Switchgear using PFAS-free insulating gas can strengthen Europe’s grid transition

The Alliance supports the objective of the EU PFAS restriction proposal as the EU should prevent avoidable uses of persistent chemicals where safer, technically feasible and economically viable alternatives exist. For medium and high voltage switchgear, this condition is already met in some sector sub-use categories for insulation gases for switchgears, and in line with the F-gas Regulation. The F-gas Regulation, revised in 2024, already gives grid operators and manufacturers a targeted framework for phasing down high GWP insulating gases. The EU PFAS restriction should complement that framework by preventing a shift from SF6 to another generation of persistent PFAS insulating gases. It should not create broad derogations that keep PFAS-based alternatives on the market as NOG solutions are available or close to deployment. NOG technology is a European success story. It is based on nitrogen, oxygen and carbon dioxide. It is being developed, produced and deployed by multiple European manufacturers and suppliers. It does not rely on restricted patents, specialised PFAS feedstock or vulnerable third-country chemical supply chains. It also supports circularity, because it avoids complex PFAS gas handling, recycling and end-of-life risks.

Availability and regulatory certainty

For electrical switchgear up to and including 145 kV, PFAS F-gas-free alternatives based on natural origin gases are commercially available and already deployed. There is sufficient supply across portfolios from major original equipment manufacturers (OEMs) and no structural supply concerns. For switchgears above 145 kV, remaining portfolio gaps are closing within the F-gas timetable. AIS applications are progressing strongly, and manufacturers are expanding PFAS F-gas free offerings towards higher voltage classes. GIS applications above 145 kV should be assessed against the existing F-gas transition pathway, not through a separate open-ended PFAS derogation for PFAS F-gas (insulation gas). C5-FK and HFO-1234yf are not currently used commercially in EU switchgear above 145 kV for new installations. No derogation should preserve optional future use of substances that are not needed today. For C4-FN and other PFAS insulating gases above 145 kV, any transition should stay narrow, time-limited, and aligned with Regulation (EU) 2024/573.

Supply security and strategic autonomy

PFAS insulating gases, including fluoronitrile C4-FN, depend on specialised chemical production and limited global supply chains. Keeping them available risks locking critical European grid infrastructure into third-country inputs that Europe does not control. NOG solutions are available in Europe from multiple suppliers. There are no associated patents and they reduce exposure to feedstock constraints and third-country production decisions. They also support the EU's wider resilience agenda by giving grid equipment manufacturers a secure, scalable and PFAS-free pathway.

Industrial competitiveness and grid expansion

Restricting PFAS F-gases where alternatives exist would strengthen European competitiveness. Alliance members have already been transitioning away from PFAS insulating gases towards NOG technologies. NOG solutions can lower lifetime costs because they avoid special gas handling tools, dedicated personnel training, extra reporting, and complex decommissioning requirements. They can be supplied by multiple producers, which helps keep prices competitive and reduces dependency risks. Grid deployment needs regulatory clarity. Broad PFAS derogations would reward delayed transition strategies, strand clean technology investment and weaken the business case for scaling European PFAS-free switchgear. The EU should instead send a clear signal that the future market is F-gas/PFAS F-gas free.

Safety, environment and circularity

PFAS insulating gases require special precautions, handling procedures, and trained personnel. PFAS gas mixtures are difficult to recycle and can create emissions risks during maintenance and decommissioning. There is evidence of acute and chronic toxicity for PFAS insulating gases used in switchgear. C4-FN and C5-FK can degrade into trifluoroacetic acid (TFA) and hydrogen fluoride (HF), creating long-term environmental concerns that should not be ignored in equipment choices. NOG technology avoids these problems. It does not generate toxic metabolites, does not require specialised PFAS gas treatment and supports more straightforward repair, maintenance and end-of-life management. That makes it better aligned with EU chemicals policy, zero pollution goals and circularity objectives.

Conclusion

Our Alliance calls on EU policymakers to prevent avoidable new PFAS dependencies which would harm European strategic autonomy in the long-term.

We urge policymakers to:

• Oppose derogations for PFAS-based F-gas insulating gases used in electrical switchgear.

• Recognise high substitution potential for PFAS insulating gases in electrical switchgear up to and above 145 kV.

• Issue procurement guidance so tenders focus on performance and do not exclude PFAS F-gases free designs by default.