What is PFAS: Impending REACH Regulations and TRP’s Compliant Fluropolymers

FFKM, or perfluoroelastomers, are a group of elastomers that are used across a wide range of industries.

By Emily HD

8 min read

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What is PFAS: Impending REACH Regulations and TRP’s Compliant Fluropolymers

PFAS regulation is currently one of the most widely discussed topics in the polymer and elastomer industry. Though PFAS chemicals are used across a wide variety of critical applications, including electronics and semiconductors, automotive, aerospace, medical devices and chemical manufacturing and processing, their use is under increasing scrutiny. The European Chemicals Agency (ECHA) is currently evaluating a proposal to heavily restrict over 10,000 per- and polyfluoroalkyl substances (PFAS) due to their persistence and risk to the environment and human health.

Understanding the difference between fluoropolymers, polymerisation aids and residual substances is essential when selecting materials for demanding industries such as hydrogen systems, chemical processing, aerospace and semiconductor manufacturing.

This article explains the fundamentals of PFAS in polymers, the role of fluoropolymers in sealing technology, how evolving REACH regulation may affect the supply chain, and what you need to know about their upcoming regulation when choosing the most appropriate elastomer materials for your custom rubber seals.

What is PFAS?

PFAS stands for per- and polyfluoroalkyl substances, a large family of fluorinated chemicals that includes thousands of individual compounds. These substances are widely used in industrial materials because fluorine-carbon bonds provide exceptional properties such as:

  • high chemical resistance
  • excellent thermal stability
  • low surface energy
  • resistance to aggressive solvents

However, PFAS is a broad category that includes two very different types of materials, which is where much of the confusion arises. This includes low molecular weight PFAS and polymeric PFAS.

Low molecular weight PFAS

These are smaller molecules typically used as polymerisation aids, surfactants, and processing additives. Examples of low molecular weight PFAS include PFOA, PFOS, PFHxS, and C9-C14 PFCAs. Because of their small molecular size, these compounds can be more environmentally mobile.

Polymeric PFAS

Polymeric PFAS are large molecular weight polymers used as engineering materials. Examples of polymeric PFAS include PTFE, FKM, FFKM, and TFM. These materials consist of long polymer chains and behave very differently from small-molecule PFAS.

During polymer manufacture, small molecule substances used in polymerisation are typically removed during processing and purification stages before the polymer reaches downstream manufacturers. These molecules are targeted for capture and disposal rather than being emitted. For example, manufacturers such as Chemours have reduced their FOC process emissions to air and water by 76% since 2018. 

Where PFAS appears in the fluoropolymer supply chain

Understanding where PFAS chemicals appear in the supply chain helps explain the difference between polymer materials and polymerisation aids.

It’s important to note that most regulatory discussions focus on polymerisation aids used during production, rather than the finished polymer materials themselves.

What are fluoropolymers?

Fluoropolymers are polymers that contain carbon-fluorine bonds in their molecular structure. These bonds provide unique performance characteristics that make them essential for demanding industrial environments. They have many key properties, which include:

  • Outstanding chemical resistance
  • High temperature capability
  • Low permeability to gases and fluids
  • Long operational lifetime
  • Resistance to ageing and degradation

In sealing technology, fluoropolymers commonly used are fluoroelastomers (FKM) and perfluoroelastomers (FFKM). These materials are used in applications where conventional elastomers would fail, including:

As fluoropolymers fall under the PFAS definition, their role in industrial supply chains is being closely evaluated within the current regulatory discussions.

Residual PFOA and PFOA-related substances

One of the most common questions from engineers is whether fluoropolymers contain residual PFAS substances such as PFOA.

To investigate this, TRP Polymer Solutions conducted third-party PFAS extraction testing on several of its fluoroelastomer materials. Testing was performed using EN ISO 23702-1:2023 with THF extraction, targeting a wide range of low Mw PFAS compounds, including:

  • PFOA and related substances
  • PFOS and related substances
  • PFHxS compounds
  • long-chain perfluorocarboxylic acids

Our results were as follows:

Low Mw PFAS testing results for selected TRP materials

Material Measurement Result
TRPlast® 260B Not detected Pass
TRPlast® 300B Not detected Pass
TRPlast® LT45 Not detected Pass
TRPlast® LT45G Not detected Pass
TRPlast® 330B Not detected Pass

Across all tested materials, no low Mw PFAS compounds were detected above the laboratory reporting limits, demonstrating the effectiveness of TRP’s manufacturing and formulation processes.

PFAS substances analysed during testing

Chemical group Reporting limit
PFOS and related substances 1000 ppb (sum)
PFOS and its salts 25 ppb (sum)
PFOA and its salts 25 ppb (sum)
PFOA-related substances 1000 ppb (sum)
PFHxS and its salts 25 ppb (sum)
PFHxS-related substances 1000 ppb (sum)
C9–C14 PFCAs and their salts 25 ppb (sum)
C9–C14 PFCAs related substances 260 ppb (sum)
PFHxA and its salts 25 ppb
PFHxA-related substances 1000 ppb (sum)


These results confirm that the tested TRP rubber materials contain no detectable residual PFAS substances above laboratory reporting limits. Therefore, when you purchase a TRPlast® O-ring, it does not contain the low Mw PFAS substances noted above. Please see our whitepaper on residual PFOA and PFAS testing of FFKM sealing materials for more information.

More materials were tested, so please contact us if you require further information on this aspect.

Impending PFAS regulation under REACH, and what this means for fluoropolymers

The European Chemicals Agency (ECHA) is currently evaluating a proposal to restrict PFAS under the REACH regulatory framework. This proposal has generated significant discussion across industries that rely on high-performance fluoropolymers.

Updated discussions in 2025 introduced additional application-specific derogations, covering sectors such as:

  • Semiconductor manufacturing
  • Energy technologies, including fuel cells and electrolysers
  • Batteries and electrical infrastructure
  • Industrial machinery and sealing systems
  • Transport and aerospace applications

These exemptions recognise the critical role that fluoropolymers have in modern industrial systems and the lack of viable alternatives for many applications. Industry groups have also proposed exemptions for fluoropolymers themselves, given their large molecular size and low environmental mobility relative to smaller PFAS compounds.

Our fluorosurfactant-free elastomers

As the regulatory landscape evolves, many manufacturers are exploring ways to reduce or eliminate fluorinated surfactants used during polymer production.

TRP Polymer Solutions formulates many of its elastomer materials in-house, allowing us close control over raw materials and processing methods. Where practical, fluorosurfactants are removed from the manufacturing process and are not intentionally added to elastomer compounds.

We have also developed fluorosurfactant-free FFKM materials, including the NFS75B compound. The compression set performance can be seen below:

These materials aim to preserve the performance expected from TRPlast® perfluoroelastomers while reducing the presence of small-chain fluorinated surfactants during manufacture.

Development work in this area continues, and TRP is actively working with customers to evaluate these materials in demanding sealing applications.

What does means for engineers selecting sealing materials

For engineers working in highly regulated industries, PFAS legislation adds another factor to consider when selecting materials. Key common questions are:

Do TRP’s material contain PFAS surfactants?

TRP FFKM materials do not contain PFAS surfactants. Some FKM formulations may vary depending on material type. TRP are currently updating the material datasheets to provide information on whether a material is manufactured with or without fluorosurfactants. 

What are the residual PFOA levels?

In the entire TRPlast® range, testing shows no detectable PFOA or related low Mw PFAS substances.

Are fluorosurfactant-free materials available?

For FFKMs; alternative materials such as NFS75B are available where fluorosurfactant-free production is required. Some FFKMs are also already using fluorosurfactant-free technology, and we are updating our datasheets to clarify this. But technically, all TRPlast® articles are fluorosurfactant-free.

For FKMs; most grades are manufactured without fluorosurfactants. However, some grades are currently being reformulated to remove fluorosurfactants from the manufacturing process. We are creating new datasheets to clarify this.

Will current materials remain available under REACH?

Current materials remain available while TRP continues to monitor regulatory developments.

PFAS regulation and our future commitments

PFAS regulation will continue to evolve as regulators balance environmental protection with the need for high-performance materials in critical technologies. For demanding sealing applications, fluoropolymers remain essential materials as a result of their unique chemical resistance and durability.

By combining in-house formulation expertise, independent testing and ongoing development of fluorosurfactant-free compounds, TRP Polymer Solutions is helping customers prepare for future regulatory changes while maintaining the performance required for critical sealing systems. 

Fully Compliant Custom Sealing Products at TRP Polymer Solutions

At TRP Polymer Solutions, we are committed to providing custom rubber moulding solutions that meet the needs of both today and tomorrow. We pride ourselves on our ability to quickly adapt to regulatory changes, meaning that you can rely on our sealing solutions to not only offer dependability and resilience, but also full compliance with REACH.

If you’d like to find out more about our services and our fluorosurfactant-free custom rubber seals, custom rubber gaskets, and rubber diaphragms, contact us today, and we can discuss your most suitable choices in further depth.

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