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Action on ‘GenX’: Another ‘forever chemical’ added to the EU list of substances of very high concern

In June this year, EU Government experts voted unanimously in favour of adding GenX chemicals1 (a small group of fluorinated chemicals) to the EU list of substances of very high concern (SHVC), which is a first step in increasing regulatory controls over them.

CHEM Trust submitted comments supporting this recommendation, due to our concerns about their probable serious effects on human health and the environment. We very much welcome this decision and hope that it will send a strong signal to the chemical industry that it is time to move away from the use of these and other fluorinated chemicals. 

What are GenX chemicals?

GenX chemicals are part of a large family of per- and polyfluoroalkylated substances, which are commonly known as PFAS. The “family” has over 4,730 members. The highly stable carbon-fluorine structure of PFAS can only be broken down at very high temperature and therefore they do not degrade in the environment. They are also very mobile, so if they are released into the environment the pollution spreads around the world. PFAS’s extreme persistence has earned them the nickname of ‘forever chemicals’.

GenX chemicals are used as processing aids in the production of fluoropolymer plastics used in applications such as non-stick coatings (eg. TeflonTM). This ‘GenX’ technology was introduced by DuPont in 2009 to replace the use of a different persistent, bioaccumulative and toxic PFAS called PFOA (Perfluorooctanoic acid).

Regrettable substitution

PFOA was banned globally under the Stockholm Convention earlier this year, but was voluntarily phased out by manufacturers in Europe and the US over the past decade in response to stewardship programs and regulation; PFOA was added to the EU SVHC list in 2013.

However, instead of moving away from controversial fluorinated chemicals, the chemical industry developed GenX as a replacement technology for PFOA based on other members of the PFAS group. This alternative was presented by the industry as having a “more favorable toxicological profile. However, as described in the dossier provided to support the listing of GenX chemicals as SVHC, animal studies show that chronic exposure to these chemicals can induce tumours in rats and be linked to toxicity for the liver, the kidney, the blood, and the immune system.

Our letter to the UK Government

Ahead of the Member States expert meeting at the European Chemical Agency ECHA in June, CHEM Trust wrote to the then UK Secretary of State for the Environment, Food and Rural Affairs, Michael Gove MP, to ask the UK Government to support the identification of GenX chemicals as SVHC for the following reasons:

  • GenX chemicals are very persistent. Scientists have argued for decades that high persistence in itself is a major concern as highly persistent chemicals accumulate in the global environment and have the potential to reach critical concentrations at which negative unexpected effects can be triggered. By this point there is no way of removing these contaminants from the environment.
  • GenX chemicals are very mobile. They have been found in drinking water, surface water and seawater in several places in Europe, including the UK and are not removed efficiently in water treatment works. We are very concerned that environmental pollution with GenX chemicals has developed over just a few years (2012-2018) since use of these chemicals started in Europe. In our analysis the increased exposure via mobility in water should be considered of equivalent concern to a chemical that bioaccumulates in organisms.
  • The high persistence of GenX chemicals, combined with their high mobility, means that potential impacts will continue even after cessation of emissions, thus presenting a threat to future generations.

Regulating PFAS as a group

GenX chemicals are the 10th subgroup of PFAS to be added to the SVHC candidate list. EU Environment Ministers recently called for an action plan to eliminate all the non-essential uses of PFAS noting “the growing evidence for adverse effects caused by exposure to PFAS” and “the evidence for widespread occurrence”.

CHEM Trust for many years has advocated a grouping approach to regulating chemicals, where whole groups of chemicals are regulated, rather than taking them one at a time. If PFAS were addressed as a group this would prevent further cases of regrettable substitution such as the GenX chemicals replacing PFOA.

Dr Julie Schneider, CHEM Trust campaigner, said:

“We welcome the listing of persistent and mobile GenX chemicals as substances of very high concern and we hope the chemical industry will realise that it’s not OK to keep substituting PFAS by other PFAS.

Highly persistent chemicals that spread around the world – like PFAS – can pollute the environment for generations and should be phased out as fast as possible due to their potential long-term impact. It’s time that the EU – and global POPs processes – dealt with all the PFAS chemicals to avoid further regrettable substitutions.”

12,3,3,3-tetrafluoro-2 (heptafluoropropoxy) propionic acid, its salts and its acyl halides – HFPO-DA