Welcome to CPMC
The Complex Products Manufacturers Coalition (CPMC) is a multi-stakeholder group dedicated to driving positive change in policymaking for sensible per- and polyfluoroalkyl substances (PFAS) management. We actively engage with legislators and regulators to promote sustainable, science-based solutions. We advocate for policies that protect human health and the environment while supporting the jobs and the products that are essential to our society’s well-being.
Who We Are
Coalition members assemble tens to hundreds or thousands of parts, components, and raw materials to manufacture products that are frequently referred to as complex durable goods. These include commercial and consumer products such as appliances, electronics, HVACR-WH systems, lighting, outdoor power equipment, communication devices, vehicles, and vessels, as well as their components and replacement parts. Complex durable goods are used to support nearly every major sector in the nation, providing critical and often life-saving services upon which are modern society depends.
Due to the complexities of multi-tiered international supply chains, lengthy product development lead times, difficulties in finding suitable alternatives, and similar complexities, manufacturers of complex durable goods face banned chemical compliance burdens beyond those of most of the regulated community.
CPMC advocates for policymakers to acknowledge this unique segment of industry and the challenges they face. The first step in doing so is to provide clear language in emerging laws, regulations, and policies that defines complex products and durable goods.
Our Initiatives
Regulatory Advocacy
Prioritization Based on Risk
CPMC encourages policymakers to see the necessity of excluding complex goods from the initial scope of PFAS product bans such as by granting “currently unavoidable use” or “critical use exemptions.” Excluding complex durable goods products recognizes their clear societal benefits and the lack of suitable alternatives. These exclusions or exemptions should provide clear and reasonable timelines and abundant notice to stakeholders to account for the extra lead time needed by complex products manufacturers to accomplish product redesigns.
When assessing risk, the potential hazard of a chemical is only one part of the equation; exposure must also be considered. The mandate to evaluate both hazard and exposure in risk assessment is well established in controlling federal law and other jurisdictions.
Not All PFAS Are The Same
Education on Science and Technology of PFAS
The 12,000 + chemicals in the PFAS family have a wide variety of properties and uses so each chemical should be analyzed for its specific characteristics. To provide certainty to the regulated community, policies should identify specific PFAS by Chemical Abstracts Service Registry Number (“CASRN”) and avoid grouping thousands of PFAS chemicals in regulations that are too complex to comply with or to enforce. Furthermore, many chemicals that fall within the scope of the commonly broad structural definition often used to define PFAS actually represent a low risk to human health and the environment, such as fluoropolymers and refrigerants, which are different in structure and risk.
In most cases, complex goods incorporate PFAS in internal components that are essential to the product’s ability to function properly and when present, PFAS are often part of an internal part. Being encased in the product interior means that any components that may include PFAS in their design are not accessible to consumers and therefore have little to no risk of exposure. Furthermore, complex goods have well-established recycling frameworks in place, thus reducing the risk of exposure at end-of-life also.
Join Us
Interested in joining CPMC and learning more about our initiatives? Feel free to reach out to us.
Membership Benefits
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Focused on PFAS
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State and federal advocacy
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Up-to-date information
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Policymaker engagement
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Legislative and regulatory tracker
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Regular meetings
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Legal and policy expertise
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Customized support
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Discussion opportunities with industry peers