Where PFAS Are Found in Your Electronics Assemblies

Throughout the history of the electronics industry, and in industrial history more generally, the use of certain chemicals is periodically limited in many products due to their health effects and persistence in the environment. Previously, it was fluorocarbons and hydrofluorocarbons, both of which are ozone-depleting compounds, then it was limitation of lead in components and assemblies. Now, a new class of compounds is being restricted: these are per- and polyfluoroalkyl substances (PFAS).

In the realm of electronics manufacturing, PFAS play a significant, yet often overlooked role in the production of electronic components and finished products. However, their useful properties also cause them to persist in the environment, earning them the nickname "forever chemicals". These chemicals are presenting serious challenges to manufacturers due to liabilities associated with these substances, and the difficulty in eliminating them from supply chains. There are also new regulations that limit the use of PFAS in electronics, which will add to the burden of all manufacturers in the industry.

PFAS in Your Electronic Devices

PFAS are a group of 4730 man-made chemicals that are very slow to degrade in the natural environment. Their chemical properties make them very useful in manufacturing highly reliable electronic assemblies, but the same properties make them very difficult to recycle and cause these chemicals to persist in the natural environment. PFAS are contained in many components and materials used in electronic devices, including:

• PCB laminate materials
• Wires and cables
• Passive components (specifically capacitors)
• Displays
• Batteries
• Packaging materials

PFAS are particularly ubiquitous in PCBs, which are the backbone on which nearly all electronics assemblies are built. Nearly every FR4-grade PCB includes PFAS as part of the laminate construction. According to a report by the United States Environmental Protection Agency, “Over 90 percent of FR-4 PCBs used epoxy resins containing the reactive flame retardant tetrabromobisphenol A (TBBPA) to meet flammability standards.” PFAS are also used in various processes in semiconductor manufacturing, such as in encapsulation and photolithography.

Can PCBA Manufacturers Spot PFAS Usage?

Because PCBA manufacturers are downstream in the supply chain, they will have some regulatory burden relating to limiting the content of PFAS in finished products. Currently, unless a company is reading every single label for parts coming into a factory and cataloging data in an internal system, it is difficult to spot exactly how much PFAS is going into an electronics assembly.

This means that more data will be required to be furnished to assemblies manufacturers and component buyers, or some marking is needed to demonstrate compliance with new regulations. This is already the approach with RoHS/REACH compliance, and depending on how the industry develops processes to grapple with this challenge, a similar approach may be taken regarding PFAS.

REACH and RoHS compliance labels.

Alternatives to PFAS

Because these types of substances are so important in electronics manufacturing and processing, limitation of PFAS will require re-engineering of processing steps and the use of alternative materials.

It Starts With Awareness

The industry is increasingly recognizing the importance of limiting PFAS from components and materials in supply chains, and companies are doing what they can to manage the problem. The regulatory landscape is also evolving, with EU and US regulatory agencies proposing and implementing new guidelines on usage of PFAS. The major governmental bodies limiting the use of PFAS include:

• U.S. EPA Toxics Release Inventory (TRI)
• U.S. EPA Toxic Substances Control Act (TSCA) Significant New Use Rule (SNUR)
• European Chemicals Agency
• State of California

The limitations are now passing down to broader intergovernmental agreements and procurement legislation. In the US, the National Defense Authorization Act, the nation’s largest annual spending bill, includes limitations on use of PFAS in procured equipment, including in electronic devices.

Given the changing regulatory environment, component and material manufacturers will need to provide data on their usage of PFAS and expected content in products they product. This will allow PCBA manufacturers to ensure their outputs are compliant with environmental regulations, similar to the approach taken with REACH/RoHS.

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