Six Questions You Should Ask a Fluorosurfactant Supplier
Knowing where the chemical substances in a raw material are registered is critically important, but these approvals don’t always allow a down-stream customer to import formulations containing these substances. For example, if a supplier registers a chemical substance in China for up to 10 metric tons of manufacture or import, that registration may not extend to a manufacturer’s formulation containing this substance. Formulators using the substance may still be required to register the active substance with the Chinese regulatory ministry before they can export their formulation.
We recommend that you understand a potential supplier’s product and product stewardship status, and know what is important for your use before buying. Consider asking the following:
1. Does the supplier have toxicological data for the chemical substances in this surfactant?
You should ensure that there is information specific to the particular product you are considering, and not merely information from a product containing a similar substance manufactured by another company, for example.
2. Is the supplier part of the U.S. EPA 2010 /15 PFOA Stewardship Program?
This program assures that a supplier has committed to or met the emissions reduction objectives for both manufacture and product content.
3. Where is this product registered, and at what volume levels?
This could impact availability over time and potentially restrict production or import of your products into certain countries.
4. Are there any use restrictions on this material anywhere in the world?
5. Are there Consent Order obligations for this material that might impact its use?
Consent Order obligations could extend to limitations in markets, applications, use conditions or content, among other things.
6. Is this material the subject of a Significant New Use Rule (SNUR), Significant New Activity (SNAc), or other regulatory restriction that would result in limitations, as listed in Question 5?
Bottom line: Make sure you choose a raw material supplier who understands the global regulatory environment and can direct you to the appropriate resource to find the answers to these and other questions. Also, ensure you understand what toxicological tests and studies have been completed on each raw material. Products that rely on test data from similar substances may not accurately reflect the potential hazards.
For more information, contact your local DuPont sales professional.
This article is not meant to serve as Legal advice and customers should seek out appropriate guidance and legal counsel regarding their obligations under the pertinent laws and regulations related to the registration of raw materials or ingredients in a given country.