Upstream Oil & Gas and CCS operations in Europe: Perspective on a proposed EU Universal-PFAS Restriction

Proposed EU Universal-PFAS Restriction in a nutshell

• The European Chemicals Agency (ECHA) is consulting on a proposed REACH Restriction for all PFAS compounds, as proposed by the governments of Germany, the Netherlands, Sweden, Denmark and Norway.
• The proposed restriction covers nearly all compounds with a -CF2- or -CF3 group. The scope of the proposed Restriction covers liquids (e.g., fluorosurfactants), solids (e.g., fluoropolymers) and gases (e.g., F-gases).
• For the European Oil & Gas and CCS industries, common uses of PFAS include fluoropolymers in umbilicals and flexible pipes, sealing devices, O-rings and gaskets, electrical cables and equipment. Fluorinated siloxanes are used in upstream production anti-foam products, and fluoroalkanes are used as tracers to characterise some hydrocarbon reservoirs / CO2 storage complexes.
• ECHA’s Risk Assessment Committee (RAC) and Social and Economic Assessment Committee (SEAC) are currently reviewing the likely impacts of the proposed Restriction on a number of industrial, commercial, healthcare and other sectors. ECHA’s committees are due to report their Opinions in March 2026, ahead of a 60-day public consultation on the draft SEAC Opinion, anticipated to start mid-March 2026.
• IOGP is collaborating with other associations to jointly prepare evidence to inform the public consultation on the likely impacts of a restriction on the Oil & Gas / CCS sector. A restriction on the use of fluoropolymers is a particular concern to many industrial sectors, including Oil & Gas / CCS, due to the widespread application of fluoropolymers in situations where resistance to high temperatures and chemically aggressive conditions, often combined with a requirement for material flexibility and low friction, is required.

IOGP Europe acknowledges that certain PFAS need to be controlled to protect human health and the environment. PFAS that are persistent, bioaccumulative and toxic (PBT) or persistent, mobile and toxic (PMT), and where their use deliberately or inevitably results in significant environmental releases are considered the highest priority for control.

The EU has recently restricted the use of PFAS-containing fire-fighting foam (EU Regulation 2025/1998), which may contain a number of confirmed PBT/PMT PFAS. However, the current evidence suggests that many other PFAS - particularly the fluoropolymers - do not meet the criteria for PBT or PMT, and do not result in significant environmental emissions during normal use.

Fluoropolymers are widely recognized as playing an important role in the oil and gas industry to ensure the integrity of hydrocarbon containing equipment. This is due to their environmental stability, resistance to high temperatures and chemically aggressive conditions, flexibility and robustness. Fluoropolymers are widely used in flexible subsea pipes and risers, umbilicals, O-rings and gaskets, electrical wire insulation, capacitors and various sealant applications. They are used to achieve the safest operations in often challenging environments.

Fluoropolymers are also widely used in medical and healthcare applications, water treatment, wind turbine blades, hydrogen electrolysers, photovoltaic panels, carbon capture and storage installations, and other sectors critical to the safe and efficient delivery of the European Green Deal and an effective energy transition.

Flexible pipes are made of an assembly of polymeric barriers with corrosion-resistant steel wires. In many applications, they are the only viable solution for Oil & Gas / CCS developments. Fluoropolymers, such as polyvinylidene fluoride (PVDF) and polytetrafluoroethylene (PTFE) are used in the construction of flexible pipes to deliver the desired safe and reliable operational performance, and to ensure safety and environmental protection. Despite significant research, currently, there is no known substitute for extruded PVDF or current uses of PVDF and PTFE in flexible pipe design and manufacturing.

Any restriction or ban could have a devastating effect on energy affordability and security. PVDFs are currently the only solution for High Pressure High Temperature (HPHT) applications; there are no known alternatives. Barriers in flexible pipes comprised of PVDF are used between 90-130°C, while PFAS-free alternatives, such as polyethylene and polyamide materials, are limited to lower temperature environments (between 60-90°C). In addition, various PTFE-based sealing elements are typically used on the interfaces between metallic components to establish the integrity of the system and prevent hydrocarbon releases.

Any restriction of PVDF and PTFE could affect the manufacturing and use of flexible pipes in Europe, severely disrupting the supply chain and resulting in economic impact of billions of Euros per year, and potential for increased health or environmental risks if alternatives without equivalent performance characteristics are not available.

Despite the proposed derogation for some fluoropolymers and fluoroelastomers (listed under the Sealing Applications sector) for Restriction Option 2 (RO2), 13.5 years after entry into legislation), the oil and gas exploration and production / CCS sector could still be impacted due to disruption in the supply chain, shortages in raw materials caused in the production of flexible pipes and supply of spare parts. Research developments in the search for PFAS-free alternatives to fluoropolymer products have not been successful, and we are concerned that suitable alternatives and their certification, the revision or development of new International Standards, and appropriate Management of Change cannot be completed within 13.5 years.

The Restriction Background Document recognises this possibility. Oil & Gas / CCS projects rely on these products as enabling technology. During the lifetime of a project some replacement products and maintenance parts are required. If the industry is unable to secure necessary spares, this may lead to premature field closure which could affect energy security and energy affordability for decades to come.

In most cases, whenever alternative materials are technically feasible they are already being used. Furthermore, it should be highlighted that materials considered as alternatives in the Restriction Proposal documentation [section E.2.15 of Annex E of the restriction report] are not technically feasible replacements for the abovementioned application. The development of alternative products could take several decades, if even possible. IOGP Europe considers that a restriction on the use of fluoropolymers in the O&G / CCS industry is neither necessary nor appropriate.

Emissions during fluoropolymer production are best controlled through effective regulatory permitting under the EU Industrial Emissions Directive. Furthermore, current evidence suggests that the majority of PFAS-containing waste in the EU are already subject to incineration. IOGP and other industry associations (including Concawe, CEFIC) are working to provide best practice guidance on PFAS remediation (in soil and water) and equipment end-of-life management for their members.

As an Oil & Gas / CCS industry, we strongly encourage a full and detailed assessment of the effects of a full ban of fluoropolymers for the reasons stated above. We are concerned that SEAC has not addressed these ‘enabling’ applications and sectors in its work to date (see PFAS use mapping, below), and that a restriction could be introduced without due consideration of the effects on business of losing access to these materials.

IOGP Europe remains open to constructive discussion and dialogue in the hope that a workable PFAS Restriction is put in place that does not undermine safe operations in the oil and gas sector, and which contributes to effective implementation of a circular economy model.

Background information:

• ECHA Restriction Background Document: Registry of restriction intentions until outcome - ECHA
• ECHA mapping of PFAS use by sector: PFAS use mapping