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26 SMT007 MAGAZINE I MARCH 2026 The Advantages and Challenges of Durability and Persistence It is the precise properties of PFAS that make them desirable in high-performance applications, where use is highly contained, and less desirable in consumer applications, such as ski wax, dental floss, and waterproof clothing, as PFAS tends to persist in the environment. Likewise, trying to place all PFAS in one bucket is inappropriate (like saying "all metals"), as this class of substances is broad and diverse. Rather than a blanket ban, PFAS restric- tions should follow a differential approach. The Challenges of Tracking PFAS Across the Electronics Value Chain Moreover, there are many types of PFAS, with thou- sands of variants within a very broad group. For many of them, the right analytical detection tools are missing. If suppliers fail to identify PFAS in their value chain, then, in theory, there is no PFAS. While there are tools to detect some types of PFAS, such as the IPC-175x series for materials declaration, others, including AI tools, are just emerging. A global value chain means a company can have several thousand direct suppliers; therefore, it can take up to one year to trace a known substance across the entire value chain. With unknown substances, this can take even longer. Key Recommendations for Regulators: • Follow a risk-, science-based, rather than hazard-based approach, in restricting PFAS. • Consider whether technically comparable alternatives exist today. If not, a 12.5-year tran- sition period and even a longer time-limited use is not a proportionate approach. In such cases, time-unlimited derogations for critical uses of PFAS in electronics are needed. • Handle fluoropolymers differently, through exemptions, as long as no technically equivalent alternatives exist today; follow the Canada and New Mexico models, accounting for the unique profile of fluoropolymers, their contained use, and the realities of global value chains. • Other PFAS types with function-critical applications and no alternatives must also be considered. Key Recommendations for Electronics Companies Prepare for the upcoming ECHA SEAC consultation, expected at the end of March 2026, and open for two months. • A draft mapping by sector and several draft questions are already available here. • Plan for the consultation and potential phase- out, internally and with your suppliers. • Ensure timely, sufficient multi-stakeholder dialogue with a common vocabulary. • One major identified challenge is that elec- tronics are spread over multiple sectors, and are not only covered in the electronics and semiconductor sectors. Thus, it is crucial that you conduct a gap analysis and determine in time which sectors you will submit comments to. Let us know as well. • ECHA is seeking PFAS emission and socio- economic data for the EU/EEA specifically; data with global estimates will not be consid- ered and will only skew the final regulatory outcome. It's essential for your business that you collect and provide accurate data. • ECHA will not allow the inclusion of attach- ments and external links. For most survey answers, there will be a predefined limit of 5,000 characters. Thus, answers must be prepared in advance with a strategic, data- based content and mindset. • Collect data on PFAS alternatives research and be ready to provide it; exemptions or derogations won't be granted if such sub- stantial evidence can't be provided up front. " Rather than a blanket ban, PFAS restrictions should follow a differential approach."