PFAS is a big family. Not every member acts alike.
The same label covers the chemicals behind contaminated drinking water and the engineered fluids that cool AI hardware. Learn what separates them, what concerns apply to each, and how the cooling industry manages its fluids.
New to the topic? Three short lessons.
Written for operators, engineers, buyers and policymakers. No chemistry degree required.
Who's behind this site?
Companies that make and sell fluorinated cooling fluids fund this cooperative, so we have a commercial interest in how these fluids are regulated. That's exactly why every claim here links to a primary source you can check yourself.
A definition of structure, not a finding of harm
Modern PFAS definitions look at chemical structure. Under the OECD's 2021 definition, a molecule with even one fully fluorinated carbon counts. That sweeps in persistent surfactants like PFOS and PFOA, and also refrigerants, fire suppressants, medical inhaler propellants and cooling fluids.
It's a sensible way to track a chemical family. On its own, though, it tells you nothing about how a specific molecule moves through water, air or the body.
Same label, different behavior
Each family has real concerns. They just aren't the same concerns, so they call for different controls.
Perfluorocarbons & PFPEs
Hydrofluoroethers
HFOs & fluoroketones
Summary only. Individual products vary, so check each manufacturer's SDS and technical data. [Link each card to peer-reviewed sources before launch.]
A closed loop is a controllable loop
In two-phase immersion cooling, servers sit in a fluid that boils right at the chip. The vapor rises, condenses on a cooling coil and drips back into the bath. Boiling absorbs a lot of heat, which is why the approach suits very dense hardware.
The fluid isn't used up or spread around like foam or a coating. The realistic way it escapes is as vapor, and that's an engineering problem with engineering answers.
Fair to say: single-phase and direct-to-chip cooling are good options for many sites. Two-phase earns its place where heat density is highest.
- Boils at the chip
- Vapor rises
- Condenses on coil
- Drips back
What every member commits to
Read the full commitments[Confirm final wording and how commitments are verified with members before launch.]
Where the rules stand
- 2021OECD publishes its structural PFAS definition.
- 20223M announces it will stop making PFAS by the end of 2025, ending Novec and Fluorinert.
- 2023ECHA publishes the EU universal PFAS restriction proposal. EPA finalizes the TSCA PFAS reporting rule.
- 2024–26EPA pushes back the TSCA reporting window several times. New two-phase fluids enter the market.
- Jan 31, 2027Current TSCA PFAS reporting deadline for manufacturers and importers.
What we don't dispute
An honest conversation starts with the concerns that are well founded.
- Legacy contamination is real.It's a serious public health problem, and the communities affected deserve answers.
- Air persistence matters.Fully fluorinated fluids have high global warming potential. Emissions should be kept as low as possible.
- TFA is an open question.Some low-GWP fluids break down into it. Its long-term effects are an active research area.
- Different doesn't mean harmless.Each chemistry should be judged on its own data. That's all we're asking for.
Questions to ask any fluid supplier
Including our members. A supplier who can't answer these clearly is telling you something. Print this list or take it to your next vendor meeting.
Download the checklist- 1Does this fluid meet the OECD or EU PFAS definition?
- 2What are its global warming potential and atmospheric lifetime?
- 3What does it break down into in the atmosphere, and is TFA one of them?
- 4Is independent toxicity and environmental data published?
- 5What fluid loss rate should I expect in a typical system?
- 6Is there a take-back, reclamation or verified destruction program?
- 7What is its current regulatory status in the US and EU?
- 8How do you expect the regulation to affect supply over the system's life?
Are two-phase cooling fluids the same chemicals found in contaminated drinking water?
Are these fluids banned?
Why not just use single-phase cooling instead?
What happens to the fluid at the end of its life?
Who writes this content, and who pays for it?
The PFAS Guide for Data Center Cooling
A plain-language reference for operators, engineers and buyers.
- Definitions without the jargon
- Chemistry compared family by family
- Current US and EU regulatory status
- The supplier question checklist
Funded by industry. Named in full.
Open to any maker of two-phase cooling fluids that signs the stewardship commitments. No single member controls the content.
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