PFAS in automotive supply chain

Introduction

Per- and polyfluoroalkyl substances (PFAS), dubbed „forever chemicals,” are critical in the automotive industry for their resistance to heat, water, and chemicals. They’re used in upholstery, coatings, seals, and electric vehicle (EV) batteries. However, their environmental persistence and health risks, like cancer and thyroid issues, have led to tighter regulations in the EU and US. The industry faces the challenge of managing PFAS, with the International Material Data System (IMDS) and OEM supplier inquiries playing key roles. This article covers PFAS applications, IMDS’s role, OEM actions, challenges in finding alternatives, and why the supply chain uses emails and surveys despite IMDS.

PFAS Applications in Automotive

PFAS enhance vehicle durability and safety due to their unique properties:

Interior Components: PFAS create stain-resistant upholstery coatings, simplifying cleaning, especially in commercial and luxury vehicles. They also provide heat-resistant, non-stick properties for dashboards, preventing heat-induced warping.
Engine and Mechanical Parts: Fluoropolymer PFAS coatings on engine wires prevent shorts and fires. Fluoropolymers, including fluoroelastomers, are used in chemical- and heat-resistant gaskets, O-rings, and seals, boosting reliability and extending maintenance intervals. PFAS are also in brake linings, hydraulic fluids, and lubricants, enhancing performance.
EV Batteries: The EV boom has increased PFAS use, particularly polyvinylidene fluoride (PVDF), a binder in battery electrodes and separator coatings, ensuring electrochemical stability. PVDF demand is expected to double by 2028.
Other Uses: PFAS are in car waxes, polishes, and air conditioning refrigerants, leveraging their non-stick and thermal stability.

PFAS’s widespread use highlights their value but also the challenge of phasing them out without compromising performance.

PFAS Regulations

Regulations are evolving rapidly, impacting automotive:

European Union

PFOS (REACH) – banned since 2009
PFOA (REACH) – banned since 2020
PFHxS (REACH) – banned since 2023 (trace contamination limits)
PFHxA (REACH Annex XVII) – added in October 2024
>10,000 PFAS (REACH proposal by DE, DK, NL, NO, SE) – submitted January 2023, decision expected 2025
PFAS in packaging (Packaging and Packaging Waste Regulation) – restriction planned for 2026

United States

PFOS & PFOA (CERCLA) – classified as hazardous substances
All PFAS (TSCA) – reporting of use/import from 2011–2022 – Deadline: July 11, 2025 (general), July 11, 2026 (small importers)
Inactive PFAS (SNUR – TSCA) – restart requires EPA review
Various PFAS (State laws: CA, ME, MN) – additional bans and reporting from 2025–2026

Global

PFOS & PFOA (Stockholm Convention) – globally restricted
Various PFAS (Canada – draft national regulation) – under consultation

These regulations push the industry to track PFAS and seek alternatives.

Role of IMDS

The International Material Data System (IMDS) is a vital automotive tool, allowing suppliers to report component compositions, including PFAS, per the Global Automotive Declarable Substance List (GADSL). In August 2022, GADSL added thousands of PFAS with low reporting thresholds.

Key IMDS Functions

Substance Declaration: Suppliers report PFAS exceeding GADSL thresholds, enabling OEMs to monitor compliance.
Regulatory Tracking: IMDS integrates GADSL and REACH updates, ensuring global compliance.
Analysis Support: IMDS data aids risk audits, identifying components for replacement.

In April 2023, the IMDS Steering Committee issued a bulletin, Global PFAS Chemical Regulations and Required IMDS Actions, raising awareness about PFAS applications and legislation.

OEM Actions and Supplier Inquiries

OEMs, actively engage suppliers to manage PFAS, driven by regulatory and sustainability pressures. Many send emails and surveys asking about PFAS in components.

Objectives of OEM Inquiries

Compliance: Ensuring adherence to REACH, TSCA, and state regulations.
Risk Mitigation: Avoiding penalties and liability through risk audits.
Sustainability Goals: Meeting consumer and investor demands for PFAS-free products, with investors managing over $8 trillion advocating phase-outs.
Strategic Planning: Identifying PFAS-containing components for replacement prioritization.

Supplier Responses

Suppliers face significant challenges due to the massive volume of data in IMDS, which can include thousands of material data sheets (MDS) for complex automotive components. Managing this data requires substantial resources, including qualified employees with expertise in IMDS navigation and regulatory knowledge, which many suppliers lack. The analysis process in the IMDS online system is often time-consuming, involving detailed reviews of material compositions to identify PFAS, especially for multi-tiered supply chains.

Challenges in Replacing PFAS

Replacing PFAS is a major challenge due to their unmatched performance:

Technical Barriers: PFAS offer exceptional heat and chemical resistance, critical for seals, coatings, and battery materials. Alternatives often fail to meet these standards, risking safety and performance.
Cost and Supply Chain Complexity: Developing and scaling PFAS-free materials requires significant investment and process redesign. Sourcing reliable suppliers is time-consuming given the multi-tiered automotive supply chain.
Performance Trade-offs: In critical applications like EV batteries, finding PVDF substitutes that maintain electrochemical stability is particularly difficult.

Despite these challenges, regulatory and consumer pressures are accelerating innovation, with industry groups such as ACEA and the Alliance for Automotive Innovation actively supporting the development of safer alternatives.

PFAS-Free Alternatives

Several companies from Europe and the US are developing PFAS-free alternatives for automotive use, offering viable options for specific applications:

Renegade Plastics (USA): Provides 100% PFAS-free coated fabrics for upholstery, trunk liners, and anti-slip truck bed liners, balancing performance and environmental safety .
Omniseal Solutions (USA): Develops PFAS-free advanced materials for critical applications like seals, noting trace PFAS may persist due to environmental prevalence.
Ensinger GmbH (Germany, Europe): Offers engineering plastics like POM, PA, and PET as PFAS-free alternatives for components traditionally using fluoropolymers.
Mitsubishi Chemical Group (Global, with key operations in Europe and USA): Supplies PFAS-free engineering plastics with technical support for material selection during transitions.

These alternatives demonstrate progress, but broad adoption, especially in high-performance applications such as EV batteries it remains a work in progress.

Why Emails and Surveys Are Still Used Alongside IMDS

Despite IMDS being central to automotive material compliance, OEMs continue using emails and surveys to address gaps:

Beyond IMDS Scope: Regulations like TSCA require PFAS data (e.g., volumes, disposal methods, health risks) not covered by IMDS.
Data Gaps: IMDS entries often use wildcards (e.g., “unspecified polymer”), making it hard to detect PFAS accurately.
Regulatory Readiness: OEMs collect data proactively to prepare for future PFAS bans and substitution strategies.
Risk Management: Direct inquiries help identify and mitigate PFAS-related risks across supply chains.
Sustainability Tracking: Surveys support progress monitoring toward PFAS-free goals aligned with investor and consumer expectations.

Conclusion

PFAS play a key role in automotive performance, from conventional parts to EV systems. Yet, evolving regulations like REACH and TSCA, combined with rising public concern, are pushing the industry toward safer alternatives. IMDS helps ensure GADSL compliance, while OEM surveys and direct inquiries increase transparency. Despite technical and economic barriers, innovation and supply chain collaboration are driving the transition to PFAS-free solutions.