Global Regulatory Dynamics of PFHxS
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About PFHxS

Perfluorohexane sulfonic acid (PFHxS) is a highly surface-active perfluorinated compound with chemical properties similar to perfluorooctane sulfonic acid (PFOS). Following the ban on PFOS by the Stockholm Convention in 2009, PFHxS has been widely used as a substitute in various products.

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However, PFHxS is persistent in the environment, capable of long-range transport, and may cause developmental toxicity, neurotoxicity, hepatotoxicity, and reproductive toxicity. At the 10th Conference of the Parties to the Stockholm Convention (SC COP-10), PFHxS, its salts, and related compounds were listed in Annex A of the Convention for elimination, with no exemptions allowed.

In light of the Convention's updates, several countries around the world have introduced corresponding control requirements. This article lists the control status of PFHxS and its salts, as well as PFHxS-related substances, in some countries and regions.

Enforcement Begun

China

On December 29, 2022, the Ministry of Ecology and Environment, Ministry of Industry and Information Technology, Ministry of Agriculture and Rural Affairs, Ministry of Commerce, General Administration of Customs, and State Administration for Market Regulation issued Order No. 28, which came into effect on March 1, 2023. It includes a list of new pollutants under priority control (2023 version), with control requirements for PFHxS, its salts, and related compounds as a ban on production, processing, use, import, and export.

Japan

On September 15, 2023, Japan revised the Chemical Substances Control Law Enforcement Ordinance (CSCL), designating PFHxS and its salts as Class I Specified Chemical Substances, and prohibited the import of 10 categories of products containing "PFHxS or its isomers or their salts." The regulation took effect in November 2023, with a ban on importing related products starting from May 2024. On February 10, 2024, Japan initiated a consultation to update the labeling and technical standards for firefighting products containing PFHxS, its isomers, or their salts, with the consultation on these two proposals ending on March 11, 2024.

European Union

On August 8, 2023, the European Commission published Regulation (EU) 2023/1608 amending the Persistent Organic Pollutants Regulation (EU) 2019/1021 (POPs Regulation), listing PFHxS, its salts, and related substances in the EU POPs Regulation's list of banned substances. The regulation requires that the content of PFHxS or any of its salts in substances, mixtures, or articles must be 0.025 mg/kg, and the sum of PFHxS-related substances must be 1 mg/kg. These requirements came into effect on August 28, 2023.

United Kingdom

On November 15, 2023, the UK issued Regulation UK S.I. 2023 No. 1217, which prohibits the use of PFHxS in accordance with the Stockholm Convention under its Persistent Organic Pollutants (POPs) Regulation. The ban applies to the use, manufacture, and placing on the market of the substance in the UK (excluding Northern Ireland).

Proposals Under Evaluation

Thailand

The Department of Industrial Works (DIW) of Thailand released a draft notification on November 1, 2023, proposing to add PFHxS, its salts, and related compounds as Class 3 hazardous substances to Annex 5.1 of the list, with the following control measures for their production, import, export, and possession:

Registration of the target substance is required before production or import;

A corresponding license must be obtained before engaging in related activities such as the production, import, export, or possession of the target substance.

New Zealand

The New Zealand Environmental Protection Authority is consulting on a plan to eliminate PFHxS under the country's Hazardous Substances and New Organisms Act of 1996 (HSNO Act), adding the substance to its schedule to ensure compliance with global agreement obligations.

PFAS Testing and consulting service

CIRS C&K Testing offers a comprehensive range of PFAS testing services to help brands and retailers meet regulatory requirements and mitigate risks associated with PFAS. Our services include testing for certain PFAS restricted by EU regulations according to standards such as REACH SVHCs, REACH Annex XVII & POPs. We also offer determination of total organic fluorine (TOF) content to meet US state regulations in anticipation of passing the proposed state law into action.

At CIRS C&K Testing, we are committed to helping brands and retailers mitigate the risks associated with PFAS. Our global network of accredited laboratories can assess products to ensure compliance with national and international regulations and standards. Contact us today to learn more about our PFAS testing and consulting services.

If you have any needs or questions, please contact us at test@cirs-group.com.