[Regulatory Update] EPA Review of PFAS Coolant for AI Data Centres Raises New Questions — AI Infrastructure and Chemical Regulation Intersect
This news is a symbolic example of how the build-out of AI-era infrastructure is generating new environmental regulatory challenges. Until now, PFAS has mainly been an issue in semiconductor manufacturing, water treatment and consumer products, but a new structural shift is now beginning — from the expansion of AI demand and data centre construction, through the use of PFAS in high-performance cooling technology and coordination with environmental regulation, to investment in next-generation cooling technology and alternative materials.
Related Regulation Information
EU Chemical & Product Safety Domain
The EU's Chemical & Product Safety Domain is the core area governing product safety and chemical substance management, with human health and environmental protection as its top priority. It encompasses the REACH Regulation, which sets out the comprehensive registration, evaluation, authorization, and restriction of chemical substances; the CLP Regulation, which harmonizes the classification, labeling, and packaging of hazardous substances; the RoHS Directive, which restricts the use of specific hazardous substances in electrical and electronic equipment; the F-Gas Regulation, which mandates the phased reduction of fluorinated greenhouse gases; and the Medical Device Regulation (MDR), which sets out hazardous-chemical-substance requirements for medical devices. The REACH Regulation entered into force in 2007, establishing a framework under which companies must demonstrate the safety of every chemical substance manufactured or imported within the EU. The CLP Regulation is aligned with the UN GHS, and in 2023 new hazard classes were added covering endocrine disruption and PBT/vPvB properties. Since the RoHS Directive entered into force in 2006, the list of restricted substances has continued to expand (the RoHS 10 substances) alongside ongoing review of exemptions. The scope and stringency of regulation are also advancing rapidly through the comprehensively revised F-Gas Regulation (Regulation (EU) 2024/573) adopted in 2024, the revised Industrial Emissions Directive (IED 2.0) that entered into force in 2024, and the proposed comprehensive restriction on PFAS (per- and polyfluoroalkyl substances). Together, these frameworks form the Level 1 Regulatory System through which the EU's chemical and product safety regulations can be understood as a whole.
See this regulation's full analysis (timeline & business impact)EU REACH Universal PFAS Restriction Proposal
The "Universal PFAS Restriction Proposal" under the REACH Regulation is a landmark restriction proposal that, using a broad definition of PFAS (any substance containing at least one fully fluorinated methyl or methylene carbon atom), would in principle ban the manufacture, import, placing on the market, and use of more than 10,000 substances across the EU. The proposal sets either a full ban (with only an 18-month transition period) or time-limited, use-specific derogations (of 5 or 12 years) for particular applications. Even industries where no substitute currently exists — such as medical devices, semiconductor manufacturing, hydrogen energy, and vehicle batteries — would only receive transitional measures with a set expiry.
See this regulation's full analysis (timeline & business impact)💡 The overview and schedule for the regulation related to this article can also be found on the Regulatory Gateway Database page.