For all two-phase technology, there is a regulatory question that engineering cannot solve. In December 2022, 3M announced the end of its manufacture of per- and polyfluoroalkyl substances (PFAS) by the end of 2025. At the same time, the company announced the removal of PFAS from its full product portfolio[27]. The company states that the exit was complete at the end of 2025. Stock from earlier production is still on the market[28].
Clarification on the press release. The press release does not name Novec or Fluorinert. It refers in general to fluoropolymers, fluorinated fluids and PFAS-based additives[27]. Thus the primary source does not support the frequent statement “3M stops Novec”. This statement comes from the communication of distributors.
In parallel, the European restriction procedure continues. 2 independent legal analyses give the same sequence[29], [30]:
- 2026-03-02: The Committee for Risk Assessment adopted its final opinion.
- 2026-03-26: Draft of the socio-economic opinion.
- Until 2026-05-25: Consultation.
- End of 2026: Final opinion expected.
- 2027: Adoption of an amendment to REACH Annex XVII expected, with a transition period of 18 months.
For heat transfer fluids, the procedure explicitly leaves the status open. The Committee for Socio-economic Analysis considers the data insufficient. The data does not permit a final assessment of the requested derogations for refrigerants, heat transfer fluids and electronic applications[29]. For high-technology sectors without available alternatives, time-limited derogations of up to 12 years are under discussion[30].
Consequences for the fluid selection
The obvious substitutes do not solve the problem. A development product that replaces perfluoropolyethers, hydrofluoroethers and fluoroketones boils at 49 °C. It has a global warming potential of 10 and no flash point. Chemically, it is a hydrofluoroolefin[31]. Thus the product itself is a fluorinated compound. Under the broad definition of the European proposal, it is in the scope of the proposal.
The same applies to R1233zd(E). The test set-up in section 05 uses this fluid[22].
This research did not find a PFAS-free two-phase fluid with comparable properties for electronics cooling.
The consequence for plant engineering: the fluid selection must stay reversible. In practice, this means:
- The saturation pressure range of the circuit permits more than one candidate.
- Materials and seals must have test results for all fluids on the list of candidates and not only for one fluid.
- The fill quantity is such that a fluid change stays a maintenance task and does not need a conversion.