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China Releases Reference List of 363 PFOA-related Substances

This list serves as a reference for enterprises ensure compliance with the List of New Pollutants for Priority Management (2023) and the Inventory of Severely Restricted Toxic Chemicals (2023).

China’s Solid Waste and Chemicals Management Center (SCC) under the Ministry of Ecology and Environment (MEE) released on 2 November 2023 the Reference List of PFOA, Its Salts and PFOA-related Compounds. This list includes 363 substances with CAS numbers and HS codes. They are recognized as PFOA, its salts and PFOA-related compounds that are subject to certain control measures in China.

Background

PFOA, its salts and PFOA-related compounds are a group of chemicals within the well-known family of PFAS. If not properly managed, they are likely to cause serious or irreversible harm to the environment. As chemicals of high concern, they were added to Annex A of the Stockholm Convention on Persistent Organic Pollutants in 2019, and added to Annex III of the Rotterdam Convention in 2022. Being a party to these two international treaties, China has introduced legislation to phase out PFOA, its salts and PFOA-related compounds. On 31 December 2022, the MEE released the List of New Pollutants for Priority Management (2023) (hereinafter referred to as 2023 List), in which “PFOA, its salts and PFOA-related compounds” are listed with strict control measures. To cope with the implementation of the 2023 List, the MEE released on 18 October 2023 the Inventory of Severely Restricted Toxic Chemicals (2023) (hereinafter referred to as 2023 Inventory), adding “PFOA, its salts and PFOA-related compounds” with specific conditions for use. However, no CAS numbers or any identification numbers are provided for this group of chemicals. To help enterprise ensure the compliance work, the SCC-MEE recently issued the Reference List of PFOA, Its Salts and PFOA-related Compounds.

Control measures

According to the 2023 List and 2023 Inventory, major control measures for PFOA, its salts and PFOA-related compounds include:

  • Prohibition on the establishment of new installations for relevant production equipment;

  • Prohibition on the manufacture and processing of these chemicals;

  • Prohibition on the use of these chemicals (with specific exemptions*);

  • Import or export of these chemicals shall obtain the Clearance Notification for Environmental Management on Import/Export of Toxic Chemicals from the MEE (permitted only for specific usages**); etc.

For more detailed control measures, please refer to the 2023 List.

Specific exemptions* & Specific usages**

The “specific exemptions” (specified in the 2023 List) and the "specific usages" (specified in the 2023 Inventory) are the same, including:

  • Photolithography or etch processes in semiconductor manufacturing

  • Photographic coatings applied to films

  • Textiles for oil and water repellency for the protection of workers from dangerous liquids that comprise risks to their health and safety

  • Invasive and implantable medical devices

  • Use of perfluorooctyl iodide for the production of perfluorooctyl bromide for the purpose of producing pharmaceutical products

  • Manufacture of polytetrafluoroethylene (PTFE) and polyvinylidene fluoride (PVDF) for the production of:

    1. High-performance, corrosion-resistant gas filter membranes, water filter membranes and membranes for medical textiles

    2. Industrial waste heat exchanger equipment

    3. Industrial sealants capable of preventing leakage of volatile organic compounds and PM2.5 particulates

  • Manufacture of polyfluoroethylene propylene (FEP) for the production of high-voltage electrical wire and cables for power transmission

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