EU restrictions on PFAS, cyclic siloxanes and chromates present a major risk to the functioning of the European space sector, representatives from industry and the European Space Agency (ESA) have warned.
Speaking at the agency's sixth REACH workshop on 17 June, ESA REACH officer Premysl Janik said the growing number of regulatory actions on chemicals is increasingly rendering materials and processes obsolete.
This growing regulatory pressure is limiting the availability of components containing targeted substances, which in turn is affecting operations and supply chains, according to some in the aerospace and defence industry.
"Effective management of material and process obsolescence is a crucial element for business success, with regulatory monitoring being a vital component of this process," Janik said.
PFAS ‘unmanageable burden’
Without suitable and exhaustive derogations, the EU proposal to restrict PFAS would impose an "unmanageable burden" on the European space industry, Janik said.
PFAS are widely used in spacecraft and launchers – from lubricants and adhesives, to cables, PCBs and multi-layer insulation (MLI). In its current form, the proposed restriction could result in companies failing compliance or creating technological risk due to the reliance on untested and largely unavailable PFAS-free alternatives, Janik said.
Siloxanes challenges
EU regulatory measures targeting cyclic siloxanes – specifically D4, D5 and D6 – are creating similar challenges for the sector. These substances are widely found in lubricants, sealants, foams and rubbers used in the manufacturing of spacecraft and their components.
The ESA and industry players are particularly concerned about the EU’s proposal to list the substances under the Stockholm Convention on persistent organic pollutants (POPs), which could lead to a global ban on the production and use of the chemicals.
The EU has concluded that, because of siloxanes’ persistence, bioaccumulation and ability to travel long distances, national and regional action would not be effective – necessitating coordinated global action.
Chromium VI restrictions
ECHA has proposed measures on all 11 chromium trioxide substances on the REACH authorisation list, initiating a process towards a comprehensive restriction that will come into force in 2028. This measure would replace existing authorisation requirements for chromium VI uses.
The agency has opened a six-month public consultation on the proposal, marking the next step in the transition from authorisation to restriction for use of the carcinogens under REACH.
ESA workshop panellist Elisa Consoli, REACH manager at industry association Aerospace and Defence Europe (ASD), said the sector has invested heavily in research and development of alternatives and has made good progress in the transition, but it has not been completely replaced yet.
Ralf Bölter, head of technology engineering at German firm Tesat Spacecom, said qualified alternatives have been achieved for most uses, although they are not as effective as chromates.
He highlighted the difference in requirements between a space launcher and a military aircraft located at a base near the sea with an operational life of 40-50 years. "Chromates are perhaps a simpler challenge for the space sector than for some of the defence uses that require long-term corrosion protection," Dr Bölter said.
The workshop also noted that regulatory action on many other substances, including bisphenol A, lead, di-isocyanates and hydrazine, is important for the sector and its supply chain.
The ESA said it is working with industry to ensure close monitoring of regulatory developments and continuing to encourage companies to track targeted substances. In particular, the agency is conducting an update to its 2023 mapping exercise of where PFAS are contained and used along the supply chain.
Janik said it is essential for the sector to collaborate and communicate with related industries such as aerospace and defence, automotive and electronics.
The REACH revision is expected to be published by the end of this year under the Commission’s Chemicals Industry Package, which is expected to bring clarity on the executive’s plans for PFAS.