Long-Chain 

Perfluorinated 

Chemicals 

(LCPFCs) Used in

Carpets

Contract # EP-W-08-010

July 27, 2012

-- Does not contain TSCA CBI --

Prepared for:

Economic and Policy Analysis Branch

Economics, Exposure and Technology Division

Office of Pollution, Prevention, and Toxics

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue

Washington, DC 20460
This Page Intentionally Left Blank
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Front Matter ▌pg. iii

Long-Chain Perfluorinated Chemicals Used in Carpets

Table of Contents

List of Exhibits...................................................................................................................................... v

Contributors......................................................................................................................................... vi

Executive Summary ...........................................................................................................................vii

1. Introduction.............................................................................................................................1-1

2. Carpet Manufacturing............................................................................................................2-1

2.1 Introduction ....................................................................................................................2-1

2.2 Manufacturers Using PFCs in Carpet Products..............................................................2-1

2.3 Manufacturers of Remaining Carpet Products with Long-Chain PFCs .........................2-1

2.3.1 Advanced Polymer, Inc., Carlstadt, NJ.............................................................2-1

2.4 Carpet Manufacturing Process........................................................................................2-2

2.5 Carpet Treatment............................................................................................................2-2

3. Industry Overview ..................................................................................................................3-4

3.1 Sector Definition ............................................................................................................3-4

3.1.1 Primary Manufacturing: Chemical Manufacturing...........................................3-4

3.1.2 Secondary Manufacturing: Carpet Manufacturing and Treatment ...................3-4

3.2 Economic Activity..........................................................................................................3-5

3.3 NAICS Sectors Potentially Using PFCs in Carpets........................................................3-6

3.4 Exports, Imports, and Domestic Consumption...............................................................3-7

3.4.1 U.S. International Trade Commission Data on Imports, 2000 – 2010 .............3-9

4. Role of PFCs in Carpet Manufacturing................................................................................4-1

4.1 Fluorotelomers in Carpets ..............................................................................................4-2

4.2 PFAS in Carpets.............................................................................................................4-5

5. Availability of Alternatives ....................................................................................................5-1

5.1 Clariant ...........................................................................................................................5-1

5.2 DuPont............................................................................................................................5-1
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Front Matter ▌pg. iv

5.3 AGC Chemicals Americas (Asahi).................................................................................5-3

5.4 Daikin Industries ............................................................................................................5-3

5.5 Solvay Solexis................................................................................................................5-4

5.6 BASF ..............................................................................................................................5-4

5.7 Advanced Polymer Inc. ..................................................................................................5-5

5.8 3M...................................................................................................................................5-5

5.9 Other Alternatives ..........................................................................................................5-5

5.10 Conclusions....................................................................................................................5-7

6. References................................................................................................................................6-1
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Front Matter ▌pg. v

List of Exhibits

Exhibit 1-1: Normalized Distribution of Fluorotelomers in Use Sectors Based on Total Reported 

Production Volume..................................................... Error! Bookmark not defined.1-2

Exhibit 3-1: Textile Product Mill Sectors: Economic Activity, 2007 ................................................3-5

Exhibit 3-2: Carpet and Rug Mills: Economic Activity, Historical Data ...........................................3-5

Exhibit 3-3: Carpet and Rug Mill Product Lines: Economic Activity, 2007......................................3-6

Exhibit 3-4: Carpet and Rug Mills: Imports, Exports, and Implied Domestic Consumption, 2007...3-8

Exhibit 3-5: Carpet and Rug Mills: Imports, Exports, Value of Shipments ($1,000), 2007 ..............3-9

Exhibit 3-6: Carpet and Impregnated Fabrics: U.S. Imports, ($1,000,000)......................................3-11

Exhibit 3-7: Carpet Imports, ($1,000,000) .......................................................................................3-12

Exhibit 3-8: Impregnated Fabrics Imports, ($1,000,000).................................................................3-12

Exhibit 4-1: PFCs in Carpet ................................................................................................................4-2

Exhibit 4-2: Fluorotelomers and Chemicals Containing Fluorotelomers Used in Polyurethane Resin4-3

Exhibit 4-3: Fluorotelomers Used in Polyurethane Resin with 2006 IUR Production Data ..............4-4

Exhibit 4-4: PFAS Compounds with 2002, or 2006 IUR Production Volume...................................4-5

Exhibit 5-1: UNIDYNE Multi-SeriesTM Water and Oil Repellent Products.......................................5-4
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Front Matter ▌pg. vi

Contributors

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.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Front Matter ▌pg. vii

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.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Introduction ▌pg. 1-1

1. Introduction

Perfluorinated chemicals (PFCs) are substances with special properties that have a variety of

industrial applications. PFCs are used widely in the textile industry because of their thermo-stability, 

ability to adapt to a variety of surface characteristics, high chemical stability, and other characteristics

(Armeduri and Bouterin 2004). 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). To date, significant adverse effects have not been found 

in the general human population1; however, LCPFCs have been linked to a number of health effects, 

including thyroid disease and reproductive function (Knox, et al., 2011; Melzer, et al., 2010).

Although three broad types of PFCs are used in textiles: fluorotelomers, fluoropolymers, and 

perfluoroalkyl sulfate (PFAS), we found no evidence of fluoropolymers used in carpet treatment

products.

This market profile is developed to support regulatory activities that would limit or eliminate the use 

of long-chain PFCs (LCPFCs) in carpets. This market profile in support for the Significant New Use 

Rule (SNUR) being proposed by EPA for LCPFCs used in carpets is structured in the following way:

 Section 2 identifies individual manufacturers of PFCs and provides a description of the carpet 

manufacturing process. 

 Section 3 provides an overview of the carpet manufacturing sector and its economic activity. 

 Section 4 defines the role of PFCs in the carpet industry.

 Section 5 lists available alternatives to LCPFC-based carpet treatment products.

 

1 Based on review of a number of studies examining health effects of LCPFCs.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 2-1

2. Carpet Manufacturing

2.1 Introduction

U.S. manufacturers have stopped producing LCPFC-based products used for carpet treatment. The 

manufacturers have developed alternative products that are based on short-chain PFCs. Specific 

technologies and products for each of these companies are described in Section 5. 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. 

This section presents a list of companies that manufacture PFC-based products for use in carpets.

During the manufacture of carpets, PFCs may be applied to carpets for oil, stain, grease repellency 

(U.S. EPA 2009b). It is important to note that 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 (3M Company 1999).

Therefore, exposure to carpet treatment chemicals may occur both during and after the manufacturing 

process. EPA’s ORD reviewed literature and found that there were high levels of PFAC in carpet and 

carpet treatment products (levels were from 0.04-14,100 ng/g)2(U.S. EPA 2009b). This is of 

particular concern for children since they engage in a variety of activities on carpets for longer 

periods of time in their earliest years and can be exposed to chemicals in carpets via inhalation. (U.S. 

EPA 2009b). 

2.2 Manufacturers Using PFCs in Carpet Products

EPA is not presenting a list of manufacturers of PFCs used in carpets due to the proprietary nature of 

these data. 

2.3 Manufacturers of Remaining Carpet Products with Long-Chain PFCs

The U.S. manufacturers listed above have stopped producing LCPFC-based products used in carpets. 

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. Additional details on those companies that are found to continue to offer 

LCPFC-based products are provided in this section.

2.3.1 Advanced Polymer, Inc., Carlstadt, NJ

Advanced Polymer, Inc. lists a product, APG-5295, in its catalog, which is described as a 

“Perfluoroalkylacrylate emulsion” by the manufacturer and can be used to carpet protection3(product 

description is dated April 6th 2011). APG-5295 is also described in a product catalog as a “C8-based 

fluorochemical system.”4 This product in no longer manufactured, although limited stock is still 

 

2 EPA referenced the research by ORD in their 2009 Long-Chain Perfluorinated Chemicals (PFCs) Action 

Plan. Therefore, the research and review of the research was completed prior to 2009 (U.S. EPA 2009b).

3

http://www.advpolymer.com/docs/APG-5295.pdf (Accessed 11/30/2011) 

4 Advanced Polymer, Inc. 2011. Product Catalog. Revised June 23, 2011.Available at: 

http://www.advpolymer.com/docs/PRODUCT_CATALOG.pdf (Accessed 11/30/2011).
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 2-2

available for purchase on a first come first served basis.5 A company representative indicated that 

currently C8-based carpet protection products are being replaced with C-6 alternatives.6

2.4 Carpet Manufacturing Process

There are two different processes of carpet manufacturing: 1) tufting and 2) weaving. Tufting is a 

process that uses machines and synthetic materials to manufacture a carpet (WFCA 2011b). The 

tufting process involves the following steps:

(1) Weaving fibers into a backing material,

(2) Dyeing the carpet7,

(3) Applying a coating of latex to the primary back and a secondary backing and sending the carpet 

though a heat press to be squeezed together8, and

(4) Shearing (WFCA 2011b). 

The second carpet manufacturing process, weaving, may be done by hand, looms, or industrial 

machinery using fibers and yarn (WFCA 2011b). The process involves stretching fibers in one 

direction, called warps, tight on a frame and weaving yarn through them, and then laying fibers, 

called wefts, horizontally across the yarn (WFCA 2011b).

Currently, 90 percent of carpets are made with synthetic (i.e., man-made) fibers (WFCA 2011a.). 

Synthetic fibers are either nylon, polypropylene, and polyester, while the most common natural fibers 

are wool, silk and bamboo (WFCA 2011a).

2.5 Carpet Treatment

Anti-stain and anti-soil chemicals can be applied to a wide variety of textiles, including fibers, yarns, 

fabrics, and carpet using the following techniques (Kissa 2001):

 Spraying

 Padding

 Kiss-roll

 Foam application

 Exhaust methods

 

5

Personal Communication with a sales representative at Advanced Polymer, Inc. on 12/13/2011.

6

Personal Communication with a sales representative at Advanced Polymer, Inc. on 12/13/2011.

7 Dyeing can occur before the other steps or at the end of the manufacturing process. Carpets that are dyed 

before the final steps are normally one color; while carpets that are dyed at the end of the process usually 

have a pattern or style. (WFCA 2011b).

8 At the point in the process, manufacturers can apply an anti-stain treatment (WFCA 2011b).
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 2-3

For carpets, spraying is the most popular technique for applying anti-stain and anti-soil chemicals. In 

most cases, these chemicals are applied at the last step of the manufacturing process before the carpet 

is dried (Kissa 2001). However, based on a report by 3M company in 1999, it appears to be possible 

for anti-stain treatment to occur during fiber manufacturing before these fibers are manufactured into 

a carpet.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-4

3. Industry Overview

3.1 Sector Definition

3.1.1 Primary Manufacturing: Chemical Manufacturing

Chemical manufacturing is broadly captured under NAICS 325. This three-digit NAICS sector 

represents an industry involved in the transformation of raw materials (both organic and inorganic) 

via a chemical process and the formulation of products (U.S. Census Bureau 2011c).

Perfluorinated chemicals could be manufactured under a variety of six-digit NAICS codes, within 

NAICS 325: Chemical Manufacturing. Based on a review of NAICS code definitions, the following 

NAICS codes were identified as industries potentially involved in production of perfluorinated 

chemicals.

NAICS Code NAICS Description

325120 Industrial Gas Manufacturing*

325188 All Other Basic Inorganic Chemical Manufacturing

325199 All Other Basic Organic Chemical Manufacturing

325211 Plastics Material and Resin Manufacturing

325212 Synthetic Rubber Manufacturing

325991 Custom Compounding of Purchased Resins

325998 All Other Miscellaneous Chemical Product and Preparation 

Manufacturing

*Includes Fluorocarbon gases manufacturing.

3.1.2 Secondary Manufacturing: Carpet Manufacturing and Treatment

Carpet manufacturing and treatment is part of the textile industry, which primarily involves the design 

or manufacture of clothing as well as the distribution and use of textiles. The textile industry includes

fiber production (natural and synthetic), raw weaving, knitting, dyeing, felting, finishing and printing 

and final make-up into garments (e.g. carpets, fabrics). Natural fibers include animal wools and 

cellulose products such as cotton and flax, while synthetic fibers include rayon, acrylic, polyester, 

polyurethane, polyamide and others. Textiles also include leather articles, upholstered household 

furniture, mattresses, and draperies.

Carpet manufacturing and treatment is represented by NAICS 314110 “Carpet and Rug Mills“ and 

falls under NAICS 314 (Textile Product Mills) that represents manufacturers that produce textile 

products, excluding apparel. The processes used in this sector include cutting and sewing of fabric in 

order to make non-apparel textile products such as woven and tufted carpets (U.S. Census Bureau 

2011d). 
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-5

The Carpet and Rug Mills industry comprises establishments primarily engaged in the following 

activities (U.S. Census Bureau 2011d):

(1) Manufacturing woven, tufted, and other carpets and rugs, such as art squares, 

floor mattings, needlepunch carpeting, and door mats and mattings, from textile 

materials or from twisted paper, grasses, reeds, sisal, jute, or rags. 

(2) Finishing carpets and rugs.

3.2 Economic Activity

Exhibit 3-1 presents the 2007 value of shipments for the 6-digit industry sector “Carpet and Rug 

Mills” and compares it to the economic activity of NAICS 314 (Textile Product Mills). As shown in 

the table, the Carpet and Rug Mills sector accounts for almost half of economic activity within 

NAICS 314.

Exhibit 3-1: Textile Product Mill Sectors: Economic Activity, 2007

NAICS Code NAICS Description

Value of 

Shipments 

($1,000)

% of Total Product 

Mill Industry

314110 Carpet and rug mills $13,054,338 45.5%

314 Textile Product Mills $28,682,164 100.0%

Source: U.S. Census Bureau 2010

Exhibit 3-2 presents historical data from Census on the number of establishments and value of 

shipments for the Carpet and Rug Mills sector. A significant industry growth in terms of the value of 

shipments is observed between 1992 and 2002 and a slight slowdown is exhibited between 2002 and 

2007.

Exhibit 3-2: Carpet and Rug Mills: Economic Activity, Historical Data

Year of Data Number of 

Establishments

5-Year Percent 

Change

Value of Shipments 

($1,000)

5-Year Percent 

Change

2007 335 -17.3% $13,054,338 -6.5%

2002 405 -14.2% $13,958,654 21.5%

1997 472 5.8% $11,492,786 16.9%

1992 446 -6.1% $9,828,300 0.3%

1987 475 - $9,795,000 -

Sources:

2007 data: U.S. Census Bureau, 2010

2002 data: U.S. Census Bureau, 2005a

1997 data: U.S. Census Bureau, 2005b

1992 and 1987 data: U.S. Census Bureau, 1996 (SIC Based)

Notes: 1992 and 1987 data are SIC-based. SIC 2273 is equivalent to NAICS 314110 (Carpet and Rug Mills).
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-6

3.3 NAICS Sectors Potentially Using PFCs in Carpets

It is likely that not all carpet and rug mills manufacture finished products that contain PFCs.

Fluorinated telomers are primarily utilized in the impregnation of carpets or as a chemical finish 

which endows fabrics with stain, soil, or grease repellant characteristics. The focus of this analysis is 

on the economic activity of the carpet manufacturing sectors that impregnate and chemically finish 

their carpets at the textile mill level. It is important to note that carpet mill manufacturers may also

purchase fabrics for use in carpets that are already treated with PFCs. EPA believes that carpet 

treatment products containing long-chain PFCs are not manufactured in or imported into the U.S.

Exhibit 3-3 shows product lines under the Carpet and Rug Mills sector, the corresponding number of 

companies with shipments of $100,000 or greater, and the value of shipments for these products.

Exhibit 3-3: Carpet and Rug Mill Product Lines: Economic Activity, 2007

NAICS Code NAICS Description

Number of 

Companies 

with 

Shipments of 

>$100,000 

Products 

Shipments 

Value ($1,000)

% of 

Industry 

Value

314110 Carpet and rug mills N $12,910,484 100.0%

31411011 Carpet and rugs, woven 14 $444,004 3.4%

31411031

Carpet and rugs, tufted 

only or tufted & finished in 

same plant

73 $11,469,402 88.8%

31411032 Carpet and rugs, finishing 

only 15 $319,137 2.5%

31411051 Other carpet, rugs, and 

mats 32 $432,731 3.4%

3141103Y Carpet and rugs, tufted, 

nsk N $9,626 0.1%

314110W Carpet and rug mills, nsk, 

total N $235,584 1.8%

Source: U.S. Census Bureau 2009.

Notes: Sectors where carpet and rug treatment with PFCs takes place are highlighted in grey.

nsk -"not specified by kind"

N - "Not available or not comparable"

Product shipments value is the total value of all products produced and shipped by all producers.

Generally, tufted carpet is treated with some form of stain resisting chemicals, which helps to 

lengthen the life of the carpet. Of the product line codes listed under the Carpet and Rug Mills sector, 

carpet and rug treatment with PFCs is likely to take place under the following product line codes:

 31411031: Carpet and rugs, tufted only or tufted & finished in same plant;

 31411032: Carpet and rugs, finishing only.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-7

As shown in Exhibit 3-3, most finishing of carpet and rugs occurs at the same plant where the carpet 

or rug is manufactured (89 percent of industry value) – NAICS 31411031. In some instances (2.5 

percent of industry value), carpet finishing takes place separately from the manufacturing process –

NAICS 3141103Y. Furthermore, in some instances, fibers are treated before they are sent to a mill for 

manufacturing carpets or rugs (3M Company 1999). 

3.4 Exports, Imports, and Domestic Consumption

Exhibit 3-4 presents data on imports and exports for the Carpet and Rug Mills sector. The table also 

shows the implied domestic consumption, import penetration and export intensity. Exhibit 3-5

presents the economic activity figures for the Carpet and Rug Mills sector.

In 2007, the value of shipments is $13.1 billion, the value of imports is $2.2 billion, and the value of 

exports is $1.0 billion. According to 2007 Economic Census data and U.S. International Trade 

Commission (ITC) data, U.S. imports represent 16 percent of domestic consumption and exports 

represent eight percent of the value of shipments.

The values for the imports and exports are originally reported in HTS codes that are mapped to 

NAICS codes. The import value represents the cost, insurance, and freight value (C.I.F.), which is the 

landed value of the products at the first port of arrival in the U.S. (U.S. Census Bureau 2011a). The 

C.I.F. import value is essentially the sum of the import charges and the customs value (U.S. Census 

Bureau 2011a). The export value is based on the free alongside ship (F.A.S.) value, which represents 

the value of exports at the U.S. seaport, airport, or border port of export (U.S. Census Bureau 2011a). 

This value is based on the transaction price, which includes inland freight, insurance, and other 

charges, but excludes the cost of loading the merchandise aboard the exporting carrier and the freight, 

insurance, and any charges or transportation costs beyond the port of exportation (U.S. Census 

Bureau 2011a). The value of shipments is reported by U.S. Census Bureau data for each NAICS code.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-8

Exhibit 3-4: Carpet and Rug Mills: Imports, Exports, and Implied Domestic Consumption, 2007

NAICS 

Code

NAICS 

Description

Products 

Description

Value of 

Shipments 

($1,000)1

Imports 

($1,000)2

Exports

($1,000)2

Implied 

Domestic 

Consumption

($1,000)

Import 

Penetration

Export 

Intensity

314110 Carpet and rug 

mills

Carpets and 

Rugs $13,054,338 $2,238,584 $1,047,551 $14,245,371 16% 8%

Sources:

1 U.S. Census Bureau 2010

2 U.S. Census Bureau 2011b

Notes: Imports and exports values are based on products (HTS codes) and not on industry classification (NAICS codes).

Import penetration figures are calculated as a ratio of imports over the value of domestic consumption.

Export intensity figures are calculated as a ratio of exports over the value of shipments.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-9

Exhibit 3-5: Carpet and Rug Mills: Imports, Exports, Value of Shipments ($1,000), 

2007

Sources: U.S. Census Bureau 2010; U.S. Census Bureau 2011b

3.4.1 U.S. International Trade Commission Data on Imports, 2000 – 2010

Historical import data on imports for carpets and treated textile fabrics are available from the U.S. 

International Trade Commission (U.S. ITC). Data on the following HTS codes were accessed via the 

Interactive Tariff and Trade DataWeb.

HTS Code Description

57 Carpets and other textile floor coverings

5903*

Textile fabrics impregnated, coated, covered or laminated with 

plastics

Source: U.S. ITC 2010

*5903 HTS code is not specific to carpets and reflects all textile fabrics impregnated with 

plastics.

In addition to the phase-out of long-chain PFCs in carpet products by domestic manufacturers, EPA 

believes that LCPFC chemical substances are not being imported as part of carpet. As presented in 

Exhibit 3-6, only 16 percent of domestically consumed carpets and rugs are imported from abroad, 

while 84 percent of the product is manufactured in the U.S. 

Long-chain PFCs may be imported into the U.S. from countries like China and applied to carpets 

domestically. We obtained relevant imports data from ITC and concluded that PFCs for which 

Value of 

Shipments

$13,054,338

Imports 

$2,238,584

Exports,

$1,047,551
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-10

imports data are available are not used in carpets.9 EPA believes that imported carpets do not contain 

LCPFCs.

Exhibit 3-7 and Exhibit 3-8 present general imports ($1,000,000) for carpets and impregnated 

fabrics, respectively, for each year, from 2000 to 2010. From 2000 to 2010, carpet imports increased 

by 19 percent and impregnated fabric imports increased by 107 percent (more than doubled). The 

following figures present the time trend for these two industry sectors.

 

9 As a result of our conversation with an ITC representative.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-11

Exhibit 3-6: Carpet and Impregnated Fabrics: U.S. Imports, ($1,000,000)

Material HTS 

Code 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

% Change 

(2000-

2010)

Carpet 57 $1,469 $1,415 $1,535 $1,667 $1,838 $2,000 $2,133 $2,118 $1,914 $1,487 $1,742 19%

Impregnated 

Fabrics 5903 $281 $257 $318 $374 $427 $465 $521 $538 $525 $422 $581 107%

Source: U.S. ITC 2011
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Industry Overview ▌pg. 3-12

Exhibit 3-7: Carpet Imports, ($1,000,000)

Source: U.S. ITC 2011

Exhibit 3-8: Impregnated Fabrics Imports, ($1,000,000)

Source: U.S. ITC 2011

$0

$500

$1,000

$1,500

$2,000

$2,500

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Im

p

orts ($1,0

0

0,0

0

0)

Year

$0

$100

$200

$300

$400

$500

$600

$700

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Im

p

orts ($1,0

0

0,0

0

0)

Year
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-1

4. Role of PFCs in Carpet Manufacturing

Two broad types of fluorochemicals are used in carpets: fluorotelomers (described in Section 4.1) and 

perfluoroalkyl sulfate, PFAS (described in Section 4.2). According to 2006 data, carpet and carpet 

care products are the second largest group of consumer products manufactured using fluorotelomers, 

after apparel (U.S. EPA 2009b). Fluorotelomers are not manufactured using PFOA, but may degrade 

to form PFOA (U.S. EPA 2009b). Fluorotelomers are essentially polymers with a functional group on 

the end of the carbon chain (Danish Ministry of the Environment 2008). On the other hand, PFAS is a 

generic grouping term that encompasses any fully fluorinated carbon chain length sulfonate, including 

perfluorooctane sulfonate (PFOS) (OECD, 2007). 

To date no evidence of fluoropolymers used in carpet treatment has been found.10

The flowchart below presents the broad categories of PFCs used in carpet treatments, their 

subcategories, and estimated production volumes of those chemicals. PFOA’s presence in each 

chemical category was also identified.

The following abbreviations are used in the flowchart:

 FT: Fluorotelomer

 TFE: Tetrafluoro ethylene

 PFAS: Perfluoroalkyl sulfonate 

 PFOA: Perfluorooctanoic acid

 

10 As a result of a conversation with an ITC representative, we believe that none of the imports data on PFCs 

available through ITC are applicable to carpets.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-2

Exhibit 4-1: PFCs in Carpet

4.1 Fluorotelomers in Carpets

Worldwide, repellents account for 4.1 percent of finishing products for textile applications; 

Fluorocarbons make up 59 percent of the repellents category, with paraffins (39 percent) and silicones 

(two percent) comprising the remaining portion (Schindler and Hauser 2004). Fluorotelomers are 

used in the textile market because of their thermo-stability, ability to adapt to a variety of surface 
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-3

characteristics, low refractive indexes, low dielectric constants, and high chemical stability (Armeduri 

and Bouterin 2004). Fluorotelomers are used as soil retardants and stain repellents in carpets (Kissa, 

2001).

Fluorotelomers are used to treat textiles which cannot be laundered, including carpets, by preventing 

or reducing the adhesion of liquid or solid contaminants to the textile fibers. Fluorotelomer carpet 

treatments are incorporated in polymers including fluorinated polyurethanes, fluorinated vinyl 

polymers (Kissa, 2001) and fluorinated acrylate and methacrylate polymers (Scheirs, 1998). These 

fluorinated polymers have a non-fluorinated backbone with fluorinated alkyl chains which provide 

the desired physical characteristics. Fluorinated polyurethanes are noted to be tough but resilient and 

can withstand foot traffic on carpets (Kissa, 2001). Fluoroacrylate and fluoromethacrylate polymers 

are used primarily for fibers and textiles (Drobny 2009), however, at least one company markets 

fluorinated acrylate polymers for use in carpets.

11 Exhibit 4-2 summarizes the fluorotelomers 

identified as ingredients in carpet treatments.

Exhibit 4-2: Fluorotelomers and Chemicals Containing Fluorotelomers Used in 

Polyurethane Resin

Chemical Formula Chemical Description Source

F(CF2)nOH 

n = 6–12 Perfluoroalkyl alcohol Kissa, 2001

F(CF2)nCH2CH2OH

n = 6-14 Perfluoroalkylethyl alcohol Kissa, 2001

F(CF2)nCH2CH2OC(=O)NH(CH2)xn is unspecifiedPerfluoroalkyl carbamic acid 

esters Kissa, 2001

F(CF2)8SO2N(CH3)CH2CH2OH n-Ethyl(perfluorooctane) 

sulfonamidoethyl alcohol Kissa, 2001

F(CF2)nSO2CH(CH3)CH2OC(=O)C(CH3)=CH2 Perfluoroalkylethyl methacrylate Kissa, 2001

F(CF2)nSO2CH(CH3)CH2OC(=O)CCH3=CH2

n is unspecified

Perfluoroalkylsulfonyl

ethylmethacrylate Kissa, 2001

F(CF2)nCH2CH2C(=O)OCH=CH2

n is unspecified Perfluoroalkylethyl acrylate Kissa, 2001

n = 6-12 Kissa, 2001

NA Fluorinated acrylic resins Scheirs, 1998

NA Fluoroalkylethyl phosphates Danish, 2008

Sources: Page 150 of Scheirs, 1998; Pages 565 - 568 of Kissa, 2001, Table 2.1, page 24 of Danish Ministry 

of Environment, 2008.

 

11 Mason Chemical, e.g., Masurf® FS-810 Fluoroaliphatic Polyacrylate Oligomer Fluorosurfactant. 

http://www.masonsurfactants.com/Products/Masurf_FS_810.htm.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-4

Exhibit 4-3 presents 2006 IUR production data for fluorotelomers used in polyurethane resin12.

Exhibit 4-3: Fluorotelomers Used in Polyurethane Resin with 2006 IUR Production 

Data

CAS 

Number Description RFLength

2006 IUR 

Production 

(lb)

Perfluoroalkylethyl Alcohol

647-42-7

1-Octanol, 3,3,4,4,5,5,6,6,7,7,8,8,8-

tridecafluoro6 > 500K - 1M

678-39-7

1-Decanol, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-

heptadecafluoro8 > 1M - 10M

865-86-1

1-Dodecanol, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12

,12-heneicosafluoro10 > 500K - 1M

39239-77-

5

1-Tetradecanol, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12

,13,13,14,14,14-pentacosafluoro12 < 500K

68391-08-

2

Alcohols, C8-14, γ-ω-perfluoro 6-12 < 500K

Perfluoroalkylethyl Acrylate

17741-60-

5

2-Propenoic acid, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12

,12-heneicosafluorododecyl ester

10 > 1M - 10M

27905-45-

9

2-Propenoic acid, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-

heptadecafluorodecyl ester

8 > 1M - 10M

34362-49-

7

2-Propenoic acid, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12

,13,13,14, 14,15,15,16,16,16-

nonacosafluorohexadecyl ester

14 < 500K

34395-24-

9

2-Propenoic acid, 

3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12

,13,13,14,14,14-pentacosafluorotetradecyl 

ester

12 < 500K

Source: OECD 2007, U.S. EPA 2011a

 

12 The 2006 IUR required reporting for chemicals manufactured or imported in quantities above a 25,000 lb 

site-specific production threshold. Thus, it is possible that fluorotelomers may be produced in quantities 

below this threshold and then used in carpets treatment products that are not included in the 2006 IUR 

dataset.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-5

4.2 PFAS in Carpets

Perfluoroalkyl sulfonate (PFAS)13 based compounds are used for treating textiles, fabrics and carpet,

most notably under the trade name Scotchgard, owned by 3M. Scotchgard upholstery and fabric 

protectors are designed to repel spills and make clean-ups easier. It is also used to protect rugs and 

carpets against soiling and restore their original look. Prior to 2003, Scotchgard formulation was 

based on perfluorooctane sulfonate (PFOS) compounds, which contain eight perfluorinated carbons

(considered a long-chain PFC). After 2003, 3M reformulated its Scotchgard product to be based on 

perfluorobutane sulfonate (PFBS) compounds containing four perfluorinated carbons (considered a 

short-chain alternative PFC) (Renner 2006).

It is important to note that based on the literature reviewed and the IUR data, we have not found any 

evidence that PFAS is currently used elsewhere in textile treatment, aside from PFBS in Scotchgard.

Exhibit 4-4 presents 2002 and 2006 IUR production data for all PFAS based compounds. The specific 

PFAS compounds used in textiles and carpet are not known. In the 2002 IUR, 24 PFAS compounds 

were reported, with perfluorinated carbon chain lengths ranging from four to ten (OECD 2007). In 

2006, only two PFAS compounds were reported, both of which are PFBS with perfluorinated carbon 

chain length of four (short-chain). Notably, the reformulation of Scotchgard in 2003 to short-chain 

PFC-based product corresponds with the lack of reported data on long-chain PFAS chemicals in the 

2006 IUR data. All chemicals listed in Exhibit 4-4 were reported to IUR by 3M only. 

Exhibit 4-4: PFAS Compounds with 2002, or 200614 IUR Production Volume

CAS 

Number Description Rf

Length

IUR Production (lbs)

2002 2006

1763-23-1

1-Octanesulfonic acid, 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro8

10K -

500K No Reports

29117-08-6

Poly(oxy-1,2-ethanediyl), α-[2-

[ethyl[(heptadecafluorooctyl)sulfonyl] 

amino]ethyl]-ω-hydroxy8

10K -

500K No Reports

67584–42–3

Cyclohexanesulfonic acid, 

decafluoro(pentafluoroethyl)-, potassium salt 8

10K -

500K No Reports

 

13 Perfluoroalkylsulfonates (PFAS) refers to the group of perfluorinated chemicals of any carbon chain length

terminated with a sulfonate (-SO3-) functional group. The two PFAS compounds described in this section

are perfluorobutylsolfuonate (PFBS; italics added to identify the infix describing carbon chain length),

which contains four perfluorinated carbons, and perfluorooctylsulfonate (PFOS; italics added to identify the

infix describing carbon chain length), which contains eight perfluorinated carbons.

14 2006 is the latest year for which IUR data are available. 
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-6

CAS 

Number Description Rf

Length

IUR Production (lbs)

2002 2006

68867-62-9

2-Propenoic acid, 2-methyl-, 2-

[ethyl[(heptadecafluorooctyl)sulfonyl] 

amino]ethylester, telomer with 2-

[ethyl[(nonafluorobutyl)sulfonyl]amino]ethyl 2-

methyl-2-propenoate, 2-

[ethyl[(pentadecafluoroheptyl)sulfonyl]amino]et

hyl 2-methyl-2-propenoate, 2-

[ethyl[(tridecafluorohexyl)sulfonyl]amino]ethyl 

2-methyl-2-propenoate, 2-

[ethyl[(undecafluoropentyl)sulfonyl]amino]ethyl 

2-methyl-2-propenoate, 1-octanethiol and α-

(1-oxo-2-propenyl)-ω-methoxypoly(oxy-1,2-

ethanediyl) 

4-8

10K -

500K No Reports

68958-61-2

Poly(oxy-1,2-ethanediyl), α-[2-

[ethyl[(heptadecafluorooctyl)sulfonyl] 

amino]ethyl]-ω-methoxy8

10K -

500K No Reports

306974–45–

8

Sulfonic acids, C6-8-alkane, perfluoro, 

compds. with polyethylenepolypropyleneglycol bis(2-aminopropyl) ether

6-8

10K -

500K No Reports

307–35–7

1-Octanesulfonyl fluoride, 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro8

10K -

500K No Reports

375-72-4

1-Butanesulfonyl fluoride, 1,1,2,2,3,3,4,4,4-

nonafluoro4

10K -

500K

>500K -

1M

376–14–7

2-Propenoic acid, 2-methyl-, 2-

[ethyl[(heptadecafluorooctyl)sulfonyl]amino] 

ethylester 

8

10K -

500K No Reports

383–07–3

2-Propenoic acid, 2-

[butyl[(heptadecafluorooctyl)sulfonyl]amino]eth

yl ester 

8

10K -

500K No Reports

1691-99-2

1-Octanesulfonamide, N-ethyl1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro-N-(2-hydroxyethyl)-

8

10K -

500K No Reports

1869-77-8

Glycine, N-ethyl-N-

[(heptadecafluorooctyl)sulfonyl]-, ethyl ester 8

10K -

500K No Reports

2263-09-4

1-Octanesulfonamide, N-butyl1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro-N-(2-hydroxyethyl)

8

10K -

500K No Reports

2795-39-3

1-Octanesulfonic acid, 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro-,potassium salt 

8

10K -

500K No Reports

4151-50-2

1-Octanesulfonamide, N-ethyl1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro8

10K -

500K No Reports

13417-01-1

1-Octanesulfonamide, N-[3-

(dimethylamino)propyl]-

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro8

10K -

500K No Reports

29420-49-3

1-Butanesulfonic acid, 1,1,2,2,3,3,4,4,4-

nonafluoro-, potassium salt 4

10K -

500K < 500K
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Role of PFCs in Carpet Manufacturing ▌pg. 4-7

CAS 

Number Description Rf

Length

IUR Production (lbs)

2002 2006

31506-32-8

1-Octanesulfonamide, 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro-N-methyl8

10K -

500K No Reports

34454-97-2

1-Butanesulfonamide, 1,1,2,2,3,3,4,4,4-

nonafluoro-N-(2-hydroxyethyl)-N-methyl4

10K -

500K No Reports

50598-28-2

1-Hexanesulfonamide, N-[3-

(dimethylamino)propyl]-

1,1,2,2,3,3,4,4,5,5,6,6,6-tridecafluoro6

10K -

500K No Reports

56773-42-3

Ethanaminium, N,N,N-triethyl-, salt with 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,8-

heptadecafluoro-1-octanesulfonic acid (1:1) 

8

10K -

500K No Reports

67906-42-7

1-Decanesulfonic acid, 

1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-

heneicosafluoro-, ammonium salt 

10 10K -

500K No Reports

68156-06-9

Cyclohexanesulfonyl fluoride, 

decafluoro(pentafluoroethyl)-

8

10K -

500K No Reports

307-35-7 Perfluoro-1-octanesulfonyl fluoride 8

10K -

500K No Reports

Source: OECD 2007, U.S. Environmental Protection Agency (U.S. EPA) 2011a, b.

Note: Grey highlights indicate chemicals with production data for 2006.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Alternatives ▌pg. 5-1

5. Availability of Alternatives

Short chain fluorotelomers are being used as substitutes for long chain fluorotelomers in products 

such as textile, carpet and paper additives uses, and tile surface treatments. As of April 2010, EPA 

received a total of more than 75 PMN notices for short chain fluorotelomers (U.S. EPA 2010). 

Furthermore, through the end of 2008, over 100 alternatives of various types have been received and 

reviewed by EPA (U.S. EPA 2009a).

It is important to note that while fluorotelomers, such as substances with an alkyl chain length of C6 

or less, have been used as substitutes for PFOS in a variety of products, telomerization results in 

various telomers of different chain lengths, even if the majority has less than six carbons (Danish 

Ministry of the Environment 2008). Thus, impurities could be found in the short chain products.

Below is a list of alternatives developed by major manufacturers of PFC-based carpet products. Note 

that for Clariant, AGC, and BASF, some of the alternatives may not be used on carpets – the 

manufacturer websites do not always provide sufficient information on specific product uses.

5.1 Clariant 

Clariant developed a product series, called Nuva® N, which uses short-chain (C6) chemistry. One 

product, called Nuva® N2116 liq, is a PFOA-free15 repellent for synthetic fibers and nonwovens, and 

can be used on a variety of textiles.16 Another PFOA-free repellent product, called Nuva® N2114 liq, 

is used in a variety of textiles including, but not limited to, sunshades, umbrellas, shoes, bedding, 

mattress protectors, military uniforms, and sportswear.17 Nuva® N5151 liq is a PFOA-free, soil and 

stain repellent product for foam applications which can be used on carpets.18

5.2 DuPont

DuPont developed an alternative to PFOA-based fluorotelomer products in a step toward reaching 

PFOA elimination targets under EPA’s PFOA Stewardship Program (DuPont 2011). A new line of 

surface protection products, CapstoneTM, based on short-chain chemistry (short-chain molecules that 

cannot break down to PFOA in the environment), is an alternative to fluorotelomer-based products 

such as Zonyl®. Capstone® repellents and surfactants are based on short-chain technology consisting 

 

15

 It is important to note that when a fluoropolymer is called PFOA-free, it means that the PFOA content is 

below the limit of detection.

16

 Clariant Textile Chemicals: Nuva® N2116 liq. 2011. Available at: 

http://www.textiles.clariant.com/C12571C400483A78/vwWebPagesByID/8A961FBAA5272607C12575D

00048F470 (Accessed October 3, 2011).

17 Clariant Textile Chemicals: Nuva® N2114 liq. 2011. Available at: 

http://www.textiles.clariant.com/C12571C400483A78/vwWebPagesByID/ABCE5BDE71BE7555C12572

AC0049E92D (Accessed October 3, 2011).

18

 Clariant Textile Chemicals: Nuva® N5151 liq. 2011. Available at: 

http://www.textiles.clariant.com/C12571C400483A78/vwWebPagesByID/506A4218AA031289C12575D0

0048FF30 (Accessed October 3, 2011). 
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Alternatives ▌pg. 5-2

of six or fewer fluorinated carbons, bound to a “delivery system” such as a polymer or surfactant. 

DuPont CapstoneTM products for textile finishes provide a step-change reduction in trace impurities 

below the limit of detection, designed to offer the same or better performance than their predecessors 

without compromising fluorine efficiency. CapstoneTM products also meet the goals of the U.S. EPA 

2010/15 PFOA Stewardship Program targets for PFOA and precursors.

For the vast majority of textiles applications, including mills and finishers, DuPontTM CapstoneTM 

products are the key ingredient in fabric finishes for apparel, home furnishings and other textiles that 

will be sold to mills by Huntsman under the Huntsman trade name Oleophobol® CP. 

DuPontTM Capstone® products are commercially available in home furnishings, firefighting foam, 

fluorosurfactants, paper packaging, textiles, stone and tile, and leather end uses. DuPont’s goal is to 

transition the majority of the textiles business to short-chain chemistry by the end of 2010.19

DuPont has developed LX Platform of fluorotelomer-based products that includes

DuPontTM Teflon®, Zonyl® and Foraperle® technologies. 20 LX Platform products meet high 

performance and value requirements, while removing nearly all trace levels of PFOA and direct 

precursors to PFOA. The LX Products are among the world’s first commercial fluorotelomer products 

to meet the EPA’s PFOA and direct precursor reduction criteria (including the reduction of higher 

homologue acids and direct precursors).21 Because the LX Platform products were developed using 

technology to remove unintended levels of PFOA and direct precursors, they are intended to be dropin replacements for the existing DuPont products that do not require new equipment or investments, 

causing no disruption or delay in the manufacturing process. 

DuPont claims that this new manufacturing process will remove greater than 97 percent of all trace 

levels of PFOA, its homologues and direct precursors from the LX Platform Products. DuPont also 

states that telomer chemistry, on which LX Platform Products are based, is not made with PFOA, nor 

is PFOA added during the manufacture of DuPont telomer-based products. However, PFOA is found 

at trace levels in some fluorotelomer products as an unintended byproduct of the manufacturing 

process. DuPont believes that no one can substantiate statements that fluorotelomer products are 

“PFOA Free” or have “Zero PFOA” even if test results are below the limit of detection. DuPont 

believes such a claim must be made with scientific accuracy, and analytical methods continue to 

advance to ever-lower detection limits.22 DuPont states that their LX Platform Products are listed on 

global regulatory clearances, such as the U.S. (TSCA), Europe (EINECS), Canada (DSL) and Japan 

(ENCS). 23

 

19 http://www2.dupont.com/Capstone/en_US/uses_apps/textiles/textiles.html

20 DuPont. 2011. Textiles and Carpet Care. Available at: 

http://www2.dupont.com/Zonyl_Foraperle/en_US/uses_apps/carpet_pgs/textiles.html (Accessed 

11/28/2011).

21 http://www2.dupont.com/Zonyl_Foraperle/en_US/products/lx.html

22 http://www2.dupont.com/Capstone/en_US/prod_steward/claims_you_can_trust.html

23 DuPont. 2011. Textiles and Carpet Care. Available at: 

http://www2.dupont.com/Zonyl_Foraperle/en_US/uses_apps/carpet_pgs/textiles.html (Accessed 

11/28/2011).
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Alternatives ▌pg. 5-3

While DuPont is not using long chain PFCs in its products, fluorinated telomers may break down into 

long chain PFCs as unintended byproducts of the manufacturing process.

5.3 AGC Chemicals Americas (Asahi)

AGC Chemicals Americas, Inc., a subsidiary of the Asahi Glass Company of Japan, produces 

fluorotelomers and flouropolymers (e.g., PTFE, and carboxylate) that are used heavily in textiles.

AGC Chemicals Americas manufactures a fluoropolymer, known as their Fluon® PTFE 

(Polytetrafluoroethylene) Resins.24 This resin is manufactured in three forms: as an aqueous 

dispersion, a coagulated dispersion, or as granular powders. Fluon® PTFE can be used to make 

textile membranes. Aqueous dispersions of Fluon® PTFE can be used to make coatings for woven 

fabrics.25

AGC has developed a stain resistant and water and oil repellent PFC product, Guard E-SERIES.26

This product does not contain PFOA or long-chain PFCs and their precursors. Instead, this product 

has six carbons, which is considered a short chain PFC. These PFCs are applied to textiles because 

the product imparts stain resistance and water and oil repellency, while still maintaining the texture, 

breathability and color of the textile. The Guard E-SERIES essentially keeps textile products, such as 

fabric and leather, looking new for longer. Furthermore, this product can also be used in applications 

such as food wrapping materials, trays, cooking paper, water repellent tents, paper, and board. 

5.4 Daikin Industries

Daikin Industries, Ltd and its subsidiaries are attempting to stop manufacturing, selling, and using 

PFOA C8 telomer-based water and oil repellent products by the end of 2012. Daikin specifically uses 

PFOA as a polymerization aid for the manufacture of some of its fluoropolymers and 

fluoroelastomers. They are planning on manufacturing alternatives with processing aids that are not 

PFOA, by 2012. They have also developed a short chain, C6, alternative for their water/ oil repellent 

C8 fluorotelomer products. Daikin has already begun the process of replacing these products (Daikin 

Industries Ltd 2011b).

Daikin Industries, Ltd has jointly developed a product with Dow Corning Corporation called 

UNIDYNE Multi-SeriesTM.

27 UNIDYNE Multi-SeriesTM products are made from C6. Specifically, 

 

24 AGC Chemicals Americas Inc. 2011a. "Fluon® PTFE Resins." Available at: 

http://www.agcchem.com/products/fluoropolymer-resins-compounds/fluon-ptfe-resins (Accessed 

September 29, 2011).

25 AGC Chemicals Americas Inc. 2011b. “Coagulated Dispersion Polymers.” Available at: 

http://www.agcchem.com/docs/fluon-technicaldata/2011/03/16/Fluon®%20Coagulated%20Dispersion%20Polymers.pdf?Status=Master (Accessed 

September 29, 2011).

26 AGC Chemicals Americas, Inc (AGC). “Asahi Guard E-SERIES.” Available at: 

http://www.agcchem.com/products/specialty-chemicals/asahi-guard-e-series (Accessed September 28, 

2011).

27 Daikin Industries Ltd. 2011. "Activities for Environmental Issues of UNIDYNETM " Available at: 

http://www.daikin.com/chm/pro/kasei/unidyne_multi/feature/env.html (Accessed September 30, 2011).
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Alternatives ▌pg. 5-4

these products use ifluoro-silicone hybrid technology.28 Exhibit 5-1 provides a list of these products 

and their features.

Exhibit 5-1: UNIDYNE Multi-SeriesTM Water and Oil Repellent Products

Product Name Features

TG-5601 Soft-hand feel; high wash durability

TG-5541 Soft-hand feel; high water repellency

TG-5543 Soft-hand feel; high wash durability

TG-5502 High water bearing pressure; high alcohol resistance

TG-8111 Oil and grease resistance to paper products

Source: Daiken Industries Ltd. 2012.

Note: TG-5601, TG-5541, and TG-5543 were jointly developed with Dow Corning Corporation.

5.5 Solvay Solexis

In 2009, Solvay Solexis announced that it had developed an alternative to PFOA that will be used in 

its products. Specifically, the PFOA-free Fluorolink products were developed for textile and leather 

good surface treatment in which the PFPE structure delivers reduction of surface energy, water and 

oil repellency, and stain and soil resistance. The Fluorolink products are based on a 

perfluoropolyether structure (rather than perfluoroalkyl) which contains functional groups that are 

able to facilitate interactions with the targeted substrate.

The Fluorolink products can be used on natural and synthetic fibers, washable fabrics like domestic 

and industrial clothing, and furniture fabrics requiring stain and soil release properties. Additionally, 

Fluorolink products can be used for upholstery, wall coverings, and rugs that require durable stain 

release or rainwear, awnings, or sportswear that require highly durable water repellency29.

5.6 BASF

BASF has developed the Lurotex Duo Systems for stain repellent and stain release to protect textiles 

from soiling and staining. The technology is made up of a Lurotex fluorocarbon finish based on 

advanced C6 technology compared to the current C8 technology which allows for an undetectable 

amount of PFOA.

The Lurotex products can be used in consumer apparel like rainwear, business wear, casual wear or 

corporate wear. They can also be used in home textiles like upholstery, tablecloths, drapes, mattress 

 

28 Daikin Industries Ltd. 2011. "Water and Oil Repellents." Available at: 

http://www.daikin.com/chm/products/fiber/index.html (Accessed September 30, 2011).

29 Solvay Solexis, 2009. “Textiles and Leather.” Available at: 

http://www.solvaysolexis.asia/marketsapps/specificmarket/marketapplication/0,,40542-2-0,00.htm. 

(Accessed October 3, 2011).
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Alternatives ▌pg. 5-5

covers, and bed linen. Additionally, the Lurotex alternative technology can be used in technical 

textiles like awnings, parasols, tents, luggage, and transportation fabrics.30

5.7 Advanced Polymer Inc.

Advanced Polymer has a line of short-chain PFC and PFOA-free technologies used in textiles called 

AdvaPel. AdvaPel-712 is a C6 based, non-PFOA contributing, waterborne, cationic, fluoropolymer 

emulsion system designed to impart oil, water and soil repellency to apparel, carpeting and 

automotive fabrics. AdvaPel-734 is a water-based, air dry, fluorochemical finishing agent that imparts 

water, oil and soil repellency to textiles, upholstery and carpeting. AdvaPel -734 is a non-C8 based 

fluoroalkyl compound and is considered PFOA-free.31

5.8 3M

As aforementioned in Section 4.2, prior to 2003, 3M produced a product containing PFOS called 

ScotchgardTM, which protected textiles from stains and soil. 3M began a voluntary phase out of 

PFOS- and PFOA-based products on May 16, 2000 (Hakes and Jariwala 2010). 3M’s new 

ScotchgardTM product contains PFBS (Perfluorobutane Sulfonate), which has a 4 carbon chain, as 

opposed to the 8 carbon chain present in PFOS (EWG 2011). These products can be used as oil and 

water repellents coatings for apparel, carpets, furniture, and leather (Hakes and Jariwala 2010).

5.9 Other Alternatives

A research paper (Lindemann 2007) evaluating commercially available PFOA-free repellent finishes 

was developed at North Carolina State University in 2007. A list of alternative finishes was 

developed and a number of products were selected for evaluation. Results of the work indicated that 

none of the commercially available alternatives tested performed at the same level as the traditional 

PFOA-containing products. Short-chain PFCs showed the highest level of performance. These were 

the only products which were able to provide oil repellency. Silicone and hydrocarbon wax products 

were also evaluated and showed varying levels of performance.

The two primary non PFC-based alternatives for fluorocarbon finishes are (1) hydrocarbon 

hydrophobes and (2) polysiloxane based finishing options. Paraffin wax containing repellents are the 

oldest and least expensive water repellent finishing option for textiles. Paraffin wax containing 

repellents (hydrocarbon wax) are both inexpensive and PFOA free. They are applied as aluminum or 

zirconium soaps. Several other waxes have been developed, but there have been significant issues that 

have affected the viability of these options in the textile industry. For example, DuPont created 

Chrome complexes, a wax based finish, which unfortunately had a blue/green color to it. Two other 

waxes, Pyridinium complexes and N-methylol compounds, may release formaldehyde, a possible 

carcinogen.

 

30 BASF, 2010. “Lurotex®Duo Systems for stain repellent and stain release.” Available at: 

http://www.performancechemicals.basf.com/ev-wcms-in/internet/en_GB/portal/showcontent_tc/content/EV/EV8/textile_processing/lurotex/lurotex. (Accessed October 3, 2011).

31 http://www.advpolymer.com/index.php/products/chemistry/fluoropolymers/
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Alternatives ▌pg. 5-6

Polysiloxane based finishes are water repellent, but may also be a better alternative than Paraffin wax 

because they are considered more durable, have a better tear strength, improved sewability, and 

impart a softer feel to the material (referred to as soft hand).32 One of the benefits of polysiloxanes is 

that they do not lose their water repellency after being washed, which tends to be the case for 

fluorocarbon finishes.33 However, one of the disadvantages to polysiloxanes is that repellency can 

decrease with over-application, or even be lost if the layer of polysiloxane layer is cracked.34

Furthermore, neither hydrocarbon waxes nor polysiloxanes have the property of oil repellency.35

Lindemann (2007) also evaluated other alternatives in the early stages of development. The following 

three methods are being researched and developed (as of 2007), and could be viable alternatives for 

finishing in the future. Plasma aided textile finishing is a “dry” process, instead of “wet” finishing 

process, which would get rid of waste water and the fabric drying processes. Another benefit of this 

alternative is that it does not affect fabric properties. One study, by Zhang, et al. compared plasma 

finishing with a fluorocarbon and ScotchgardTM and found that the plasma treatment worked well in a 

variety of areas, including softness, whiteness of the samples, water vapor permeability, and abrasion 

resistance.36

Another possible method looks at surface roughness, which increases wetting properties because of 

the increased surface area.37 In one research study, the researchers created an ultra-hydrophobic 

surface on a microfiber polyester fabric, based on the findings on surface roughness.38 Several other 

studies have been conducted that look into the relationship between the texture of a surface and water 

repellency.

Finally, fluorinated polysiloxanes may also become an alternative. One study, by Shao, et al., looked 

at a perfluoroalkly-containing multi-epoxy compound (PFME) and found that the chemical was oil 

repellent and had moderate durable press properties.39

 

32 In Lindemann 2007 this information comes from: Schindler, W. D.; Hauser, P. J.; Textile Institute in 

Chemical Finishing of textiles; Crc; Woodhead: Boca Raton; Cambridge, England, 2004, pp 213.

33 In Lindemann 2007 this information comes from: Lee, M.; Nishi, K.; Jeong, D. S.; Tokuyama, T.; Itazu, T.; 

Miyaji, Y.; Wakida, T. Sen'i Gakkaishi 2005, 61, 309.

34 This can occur during washing.

35 In Lindemann 2007 this information comes from: Kissa, E. In Fluorinated surfactants and repellents; 

Surfactant Science Series; Marcel Dekker: New York, 2001; Vol. 97, pp 615. and Schindler, W. D.; 

Hauser, P. J.; Textile Institute in Chemical Finishing of textiles; CRC; Woodhead: Boca Raton; Cambridge, 

England, 2004, pp 213.

36 In Lindemann 2007 this information comes from: Zhang, J.; France, P.; Radomyselskiy, A.; Datta, S.; 

Zhao, J. A.; van Ooij, W. J Appl Polym Sci 2003, 88, 1473.

37 In Lindemann 2007 this information comes from: Bico, J.; Marzolin, C.; Quere, D. Europhys. Lett. 1999, 

47, 220.

38 In Lindemann 2007 this information comes from: Gao, L. C.; McCarthy, T. J. Langmuir 2006, 22, 5998.

39 In Lindemann 2007 this information comes from: Shao, H.; Sun, J. Y.; Meng, W. D.; Qing, F. L. Text. Res. 

J. 2004, 74, 851.
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

Alternatives ▌pg. 5-7

5.10 Conclusions

As a result of our research on alternative technologies and products used for carpet treatment, we 

found that major manufacturers of PFC-based carpet products currently offer alternative products that 

use short-chain PFCs. Additional research is needed to assess performance of those alternative 

products in comparison to LCPFC-based products. 
Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

References ▌pg. 6-1

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Long-Chain Perfluorinated Chemicals (LCPFCs) in Carpets Contract # EP-W-08-010

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