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The EPA analyst responsible for this report is Timothy Lehman of the Economic and Policy Analysis Branch; Economics, Exposure and Technology Division; Office of Pollution Prevention and Toxics. Analytical and draft preparation support was provided by Abt Associates, Inc. under EPA Contract No. EP-W-08-010.

Executive Summary

Perfluorinated chemicals (PFCs) are substances with special properties that have a variety of industrial applications. PFCs are used in carpets to impart stain, soil, and grease repellant properties (U.S. EPA 2009c; KEMI 2006). During the manufacturing process, PFCs are utilized in the impregnation of carpets or as a chemical finish which endows fabrics with those characteristics. Long-chain perfluorinated chemicals (LCPFCs) are found world-wide in the environment, wildlife, and humans. They are bioaccumulative in wildlife and humans, and are persistent in the environment (Danish Ministry of the Environment 2008).

There are four typical scenarios for chemical application that could lead to the presence of LCPFCs in carpet products. First, LCPFCs could be applied to carpet at a carpet and rug mill during the manufacturing process. Secondly, LCPFCs could be applied to carpet after the manufacturing process at a separate finishing facility. Thirdly, treatment products containing LCPFCs could be applied to carpets by final consumers in the post manufacturing stage. In the described scenarios, LCPFCs could be domestically produced or imported. In addition, domestically produced carpets could be made using imported fabrics that had been treated with LCPFCs. Finally, carpet containing LCPFCs could be imported into the United States as a final product.

The Agency believes that the LCPFC chemical substances included in the proposed rule are no longer being manufactured, processed, or imported for use as part of carpet or for treating carpet (e.g., for use in the carpet aftercare market) in the United States. Partly as a result of the 2010/15 PFOA Stewardship Program, U.S. manufacturers have stopped producing LCPFC-based products used for carpet treatment. Major manufacturers have developed alternative products that are based on short-chain PFCs. However, a few companies continue to sell previously manufactured products that use LCPFCs. It is expected that no LCPFC-based products will be available for sale in the U.S. once the existing inventory is sold out.

In addition to the phase-out of long-chain PFCs in carpet products by domestic manufacturers, EPA believes that imported carpet products do not contain LCPFCs. Only 16 percent of domestically consumed carpets and rugs are imported, while 84 percent of the product is manufactured in the U.S. Long-chain PFCs may also be imported into the U.S. from countries like China and applied to carpets domestically. The imports data obtained from ITC suggest that no long-chain PFCs for use in carpet treatment are currently imported into the U.S.

Because chemical treatments for carpets are not only applied during the manufacturing process but can also be applied to carpets by the consumers in the post manufacturing stage, exposure to carpet treatment chemicals may occur both during and after the manufacturing process. This market profile is developed to support the Significant New Use Rule (SNUR) being proposed by EPA for long-chain PFCs used in carpets.