New Space Sector Task Force on large-scope REACH restriction initiatives on PFAS and bisphenols

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Eurospace announces the creation of a new Task Force to answer to large-scope REACH restriction initiatives on Per- and polyfluoroalkyl substances (PFAS) and a number of bisphenols. A Kick-Off Meeting was held on Friday, 10 February 2023, but remains open to new participants.

  • The first restriction proposal of interest concerns Bisphenol A and four bisphenols of similar concern (link to ECHA website) – hereafter “BPA+”. The 6-month European Chemicals Agency (ECHA) public consultation of stakeholders on this restriction proposals by Germany is already ongoing (final deadline on 22 June 2023). The restriction could be adopted by the end of 2024.
  • The second restriction proposal for a large group of over 10,000 PFAS substances was published on 7 February 2023 (link to ECHA website) – hereafter “universal PFAS”. The ECHA 6-month public consultation of stakeholders on this restriction proposals by five Member States is due to start on 22 March 2023. This restriction could be adopted as early as 2025.

For the Space Sector these group restrictions present significant risks of wide-spread obsolescence for materials and processes “M&P” (see Info box below) and unpredictable side effects within the space and other industrial supply chains. Suitable derogations from the restriction will be essential, but may not be sufficient given the complexity of supply chains and the limited visibility on substances present in very low concentrations (not mentioned in Safety Data Sheets).

PFAS and bisphenols in space production: Bisphenols as well as PFAS chemicals both have a wide variety of uses in many materials which multiple manufacturing processes with space verification status are relying on. Some of these materials were even initially developed for space use and cannot be easily replaced due to their high performance in harsh space environments. A very thorough crosscheck of relevant manufacturing processes with involvement of M&P experts is needed to identify “space-specific” uses of bisphenol-containing mixtures (pre- and post-processed CFRP materials, encapsulants, adhesives, primers, and many others) as well as the wide utilisation of PFAS substances in many key applications (such as lubricants, coatings, creep barriers, functionalised polymers’ surfaces, coolant fluids, fluoro-elastomeric sealants, cable insulation, shrink sleeves, labels and many others).

Against this backdrop, the Space Restrictions Task Force (RTF) has been created to prepare and inject contributions to ECHA, the European Commission and potentially Member States in support of European Space Sector interests, collaborate with ASD and other third parties as appropriate in relation to restriction proposals under the COM Restrictions Roadmap, with an initial focus on universal PFAS and BPA+. For BPA+, an information collection survey to RTF participants has already been launched for replies by the 31 March 2023.

The RTF is an initiative of the Materials and Processes Technology Board of the European Space Components Coordination (ESCC MPTB), a partnership between the European Space Agency (ESA), national space agencies, and space industry represented by ASD-Eurospace.

Industrial participants of the RTF are initially:

  • Airbus Defence & Space
  • ArianeGroup
  • Avio
  • Beyond Gravity
  • Leonardo Company
  • OHB
  • Thales Alenia Space

The Working Group is also attended by the European Space Agency (ESA) and the following national space agencies: Agenzia Spaziale Italiana (ASI), Centre National d’Etudes Spatiales (CNES) and Deutsches Zentrum für Luft- und Raumfahrt e.V. (DLR). The task force is also attended by the European Defence Agency (EDA) as an observer, as well as TNO, an independent research organisation.

The group is an open forum. New participants with a Space Sector interest may be admitted. You are invited to contact Eurospace.

ASD-Eurospace is acting as the Secretariat and REACHLaw Ltd. as consultant.

Contacts:

  • Secretariat: Pierre Lionnet, Research & Managing Director, ASD-EUROSPACE, pierre.lionnet@eurospace.org, +33-(0)1 44 42 00 70
  • Project Coordinator and Key REACH Expert: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143