Opinion piece written by Dr Julie Schneider, CHEM Trust Campaigner.
Last week, CHEM Trust submitted its response to the public consultation on the EU universal PFAS restriction proposal. This follows on one year from CHEM Trust, Arnika, Tegengif, HEAL, EEB, ClientEarth, and BUND launching the BAN PFAS manifesto. We have since been joined by 125 organisations from 25 EU countries and beyond, showing that there is huge support for the urgent phase out of PFAS use and manufacturing, to protect our future and our children’s future.
The publication of the universal PFAS restriction proposal under REACH by the authorities of Denmark, Germany, The Netherlands, Norway and Sweden in February 2023 is a remarkable step and every effort should be made to ensure that PFAS phase out is set in European law as soon as possible.
Planetary scale contamination
Per and -polyfluoroalkyl substances, PFAS, are synthetic substances that did not occur in the natural environment until the first PFAS were created in a laboratory and mass produced in the wake of the second world war.
PFAS have now contaminated the entire planet and its inhabitants, and scientists argue that the PFAS planetary boundary has been exceeded.
PFAS contamination already has a significant health and psychological impact on communities affected by high contamination levels. The ubiquity of PFAS in the environment means we are all exposed to at least a low level of PFAS via the food we eat and the water we drink – in addition to the PFAS present in everyday products. 14% of European teenagers have been found to have PFAS in their bodies at levels that may harm their health.
And humans are not the only ones at risk, analysis from the Environmental Working Group has reported that over 600 species across the globe are at risk of harm from exposure to PFAS.
PFAS are the most persistent organic chemicals ever created. This exceptional property means that if emissions of these ‘forever chemicals’ continue, PFAS levels in the environment will only increase, increasing the risk of triggering irreversible large scale adverse health and environmental effects.
There is no questioning that the decontamination of highly polluted sites must be part of the actions to protect current and future generations from exposure to harmful levels of PFAS. However, the achievement of a PFAS-free economy is a prerequisite to stop adding more to the existing pollution burden. Unless action is taken, the dossier submitters of the universal PFAS restriction proposal have estimated that the continued use of PFAS in the EU in the next 30 years would lead to an additional 4.5 million tonnes of PFAS in the environment. The following analogy is often used to describe environmental issues and is also quite apt to describe the issue of PFAS pollution: when the bath overflows, you must turn off the tap first, before reaching for the mop.
A smooth transition for a PFAS-free economy and the role of the universal PFAS restriction
Now that PFAS have permeated every sector of our economy, the transition to a PFAS-free economy won’t happen overnight, of course. This is where the universal PFAS restriction has a crucial role to play; bringing in a legal framework for the smooth phase out of the different PFAS uses.
The restriction will provide specific transitions timelines for different applications, according to the development state of PFAS-free alternatives. Ambitious timelines are vital for incentivising substitution and providing predictability to companies.
While some adjustments to the current restriction proposal may be needed for a smooth transition to a PFAS-free economy, without losing access to critical applications, it is crucial to keep derogations time-limited and as specific as possible. The ambition of the current proposal, i.e. to achieve a PFAS-free economy in the EU by the end of all transition periods, must be retained to ensure a drastic reduction in PFAS emissions in the EU, as promised by the European Commission in the Chemicals Strategy for Sustainability Towards a Toxic-free Environment.
The transition to a PFAS-free economy is underway
The good news is that there is strong evidence that industry will find solutions for alternative products and processes without impacting on the essential needs of society.
- Many progressive companies have already switched to PFAS-free alternatives, and more are determined to phase out PFAS. Since 2020, in the EU, over 100 companies have joined ChemSec’s PFAS Movement, in support of a ban on PFAS.
- PFAS-free alternatives have been developed in challenging applications such as use in firefighting foams where it was previously argued that only PFAS could fulfil the intended functions.
- There are also strong indications that alternatives are being developed for applications in semiconductors or hydrogen productions where PFAS substitution has been claimed as impossible.
With the right support and determination, PFAS-free alternatives can be found. For more information on this read the inspirational story from students of the University of Massachusetts Lowell who within 12 months helped a local company find safer alternatives to PFAS for the production of semiconductors. This is the hopeful vision that we must cultivate and encourage; human creativity can solve this challenge rather than taking a defeatist approach from the start.
Technologies of the future must be PFAS-free
Professor Martin Scheringer, chair of the International Panel on Chemical Pollution and a co-coordinator of the Global PFAS Science Panel, has called on industry to “Innovate beyond PFAS” in an editorial published in Science in July. It is indeed crucial to avoid locking in the technologies of the future with PFAS chemistry. This could lead to growth in PFAS use and an increase in PFAS emissions.
In the electronics and semiconductor sector, the dossier submitters of the universal PFAS restriction proposal anticipate a substantial rise in PFAS emissions over time in their baseline scenario. Based on the assumptions regarding PFAS usage trends in this sector, they foresee a more than 1000% increase in PFAS emissions from 2025 to 2050 for this sector alone (see Annex E, section E.2.11. of the restriction proposal).
Locking in PFAS use in sectors where significant growth is expected would risk negating the positive impact, in terms of emissions reduction, of phasing out PFAS uses in other sectors. This is why, as Professor Martin Scheringer rightly said, society must innovate beyond PFAS.
The EU restriction is the first step towards global PFAS phase out
The European universal PFAS restriction proposal could act as the blueprint for the phase out of PFAS globally. The momentum created by the European PFAS restriction proposal will facilitate the global phase out of PFAS by stimulating innovation in PFAS-free technologies.
The end goal is the achievement of a PFAS-free economy, where society ends its reliance on PFAS chemistry and moves towards a clean and healthy future. The talent and commitment to do so are here, what is needed is the political will and institutional support to unleash and foster human creativity to achieve a PFAS-free economy.
