As reported by the CO₂ refrigeration marketplace R744, the Volkswagen Group plans to convert all mobile air conditioning heat pumps in its battery electric vehicles (BEV) models to CO₂ (R744) by 2030. The Group made the statement in a public comment submitted regarding the European PFAS Restriction Proposal.

In 2023, the European Chemicals Agency (ECHA) published details of a proposed ban on the production, use, sale and import of some 10,000 per- and polyfluoroalkyl substances (PFAS).

The purpose of the ban is to keep PFAS out of the environment. The proposed ban, officially a restriction proposal, was drafted by the Netherlands, Germany, Denmark, Norway and Sweden. The European Commission is slated to present the proposal to Member States formally in 2025. If passed, it would constitute one of the largest chemical substances bans ever in Europe.

In its opening remarks, the Volkswagen Group said that:

The Volkswagen Group is focusing on development and investments in the direction of electrification of the entire fleet and model portfolio. This transformation to climate-neutral mobility by 2050 is irreversible for the Volkswagen Group. … Against this background, the comprehensive restriction proposal—especially in the central components of electric drives—is viewed with great concern.

… This restriction proposal, which is tantamount to a quasi-ban, would require a not feasible re-engineering of an extremely large number of components and assemblies of today’s vehicles and tie up far-reaching human and economic resources in an extremely limited timeframe. The necessary and desired transformation to electromobility would be at least drastically delayed and endangered.

For today’s vehicle concepts—especially with regard to electromobility—the use of PFAS is indispensable. However, emissions into the environment can be largely excluded through responsible use.

Specific to the mobile air conditioning issue, The Volkswgaen Group said that due to the relatively high amount of PFAS contained in the refrigerant of actual mobile air conditioning system and the fact that small amounts of refrigerant are released into the environment even during regular operation over lifetime, the refrigerant offers significant leverage for the effective reduction of PFAS..

VW Group is working to convert all BEV models to the refrigerant R744. The market introduction of first new BEV platforms using R744-only will start during the second half of this decade. The overall transformation towards R744 will then take several years until end of 2030 to change all major BEV-platforms.

For ICE cars, including hybrids, the VW Group suggests an exemption of the PFAS restrictions.

The new development of the refrigeration circuit would be much more complex for vehicles with ICE than for BEVs, since the boundary conditions (including temperature and vibrations) in the front end are much more challenging than with BEVs, the Group said. In addition the portfolio of ICE cars is broad, covering different platforms and engine designs and requiring individual developments, applications and homologations.

Focusing the limited development capacities on BEV-only secures a fast transition in these future related purely EV-models. Applying PFAS restrictions in addition to the diminishing volume of ICE would endanger improving the BEV-platforms, add huge complexity into development processes and overburden limited development capacities in industry,the Group argues.

Other areas of concern for the Group regarding a possible PFAS ban include:

• Fluoropolymers. The scope of the restriction should be limited to PFAS posing a risk to health or the environment. Fluoropolymers which are to be considered as polymers of low concern should be excluded from the restriction, the Group said.

• Batteries. Exemptions are required for applications for the production of lithium-ion batteries for transport vehicles e.g., binder for the coatings of the electrodes or additives for electrolytes. Currently no substitute is available— neither in pre-development nor any level of industrial scale—to replace the commonly used PFAS-substances in batteries, the Group said. Additional exemptions should be given for batteries for energy storage systems or transport vehicles for repurpose use e.g., as energy storage devices.

• Electronics. Within the restriction proposal some exemptions are proposed but based on Volkswagen’s assessment, these exemptions are inadequate and do not consider the significance of PFAS related to functional requirements in multiple applications and potential innovations in the electronics and digital industry.

• Seals and hoses. Seals and hoses containing PFAS polymers of low concern should be exempted from the restriction proposal.

• Lubricants. PFAS-containing lubricants should not be prohibited for use cases under harsh conditions or where the implementation of safety-related functions is required.

• Metal Plating. The use of PFAS plays an important role within hard chrome plating processes as mist suppressant to secure and increase workers safety. No PFAS-free technically suitable substitutes are currently available to ensure a safe hard chrome plating process. To ensure an implementation of suitable, PFAS-free alternatives, Volkswagen Group proposes a derogation period of 13.5 years.