Reply to ECHA consultation on PFAS – impact of a potential PFAS restriction

02 October 2023

The Gas and Steam Turbine Industry is essential for Europe’s electricity system, providing reliable power generation and heating, notably in cogeneration plants. This paper, created alongside EUTurbines’ response to the European Chemical Agency (ECHA) consultation, outlines the industry’s reasons for seeking a derogation from per- and polyfluoroalkyl substances (PFAS) restrictions.

Considering gas and Steam Turbines as vital components in electricity and gas transportation systems, we request their inclusion in the Annex XV Restriction Report as a sub-sector within the Energy Sector.

As downstream users of PFAS-containing parts, as identified by suppliers and manufacturers in the Mining & Petroleum sector, which has been granted a 13.5-year derogation on fluoropolymers, we strongly urge the Dossier Submitters to extend this derogation to encompass our gas and steam turbine power plants, including their compressors, auxiliary equipment, spare parts, and their utilisation in non-power plant applications (e.g., industrial and gas transportation).

Failure to provide appropriate derogations poses a significant risk to the security of the present and future electricity supply in the European Union. It would also result in economic losses not only for stakeholders in the gas and steam turbine sector but also for industries and consumers throughout Europe.

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