PFAS substitution is a research effort problem before it is a chemistry problem

Emil Damgaard-Møller of the Danish Technological Institute recently published a provocation called PFAS Substitution: The alternative you need was probably invented in 1961. His argument is that fluoropolymers froze the technology tree. When they arrived in the 1950s and 60s they solved five problems at once, and work on the competing approaches — ceramic surfaces, silicone hybrids, metal and graphite seals — mostly stopped within a decade. Those branches were rarely disproven. They were outcompeted on convenience and abandoned with the hard work largely done, often for reasons that have since expired: a patent that lapsed, a missing process that now exists, a cost that has inverted.

His closing point is the one that matters most. The bottleneck is not finding a candidate. It is knowing whether it will still be working in ten years. Most substitution decisions are made on supplier datasheets; most substitution failures happen for reasons that only show up in field service history and failure reports. So don’t search for what works — search for what broke, why, and what was still standing afterwards.

Doing that properly means reading across four languages, forty years and somebody else’s industry. No engineer has ever had the time.

Where the time actually goes

Ask a materials engineer what a PFAS substitution project costs them, and very little of the answer is lab work.

It is finding where the PFAS actually is — not the line items suppliers declared, but the O-ring inside a purchased assembly, the release coating referenced only in a 2011 drawing note, the process aid that never reaches a bill of materials.

It is reconstructing the requirement. PFAS is chosen for a bundle of properties, and a bundle rarely has a one-to-one material replacement. It very often has a system replacement: a cheaper bulk polymer plus a surface treatment, a different geometry, a changed maintenance concept. Search only for materials and you miss most of the real answers.

It is interrogating the spec. In most projects, at least one requirement that excludes every non-fluorinated option turns out to be inherited, unverifiable, or a safety factor stacked on another safety factor.

And it is the evidence — being able to show later what was considered, what was rejected, and why.

None of that is chemistry. All of it is document work, and there is far more of it than the people you have.

What a material intelligence layer changes

This is what Viridium AI was built for. Not to invent a new fluorine-free polymer — that is what the labs and research consortia are for — but to make the surrounding work tractable.

One principle we won’t bend on: plausible is not proven. A model suggesting a silicone hybrid might replace an FKM seal is worth little. A traceable path from your requirement, through the historical evidence and the failure record, to a candidate you can defend in a dossier is worth a great deal.

Europe: the restriction and the research base

The EU’s universal PFAS restriction is past the point where waiting is a strategy. ECHA’s Risk Assessment Committee finalised its opinion in March 2026 supporting a broad ban, the Socio-Economic Analysis Committee’s draft went out for consultation that closed in May, and the Commission drafts the restriction text once both are final. Every sector-level argument turns on the same question: are alternatives available? A derogation is something you argue for with evidence.

The alternatives are being developed in public. ZeroF demonstrated PFAS-free coating systems for packaging and textiles that approach PFAS-level performance. PFAROS, a five-year, €41m Innovative Health Initiative project coordinated by Ghent University with RISE leading materials benchmarking and SSbD implementation, is doing the same for pharmaceuticals and medical devices, with an AI-driven tool at its heart to map PFAS use and identify viable alternatives.

That is the right instinct, and there is a gap on the far side of it. A consortium can validate that an alternative works. It cannot tell a manufacturer which of their 16,000 parts the finding applies to, what else changes in the assembly, or whether their own 2009 qualification report already contains a reason it won’t work for them. Connecting published research to a real part list is the layer we provide — and if you are in a substitution consortium looking for the industrial-uptake path, that is a conversation we’d like to have.

The US: a faster clock and a harder burden of proof

European manufacturers often treat PFAS as a European problem with an American grace period. The opposite is closer to the truth. Maine’s first-phase sales prohibitions took effect on 1 January 2026, Washington’s notification requirements began the same day, and Minnesota’s Amara’s Law requires reporting of intentionally added PFAS in any product sold into the state ahead of a general ban in 2032.

The sharper point is the exemption route. In Maine, Minnesota, New Mexico and California, continuing to use PFAS past the deadline means petitioning for a currently unavoidable use determination — and the burden is on the manufacturer to show no safer alternative is reasonably available. Maine has run that process once: of eleven requests, two were approved. In the nine rejections the department found reasonably available alternatives existed, including where the petitioner argued they performed worse.

Read as an engineer rather than a lawyer, that says something specific. The regulator is now doing an alternatives assessment on your product, and if theirs is better than yours, you lose.

Bring us the one you think is impossible

Damgaard-Møller ends by asking which application you believe cannot be substituted — because that is the one he would most like to start with. We’ll take the same challenge. Bring us one hard material question: one PFAS-containing part, one inherited requirement nobody can source, one substitution that has already failed. We’ll show you what the evidence supports, where it came from, and what it would take to defend the decision.

The alternative you need may well have been invented in 1961, run for thirty years in another industry, and been documented in a language nobody on your team reads. That used to be an acceptable excuse.