Circularity for A Resilient Supply Chain, PFAS, and More

Estimated reading time: 6 minutes

Editor’s Note: This important circularity and policy conversation continues a conversation with Dr. Diana Radovan of the Global Electronics Association. See Part 1 here.

Marcy LaRont: Let’s discuss PFAS chemicals, an issue that has largely been oversimplified by policymakers and the press. Where are we in that discourse?

Diana Radovan: PFAS refers to a very broad group of over 10,000 substances that vary in bioaccumulation, toxicity, and persistence in the environment. Critical to electronics and their function across the value chain are fluoropolymers. We know we can substitute fluoropolymers in specific use cases, but we cannot do that at scale because we would lose their critical functionality. Currently, no alternatives can fully replace the stringent performance and safety requirements of fluoropolymers in high-reliability electronics.

LaRont: That is the great concern. Functionality is always first, and if it cannot be attained and maintained any other way, then product replacement is not a viable solution. 

Radovan: There's a growing body of evidence that actually demonstrates scientifically that fluoropolymers should, in fact, be handled differently and not be in the scope of a blanket PFAS ban. That aligns with our recent position and reactions to the European Chemicals Agency’s (ECHA’s) Risk Analysis Committee (RAC) final opinion and Socio-Economic Analysis Committee (SEAC) draft opinion.

In June, the Bavarian branch of the German Chemical Industry Association (VCI) prepared and published a comprehensive overview of the available scientific evidence related to fluoropolymers.

The webpage highlights the challenges of finding viable alternatives to fluoropolymers in a range of strategically important industries. It also summarizes the available scientific evidence showing that incineration is an effective end-of-life option and reviews recent studies indicating that fluoropolymer waste is already being managed safely and responsibly.

In addition, it outlines European fluoropolymer manufacturers' voluntary commitment to further reduce manufacturing emissions and references a legal opinion arguing that the current PFAS restriction proposal does not meet the legal requirements under REACH and would require significant revisions before it could be adopted as a legally robust restriction.

Overall, the evidence referenced on this webpage reinforces that fluoropolymers do not pose an "unacceptable risk" under REACH and should therefore be exempted from the scope of the proposed EU restriction.

Now, the SEAC will further evaluate the thousands of submissions it has received, including those from the Global Electronics Association, for PFAS alternatives and the lack of alternatives in electronics. They will release their final opinion in the coming months.

This recommendation will be shared with the European Commission, which will ultimately propose how the PFAS restriction, for electronics and other sectors, will look in practice. Our advocacy work does not end here. We continue to advocate for allowing the use of fluoropolymers in function-critical applications that support our daily life and infrastructure, and plan different outreach activities to policymakers.

We are also working jointly with other associations that cover modern life-enabling technologies on a joint position to put forward to the European Commission as part of a broader coalition that includes semiconductors, medical technology, automotive, aerospace and defense, and other key sectors that rely on electronics.

LaRont: This is an important topic in the U.S. as well. How are you addressing it there?

Radovan: Yes, this is equally important in the U.S., and we are looking at ways to amplify our advocacy messages at both the federal and state levels. States like Minnesota and New Mexico are taking different approaches to fluoropolymers, and we cross-reference to their approach in our submission to ECHA. More broadly, we are advocating for regulatory coherence in how PFAS and fluoropolymers in electronics are regulated across regions. Incoherence across regions on how specific chemicals are regulated in industrial electronics can lead to major supply chain disruptions, with implications for multiple critical digital sectors relying on such electronics, and can become an obstacle towards circularity.

It is possible to apply for exemptions for currently unavoidable use (CUU) for PFAS in products in Minnesota, but the mechanism for doing that is still not entirely clear. We are working with our members and other associations to find a more general approach to applying for such exemptions for product groups as a coalition, rather than having every single company apply for their very specific individual products to receive exemptions.

LaRont: Tell me about some of your recent travels for the Association. What were the objectives of those events, and what did you come away with?

Radovan: In May, I participated in a panel on traceability at the International Tin Association Conference in Seville, Spain. Tin is very important for electronics because it’s used in solder. It’s only small amounts, 2–3%, so we don't always think about tin as being there, but without it, PCBs would not work.

I also visited Atlantic Copper to see how copper is manufactured and learned about a new circularity project in which they are recovering copper from electronic waste pre-approved by other agents, as well as other metals that may have been discarded in the past, like tin. It was very interesting and important to experience the process first-hand.

LaRont: Where did you go next?

Radovan: In early June, I headed to Mannheim, Germany, for the Sustainability osapiens Summit (SoS.26). Even though the event was not specific to electronics, it brought many electronics companies together with other sectors. It’s valuable to learn how companies in other sectors are implementing policies and how the automotive industry is adopting digital product passports for batteries. The Digital Product Passport, a requirement under the Ecodesign for Sustainable Products Regulation (ESPR) with future “license-to-operate” in Europe implications, with a number of still-to-be-solved implementation challenges, is a major topic for electronics too, and something we are actively working on. There were also many policymakers present, which helped get a sense of the general direction that sustainability policy is heading towards in Europe, with global value chain implications.

The following week, I was in Frankfurt for the E-Waste World Expo 2026, which contained parallel conferences on waste, batteries, metals, IT asset recovery (ITAD), and circular electronics. It was very focused on the recovery of critical raw materials. It was a pleasure to connect with SERI and some of our members, such as AT&S, as well as to forge new connections, e.g. with the WEEE Forum (WEEE = Waste from Electrical and Electronic Equipment).

As a result, we have recently joined the WEEE Joint Association Roundtable. Frankfurt was intense, featuring many interesting panels, including several on the upcoming Circular Economy Act. The general feeling was as already expressed above, that discussions are perhaps too focused on materials recovery from batteries and recycling of consumer electronics and fail to ignore a more holistic approach to the value chain, including design and other R-strategies.

LaRont: I guess it stands to reason that the focus would be on e-waste recycling and batteries specifically. Most of the e-waste happening most quickly is from consumer electronics disposal; the sheer volume of mobile phones and laptop computers that are discarded every day is staggering.

Radovan: Yes, but the promise of urban mining is a bit deceiving. Some presenters stated that one would need thousands of phones to recover metals in a meaningful and economically sensible way, that it must be done within a certain timeframe, and that there must be a market demand.

Some industrial electronics will never be part of a circular economy for solid reasons. Design for durability (rather than for recycling) is critical in the durable goods sectors, i.e., aerospace and defense, implantable medical devices, and the automotive sector. Certain medical devices will be deemed contaminated if they have been in contact with human or animal tissue and thus cannot be recycled. A spaceship meant to orbit in space for decades will never return to Earth.

Moreover,15–20 years from now, certain devices will not be eligible for recycling due to materials that will no longer be acceptable from a planetary health risk perspective. Circularity should be regulated where it makes sense. Circularity objectives must be balanced against safety, reliability, cybersecurity, certification, and performance requirements.

LaRont: You mentioned that a better business case needs to be created for product circularity in electronics. What does that look like, or what do you hope it will look like?

Radovan: That’s the million-dollar question. We have to address access to funding. There are several funding sources in Europe, but they are very fragmented. To apply for it, you need a consortium of organizations across different countries. Then there's no guarantee you'll get the funding. Private-public partnerships make sense.

The Circular Economy Act should address the lack of harmonization in Extended Producer Responsibility schemes between different EU Member States. Even the way you carry waste from one country to another across a border is problematic. So, there has to be a clearer funding mechanism and clearer business incentives in place.

LaRont: You also had a big event in Brussels, correct?

Radovan: Yes, we had our annual Advocacy Day in Brussels on June 23. In parallel, I went to the European Parliament for a hearing on the upcoming Circular Economy Act: Less Waste, More Value, which included concluding statements from the European Commission. It was very good to hear first-hand how the Dutch Investment Bank and specific political parties are seeing the development of the Act and their recommendations. In many instances, I saw alignment regarding identified gaps that still need to be filled to make the CEA a reality. The following day, I went to the annual European Metals conference in Brussels where, again, circularity was a big topic, and policy makers were present and shared their view on the CEA.

So, it was a busy few weeks, but overall we heard positive messaging and have been considering various ways to ensure that Europe’s major sustainability policy ambitions support supply chain resilience rather than hinder it. And now we continue to work, over the summer period, to ensure that the missing puzzle pieces in achieving those big ambitions are clearly pinned down in conversations with policymakers and that they involve all value chain actors.

We have a very clear idea of what electronic manufacturing companies want to see in the act, but we continue to welcome more engagement. If any of our industry companies have questions or wish to be directly involved in our sustainability advocacy work, I welcome their email at dianaradovan@electronics.org.

LaRont: Thank you, Diana. It’s always nice talking with you.

Radovan: Likewise, Marcy. Until next time.