Panel: Future of 2-Phase Immersion Cooling: Addressing the PFAS Challenge

Author: Rolf Brink (Moderator/Promersion), Dr. Cheng Chen (Meta), Mohan Kumar (Intel Fellow), Sam Allen (Wesco VP Engineering), Brandon Marshall (Chemours Global Marketing Manager) Collection: 2023 Global Summit - Cooling Environments

Summary

This panel at OCP Global Summit 2023 convened five industry experts to address what moderator Rolf Brink described as "the biggest hurdle" facing two-phase immersion cooling: the PFAS (Per- and Polyfluoroalkyl Substances) regulatory challenge. All current two-phase immersion fluids are PFAS-based, which places the entire 2-phase immersion cooling market at existential regulatory risk. PFAS chemicals are man-made "forever chemicals" linked to liver damage, cancer, and hormonal imbalances through bioaccumulation; the European Union began PFAS restriction proceedings in 2021 and anticipated major regulatory changes by 2025–2027, while the US EPA announced a risk-based framework in June 2023 using the Toxic Substances Control Act (TSCA).

The panel discussed industry responses from the perspectives of a hyperscaler (Meta), a chip manufacturer (Intel), a systems integrator (Wesco), and a fluid manufacturer (Chemours). Meta's Cheng Chen described the situation as "painful," noting that PFAS regulations impact not only 2-phase immersion fluids but also more than half of single-phase immersion fluid options and many cold plate materials and secondary loop components. Intel's Mohan Kumar framed chip manufacturers as "at the receiving end"—they do not make chemicals but must support whatever cooling medium customers use, making long-term R&D investment difficult given regulatory uncertainty. Sam Allen drew an analogy to the refrigerant industry's transition away from R22, R134a, and other fluorinated gases, arguing that the legislation will proceed regardless of lobbying, and emphasized that the data center industry lacks a unified advocacy voice.

Brandon Marshall of Chemours provided the most concrete roadmap information: molecule development timelines are 10-plus years, meaning near-term alternatives with acceptable GWP (Global Warming Potential), nonflammability, good material compatibility, and low acid formation risk are extremely difficult to develop. The panel consensus was that 2-phase technology is not dead but action is urgently needed on three fronts: educating regulators about specific industrial use cases (as distinct from the broad PFAS definition covering 10,000+ compounds), developing risk-based assessment frameworks similar to the EPA's approach, and continuing technical collaboration through OCP and DMTF to evolve specifications that can accommodate new fluid chemistries.