and/or anionic end groups. FEVE resins do contain a small amount of hydroxyl and carboxyl functional groups. These functional groups are classified as low concern RFG by the USEPA (1997) and OECD (2009). There are no RFG structural similarities across the polymers in this study.

Low MW leachables (MW < 1000 Da): All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the low MW leachable PLC criteria, which has been widely discussed (see Supporting Information: Chapter 3 for references). Many of the study polymers report no active leachables, whereas the rest cite values less than 1 ppm (Tables 4 and 5). For FEVE, it is reported that some nonfluorinated polymer PA may well remain in the uncured polymer resin. The methods and references for low MW leachables are presented in the Supporting Information: Chapter 4 with the specific chapter noted in Tables 4 and 5. The data presented in Tables 4 and 5 were determined for each of the respective polymers in this study using techniques such SEC and GPC as the predominant analytical methods along with the use of USP Class VI testing. Additional methods included 21 CFR 177.2600 (USCFR, 2022) and the USEPA's toxicity characteristic leaching procedure (TCLP; SW‐846 Test Method 1311; USEPA, 1992).

Residual monomers and ratio of residual monomers to typical MW: PLC criteria of equal interest to the low MW leachables are the residual monomers and the ratio of residual monomers to typical MW (see Supporting Information: Chapter 3 for references). All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the residual monomers and ratio of residual monomers to typical MW PLC criteria. The study data presented in Tables 4 and 5 show the polymers in this study have residual monomers ranging from less than 50 ppb for several fluoropolymers and up to less than 0.1% for PCTFE based on the methods utilized. Fluoroelastomers in this study have residual monomers ranging from less than 50 ppb up to less than 5 ppm. Residual monomers were determined in several ways including dynamic and static headspace gas chromatography/mass spectrometry (GC/MS) at 150 °C. The monomers used in most cases have very low boiling points and are thus readily volatilized (and captured or destroyed) during polymer manufacture processing and drying steps. The methods and references for residual monomer determination are presented in the Supporting Information: Chapter 4 with the specific chapter noted in Tables 4 and 5. Given the very low residual monomer levels reported, the ratio of residual monomers to polymer MW range from 10⁻¹¹ to 10⁻¹³ for the study polymers.

Water solubility and octanol/water partition coefficient (K_ow): The fluoroplastics, specialty fluoroplastics, and fluoroelastomers in this study are solids that are hydro‐ and oleophobic, practically insoluble in both water and n‐octanol. Therefore, a K_ow cannot be computed and is not applicable to these substances. It is worth noting that the practical lack of solubility in water (<10 mg/L) and n‐octanol indicate the inability for the study fluoropolymers to actively or passively cross cell membranes. This does mean there is no indication that these polymers can bioaccumulate or bioconcentrate in biota (Henry et al., 2018 and this study). The methods and references for solubility are presented in the Supporting Information: Chapter 4 with the specific chapter noted in Tables 4 and 5.

Particle size: To meet the PLC assessment criteria for particle size, a powder must be 5 µm or greater in size (median mass aerodynamic diameter [MMAD]). All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the particle size PLC criterion. As shown in Tables 4 and 5, the fluoroelastomers in this study are provided in sheets, blocks, pellets, or “crumb,” and the fluoroplastics and specialty fluoropolymers in this study are provided in the form of powders, pellets, sheets, flake, or in dispersions. References and additional information regarding the form of the study polymers is provided in the Supporting Information: Chapter 4.

Stability: All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the PLC criteria for hydrolysis, light stability, oxidative stability, and aerobic and anaerobic biodegradability (e.g., breakdown into species with Mn <1000 Da). Public literature has abundant thermal, chemical, and biological stability data for the polymers in this study as stability is a hallmark property for these polymers (Ebnesajjad, 2017). For biodegradation, the assessments were largely made based on property data of the study polymers demonstrating they are insoluble and stable in environmental media and thus are not expected to be bioavailable and therefore not biodegrade.

Additionally, published literature reports (Drobny, 2016; Ebnesajjad, 2017; Grot, 2013; Henry et al., 2018; Polymer Industry Association [PIA], 2019) that the study polymers are stable at foreseeable maximum continuous use temperatures presented in Tables 4 and 5. All polymers, including fluoropolymers can degrade when misused or when heated above their recommended use temperatures (Fluoropolymer Products Group of Plastics Europe [FPG], 2012; PIA, 2019). Of course, users are expected to follow guidance for use provided by manufacturers. Hence, the recommended temperatures for reasonably foreseeable use for the study substances are presented in Tables 4 and 5. References and additional information regarding the stability of the study polymers is provided in the Supporting Information: Chapter 4.

Fluorinated PA: If a fluorinated PA was used in the manufacture of the polymer, it was reported for each fluoropolymer in this study. Nine of the 14 fluoropolymers in the study were reported not to have used a fluorinated PA in their manufacture. It is industry practice to use fluorinated PAs when it is necessary to obtain specific end‐use property or performance requirements generally related to very high‐polymer MWs (see also Supporting Information: Chapter 7). For five study polymers, THV, FKM, FFKM, fluorinated ionomers, and amorphous fluoropolymers, a response of “Yes and No” was provided indicating that for some polymer grades a fluorinated PA is used, but not for others. See Supporting Information: Chapter 4 for additional information.

Results summary: This study examined three fluoroelastomers, nine fluoroplastics, and two specialty fluoroplastics: ionomers and amorphous. Data for each were gathered from the author companies and assessed by the PLC criteria applicable to the polymer itself “in use” (BIO by Deloitte, 2015; Henry et al., 2018; OECD, 2009). All fluoroplastics, specialty fluoroplastics, and fluoroelastomers in the study met the PLC criteria based on the data presented in Tables 4 and 5 with additional details provided describing methods and references in the Supporting Information: Chapter 4.

Including the four fluoroplastics in the prior study (Henry et al., 2018), data for 18 fluoropolymers have been provided for PLC assessment. These polymers have a wide range of compositions and structures and represent most of the global commercial fluoropolymer market (see additional text in the Discussion). These 18 fluoropolymers represent the major fluoropolymers manufactured and are used worldwide in innumerable critical end‐use products and applications. Tables 1 and 2 highlight examples of the end‐use markets as well as critical functionality and benefits these polymers provide.

Each of the assessed polymers in this study are insoluble in both water and n‐octanol, and thus K_ow is not applicable. This lack of solubility in water and octanol confirms that fluoropolymers are not mobile in the environment and are not bioaccumulative and not able to bioconcentrate. The stability studies reported here on each of the study fluoropolymers reveal their stability in terms of light, hydrolysis, heat, oxidation, and biodegradation. When coupled with the lack of solubility, these fluoropolymers are most often characterized as relatively inert materials in the environment. Like any other chemical material or product, it is important to follow the fluoropolymer manufacturer's recommended use and temperature conditions. Tables 4 and 5 describe these recommendations for each fluoropolymer. As reported, the physical forms of the fluoropolymers are largely pellets, blocks, crumb, sheets, some powders (all with MMAD >5 µm). The solid fluoropolymers are not nanoparticles, and concerns related to nanoparticles do not apply during normal product use. Due to the properties described above for the assessed fluoropolymers—large molecules with no water solubility—the fluoropolymers are biologically inert without the practical ability to cross cell membranes.

During the evaluation of the study fluoropolymers, there was a conscious focus on several core PLC parameters: MW, low MW leachables, % oligomers, and residual monomers, which are direct outcomes related to fluoropolymer manufacturing. In addition to what is reported here in Tables 4 and 5 for the fluoropolymers themselves, industry efforts to manage emissions during manufacturing are discussed below.

DISCUSSION

Fluoropolymers have substantial, unique societal value: Fluoropolymers possess a remarkable combination of properties and functional characteristics, as shown in Tables 1 and 2, that make them valued materials of choice in a broad range of industries and applications critical to life and a sustainable environment in the 21^st century. Their unparalleled combination of properties and performance characteristics deliver functionality to a wide variety of products and systems critical to achieving important societal goals (Amcham, 2020c; FPG, 2021a; Wood, 2020b). They are strategically important to innovation in vital sectors of the global economy requiring high‐speed, high‐volume data transmission, miniaturization, or operations in extreme temperatures. Moreover, they are crucial to achieving important societal goals such as decarbonization, renewable energies, and/or competitiveness in the digital transition (FPG, 2021a). Fluoropolymers are indispensable for critical applications in the chemical, electronic, semiconductor, healthcare, and transport sectors and the deployment of 5G networks (FPG, 2021a). For many critical applications, fluoropolymers are the material of choice because alternatives are unable to provide the full complement of performance and functionality required. As such, there are currently no viable commercial alternatives to fluoropolymers in virtually every critical application in which they are used (FPG, 2021a, 2017; PFP, 2020).

Commercial fluoropolymers in this study meet the PLC criteria: Widely used by regulators, PLC criteria have been established around the world and documented by OECD expert groups as an appropriate hazard assessment methodology for polymers in‐use and can effectively identify low risk fluoropolymers to help prioritize regulatory action (BIO by Deloitte, 2015; OECD, 1993, 2009). Here, we present PLC data, for hazard assessment, that define a group of fluoropolymers' “in‐use” properties. PLC is not a comprehensive life‐cycle assessment tool. Full life‐cycle assessments consider all phases of product “life” including creation (manufacturing) and end‐of‐life (disposal). Information on manufacture and end‐of‐life is provided later in this study. Recently, polymers have been under increased regulatory scrutiny. In 2019, the industry‐led European Centre for Ecotoxicology and Toxicology of Chemicals (ECETOC) developed a Conceptual Framework for Polymer Risk Assessment (“CF4Polymers”; ECETOC, 2019). CF4Polymers provides guiding elements to be considered in assessing potential ecological and human health hazards and risks posed by polymer substances. CF4Polymers also considers specific life‐cycle stages of polymer products and their associated routes of exposure. The authors of the CF4Polymers framework support the PLC approach as a means to accomplish polymer risk assessment. They specifically support the findings of Henry et al. (2018) and state that they are “unaware of scientific evidence to justify generally assigning fluoropolymers the same level of regulatory concern as other PFAS” (ECETOC, 2019). In 2020, the European Commission contracted a study to propose criteria to identify PRR under REACH (Wood, 2020a). The report states that the authors consider fluoropolymers meeting the criteria to be considered PLC, “following the recommendations of Henry et al. (2018).”

The properties and characteristics of fluoropolymers are anchored in the strength of the carbon–fluorine bond, which render them highly stable (thermally, chemically, and biologically), inert, and durable—long lasting in use—under exacting and high‐performance conditions. Physical, chemical, thermal, and biological stability are important criteria for a polymer to be considered a PLC. The data presented in Tables 4 and 5 demonstrate that commercial fluoropolymers from the author companies meet the criteria to be considered PLC. The PLC criteria for physicochemical properties reflect the state of the polymers in this study, solids, as well as their inertness and stability. None of the fluoropolymers assessed in this study were soluble in water or octanol. They are biologically inert, insoluble in water and octanol, and not expected to move in or between environmental media. Fluoropolymers are also twice as dense as water. These properties and water insolubility mean fluoropolymers are not mobile in the environment and therefore would not be expected to be found in sources of drinking water. Fluoropolymers are neither bioavailable nor bioaccumulative. These solid polymers cannot be absorbed through a cell membrane via passive or active transport and do not bind or interact with the cell surface (see also Supporting Information: Chapter 8). In addition, whereas aquatic and mammalian toxicology studies of fluoropolymers may be desirable for some, they are technically difficult for insoluble, solid, high‐MW polymers. The OECD test guidelines reiterate this in many cases. This is confirmed for example in REACH Annex VII guidance, which repeatedly states toxicity is unlikely to occur “if a substance is highly insoluble in water or the substance is unlikely to cross biological membranes” (see Supporting Information: Chapter 9).

Finally, structure criteria including MW, MWD, residual monomer(s), oligomers, and other synthesis by‐products, as represented by low MW extractables and leachables have been determined for the fluoropolymers presented and meet values established for the PLC criteria and regulated uses (e.g., USP). The concentrations in the fluoropolymer that have been evaluated are extremely low, reflective of effective manufacturing processes that minimize these compounds complemented by capture and/or destruction systems for such materials. For additional information, see the section below discussing responsible manufacturing. This study and prior work (Henry et al., 2018) provide a guide for other global fluoropolymer manufacturers to gather and present data on additional commercial fluoropolymers to determine if they too meet the PLC criteria.

Fluoropolymer stability, aka persistence, is not an intrinsic hazard: Fluoropolymers are stable, inert, solid materials. Fluoropolymers resist degradation by acids, bases, oxidants, reductants, photolytic processes, microbes, and metabolic processes; for this reason, they are thermally, chemically, and biologically highly inert. Fluoropolymer stability was presented in the introduction and is further considered in the Supporting Information: Chapters 4 and 5. Fluoropolymers are not expected to degrade under environmental conditions or normal use and processing conditions (Wood, 2020a). They are stable and remarkably durable and are therefore persistent. However, persistence alone does not imply that there is a present or future risk to human health or the environment (Rüdel et al., 2020). Persistence itself is not an intrinsic hazard, as it does not in itself imply or inform the potential for an adverse effect (aka toxicity). There is no language in REACH supporting the notion that persistence alone justifies risk‐management measures. REACH has regulated persistence in combination with other properties that do inform potential hazards. In fact, REACH combines persistence with bioaccumulation and toxicity (or “very persistent” with “very bioaccumulative/very mobile” vPvB/vPvM) to justify designation as a substance of very high concern (SVHC) and consideration of potential risk‐management measures for uses associated with unacceptable risk. Therefore, persistence on its own does not justify the need for specific risk‐management measures. Fluoropolymers themselves are persistent, but they are not bioaccumulative, not mobile, and not toxic and therefore not SVHCs from a regulatory perspective (Ruwona and Henry, 2021).

PFAS grouping and segmentation—Scope of regulatory measures: The OECD definition of PFAS is based only on chemical structure (OECD, 2021). It describes a universe of fluorinated organic substances with vastly different physical, chemical, and biological properties, including polymers and nonpolymers; solids, liquids, and gases; highly reactive and inert substances; soluble and insoluble substances; and volatile and involatile substances and is too broad to allow effective, science‐based assessment and regulation of chemical compounds as an entire group (Amcham 2020a; BDI, 2021; Buck et al., 2021; Orgalim, 2021; Wallington et al., 2021). A 2021 OECD report states: “it is highly recommended that such diversity be properly recognized and communicated in a clear, specific and descriptive manner” and “the term ‘PFASs’ does not inform whether a compound is harmful or not, but only communicates that the compounds under this term share the same trait for having a fully fluorinated methyl or methylene aliphatic carbon moiety” (OECD, 2021).

In this context, the available property data (Tables 4 and 5) reveal that fluoropolymers have distinctly different properties from nonpolymeric PFAS and from SCFPs that have a polymeric backbone that does not contain C–F bonds directly attached to it. The perfluoroalkyl moiety in SCFPs is found in a side‐chain connected via a functional group to the polymer backbone and “can potentially lead to the formation of nonpolymer PFAS as a result of degradation” (Fluoropolymer Products Group of Plastics Europe [FPG], 2021b; Wood, 2020a; see Supporting Information: Chapter 6). Segmentation that clearly differentiates the broad PFAS family according to their properties, rather than using a structure‐based classification alone (OECD, 2021), is needed for a scientifically sound, risk‐based regulatory approach. Regulating all PFAS as one homogenous group (ECHA, 2020) absent consideration of their properties, particularly when the properties are so demonstrably different, neglects basic scientific consideration of these properties, which are the foundation of substance differentiation. The USEPA does not consider all PFAS to have similar risk profiles and therefore they are following a categorical grouping approach based on information about similarities in structure, physicochemical properties, and existing test data on the toxicity of PFAS (USEPA, 2021b). Therefore, segmentation based on properties should be conducted before performing any grouping‐based risk assessment, placing stable, nonhazardous fluoropolymers that meet the criteria to be considered PLC in a separate category (see also Supporting Information: Chapter 6).

Fluoropolymer market perspective: The commercial fluoropolymer global market sales have been reported to be approximately 230 000 MT (Dams & Hintzer, 2017). Given the expected fluoropolymer market growth, ranging from approximately 4%–5% to 7%–8% (Allied Market Research [AMR], 2022; Future Market Insights [FMI], 2022; FPG, 2021a; Globe Newswire, 2021), a pro forma market table was created for 2021 using a 5% growth rate. Adding ionomers as well as updated amorphous market information (company data) to the above, the total commercial fluoropolymer market sales is estimated to be approximately 330 000 MT in 2021 (see Supporting Information: Chapter 10). Four fluoropolymers: PTFE, FEP, PFA, and ETFE, were the focus of the first fluoropolymer PLC paper (Henry et al., 2018) and account for approximately 64% of fluoropolymers sold globally in 2021 (pro forma basis). The sales volume of these four fluoropolymers is represented by the first four bars in Figure 10.1 in Supporting Information: Chapter 10. This study discusses 14 fluoropolymers representing an additional 32% (pro forma basis) of the global fluoropolymer market. Therefore, this study, in combination with Henry et al. (2018), presents PLC data from the cited manufacturers of commercial fluoropolymers representing approximately 96% of the global commercial fluoropolymer market that meet the criteria to be considered PLC. The projected 2021 sales volume of the major types of commercial fluoropolymers covered in this study (PVDF, FKM, FEPM, amorphous, ionomers, THV, ECTFE, PCTFE, and FFKM, EFEP, CTP, and FEVE) are also represented in Figure 10.1 in Supporting Information: Chapter 10. As noted, estimated market volumes were provided for the sum of FEPM, CPT, EFEP, and FEVE as well as a small “others” category. The fluoropolymer polyvinyl fluoride (PVF) was not covered by these two papers but is also shown in Figure 10.1 in Supporting Information: Chapter 10. Other fluorinated polymers, perfluoropolyethers, and SCFPs are not addressed in this study (see Supporting Information: Chapter 6).

FLUOROPOLYMER LIFE‐CYCLE CONSIDERATIONS

This study focuses on the properties of the 14 selected commercial fluoropolymers themselves in‐use providing data that demonstrate they meet the criteria to be considered PLC. Additionally, the life‐cycle stages of fluoropolymer creation (manufacturing) and disposal at the end of industrial or consumer use (end‐of‐life) are important to consider. The primary focus in these life‐cycle stages is generally nonpolymer PFAS from the manufacturing process or fluoropolymer degradation in end‐of‐life disposal (ECHA, 2020; FPG, 2021a; Guelfo et al., 2021; Lohmann et al., 2020).

The long‐established life‐cycle assessment approach to environmental protection and risk management first considers the extent of emissions, their toxicity, and their exposure potential (Guinee et al., 2011). When emissions are sufficiently large in scope, toxicity, and exposure potential, emission‐management methods are then considered, including process input changes and emission controls to reduce or eliminate the risk of the emissions. Fluoropolymer manufacturing and disposal life‐cycle stages were discussed in the paper that first presented fluoropolymer PLC data (Henry et al., 2018). Here we provide an update and current perspective.

Responsible manufacturing: As corroborated by the data presented here and in prior work (Henry et al., 2018), a large volume percentage and number of commercial fluoropolymers are manufactured that meet the criteria to be considered PLC. Emissions from fluoropolymer manufacture are a key product life‐cycle focus. The main focus during the manufacturing phase is not directly related to fluoropolymers but from emissions. Emissions of concern may include nonpolymer PFAS such as fluorinated PAs, unreacted monomers, oligomers, or other unintended by‐products formed during manufacturing. It is important to note that, although some high‐MW fluoropolymers require use of a fluorinated PA in manufacturing (see also Supporting Information: Chapter 10), it has been reported that at least 50% of commercial fluoropolymers are made without one (Pro‐K Fluoropolymer Group, 2021).

Recently, a group of fluoropolymer member companies of FPG voluntarily committed to responsible manufacturing principles through the commissioning of a Regulatory Management Option Analysis, developed by independent consulting firm Chemservices (FPG, 2021a). Member companies of this group are working on individual projects and joint projects at the trade association level with third‐party experts. Specifically, companies have committed to continuously improving and/or developing the best available techniques in the manufacturing process, managing environmental emissions, developing R&D programs for the advancement of technologies allowing for the replacement of nonpolymer PFAS PAs and/or working with downstream users to increase the recyclability and reuse of its products in line with the objectives of circular economy (FPG, 2021a). Implementation of this voluntary industry initiative to address concerns relating to fluoropolymers will strengthen already ongoing efforts performed by the fluoropolymer industry promoting responsible manufacturing practices. In addition, member companies are committed to working with EU authorities to establish and implement technical actions to guarantee adequate control of the risks derived from the manufacture and use of fluoropolymers to mitigate such risks wherever possible. This will be done following transparency principles and agreements to monitor progress. For example, important emission reduction has been demonstrated by major fluoropolymer manufacturers including fluorinated PA recovery for reuse, 99% removal of fluorinated PA in wastewater treatment, and 99.99% capture and destruction efficiency of gaseous emissions routed to a thermal oxidizer (Chemours, 2021c), as well as 99–99.9 plant emission reductions (Daikin, 2021c, 2022). Four other companies have reported replacement of fluorinated PAs with nonfluorinated PAs (Arkema, 2008, 2021b; Chemours, 2022; Gujarat Fluorochemicals Limited, 2022; Solvay, 2022). These are substantial efforts toward mitigating emissions associated with fluoropolymer manufacturing being worked on by fluoropolymer manufacturers. This study and the prior study (Henry et al., 2018) provide a guide for other global fluoropolymer manufacturers to gather and present data on their commercial fluoropolymers in‐use demonstrating that they meet the PLC criteria.

End‐of‐use: At the end of industrial or consumer use, fluoropolymers may be disposed via the following routes: landfill, incineration (e.g., waste‐to‐energy [WTE] facilities), or reuse/recycling. There is considerable data demonstrating that fluoropolymers such as PTFE do not degrade in the environment or release substances of toxicological or environmental concern (FPG, 2021a; Hintzer & Schwertfeger, 2014). FPG member companies are working with the industry and end users on this subject and are engaged in a research project aimed at identifying conditions required for proper disposal (incineration) of fluoropolymers (FPG, 2021a).

Fluoropolymers are chemically, thermally, and biologically stable (Henry et al., 2018; this study) and therefore are not expected to transform to dispersive nonpolymeric PFAS when disposed of in a landfill. A recent study presented results from OECD guideline biodegradation studies demonstrating that PTFE is stable and does not degrade under environmentally relevant conditions (Ruwona and Henry, 2021). Further, fluoropolymers that meet the criteria to be considered PLC, such as those in this study and prior work (Henry et al., 2018), have negligible leachables, unreacted monomers, and oligomers most likely destroyed in fluoropolymer use processing and would therefore not be expected to significantly contribute to landfill leachate (Ruwona and Henry, 2021).

Available data reveal that fluoropolymers are mineralized (i.e., all C–F bonds broken, hydrofluoric acid generated, and scrubbed to calcium fluoride) under commercial WTE incineration operating conditions (Aleksandrov et al., 2019; Bakker et al., 2021; DEC, 2021; Giraud et al., 2021a, 2021b). In recent pilot scale studies representative of full‐scale WTE facilities, the most common form of end‐of‐life destruction conducted on PTFE found that combustion converted the fluorine into controllable hydrogen fluoride gas and that, of the 31 PFAS studied, no fluorine‐containing products of incomplete combustion were produced above background levels (Aleksandrov et al., 2019). Further, a recent study investigating the presence of PFAS in waste incinerator flue gas stated: “based on a literature review, RIVM expects that most of the PFASs will largely degrade during the incineration process and then be removed when the flue gases are cleaned. The remaining PFASs are expected to be removed during the recovery of the carbon dioxide” (Bakker et al., 2021). The RIVM report affirmed that PTFE is the most stable fluorine‐containing polymer. For PTFE, the RIVM report concluded that complete thermal decomposition is achieved at a temperature of approximately 800 °C. It was therefore assumed that other fluorine‐containing polymers also thermally decompose completely at a temperature of 800 °C. Temperatures at the pyrolysis front and the combustion front in the waste‐burning bed range from 900 °C to 1100 °C (Asthana et al., 2006; Ménard et al., 2006), which is well above 800 °C, the temperature at which the complete thermal decomposition of PTFE is achieved (Bakker et al., 2021). Studies for additional fluoropolymers and those with additional pilot and/or full‐scale fluoropolymer studies would contribute to this body of data and further affirm their results. The PFP and FPG currently have joint projects working on these potential contributions.

Recycling of fluoropolymer products and articles containing fluoropolymers is difficult because separation of the fluoropolymer from the end products is not always possible (FPG, 2021a; Hintzer & Schwertfeger, 2014; Pro‐K Fluoropolymer Group, 2018). This is because fluoropolymers are used predominantly in small components of larger finished articles involving a wide variety of materials. There are several options to recycle fluoropolymer products. In primary recycling, solid fluoropolymer waste is ground and later fed back into the manufacturing cycle of some fluoropolymer products. Recycled fluoropolymers may be used in high‐end applications when correctly collected, cleaned, and reprocessed. In secondary recycling, solid fluoropolymer waste is ground, followed by degradation to approximately 1% of the original degree of polymerization by using electron beams, gamma rays, or thermomechanical degradation. The recovered material can be used in the manufacturing of new fluoropolymer products. Lastly, in tertiary recycling or upcycling, solid fluoropolymer is ground, then decomposed into the starting monomers at temperatures higher than 600 °C (pyrolysis) to obtain the same chemical components from which the fluoropolymer was manufactured; monomers, such as tetrafluoroethylene, are purified by distillation, and can then be reused to manufacture new fluoropolymer (3M, 2021; Schlipf & Schwalm, 2014). For the primary and secondary schemes, recycling treatments can be undertaken by the manufacturers of fluoropolymers themselves (onsite), or at a larger scale, mainly by specialist recycling companies. The upcycling needs to be colocated to a fluoropolymer manufacturing plant that can use tetrafluoroethylene.

Primary and secondary recycling is limited because of the presence of fillers, colorants, and other materials in the composition of their final articles. Further, recycling might not work for all end‐of‐life components, as they are used predominantly in small components of larger finished articles involving a wide variety of materials. Therefore, collecting and dismantling for recycling might not be feasible for all products (FPG, 2021a; Hintzer & Schwertfeger, 2014; Pro‐K Fluoropolymer Group, 2018). However, it should be noted that upcycling treatment is applicable to some articles containing fluoropolymers, such as pipe liners in chemical plants, as well as other plant components such as pumps, tank liners, seals, hoses, compensators, and many other fluoropolymer components and systems. These are the products for which the high quantities of fluoropolymers are used offering significant recycling potential.

SUMMARY

This study has described the composition, uses, performance properties, and functionalities of 14 commercially available fluoropolymers, including fluoroplastics and fluoroelastomers. Fluoropolymers are the preferred material of choice because of their unique combination of properties, which are not achievable from other materials or via other functions. As a result, fluoropolymers have become a critical mainstay for society and are useful to modern living, as they provide vital, reliable functionality to a broad range of industrial and consumer products. Further, the study has presented data demonstrating the subject fluoropolymers satisfy the widely accepted polymer hazard assessment criteria to be considered PLC. The data presented demonstrate the fluoropolymers in the study are thermally, biologically, and chemically stable, negligibly soluble in water, nonmobile, nonbioavailable, nonbioaccumulative, and nontoxic, and contain low levels of impurities. These results further demonstrate that the fluoropolymer class should be considered distinctly different and should not be grouped with other PFAS for hazard assessment or regulatory purposes. When combined with earlier work (Henry et al., 2018), the study demonstrates that commercial fluoropolymers are available that meet the criteria to be considered PLC, which represent approximately 96% of the global fluoropolymer market. Lastly, emissions from fluoropolymer manufacture and disposal at end‐of‐use are a product life‐cycle focus. Emissions may include nonpolymer PFAS such as fluorinated PAs, unreacted monomers, oligomers, or other unintended by‐products formed during manufacturing. Fluoropolymer manufacturers recently committed voluntarily to responsible manufacturing principles by continuously improving and/or developing the best available techniques in the manufacturing process, managing environmental emissions, developing R&D programs for the advancement of technologies allowing for the replacement of fluorinated PAs, and/or increasing recyclability and reusing fluoropolymers in line with the objectives of circular economy.

ACKNOWLEDGMENT

The authors thank GSI Environmental for assisting with this study as well as the many colleagues, including Thomas Labour, Florence Churlaud, Catherine Savary, and Betsy Edhlund who provided valuable knowledge to accomplish the study, and all the reviewers for providing valuable comments on this manuscript. There are no funders to report for this submission.

CONFLICT OF INTEREST

The authors are employed by companies that commercially manufacture fluoropolymers. SHK is an independent fluorotechnology consultant working on behalf of AGC Chemicals Americas Inc. and principal of BeachEdge Consulting LLC.

DATA AVAILABILITY STATEMENT

Data gathered for this paper is presented in the paper itself and the Supporting Information: Data file provided. Additional data are available upon request from the corresponding author Stephen Korzeniowski ([email protected]).