The EU's Per- and Polyfluoroalkyl Substances (PFAS) Ban: A Case of Policy over Science

Abstract

The proposal by the European Chemicals Agency (ECHA) to ban over 12,000 per- and polyfluoroalkyl substances (PFAS) has sparked a debate about potential consequences for the economy, industry, and the environment. Although some PFAS are known to be harmful, a blanket ban may lead to significant problems in attempting to replace PFAS-based materials for environmental transition, as well as in medical devices and everyday products. Alternative materials may potentially be less safe, as a rush to replace PFAS would reduce the time needed for toxicological analyses. Studies have shown that PFAS exhibit a diverse range of mechanisms of action, biopersistence, and bioaccumulation potential, and should thus not be treated as a single group. This is particularly true for the class of fluoropolymers. A targeted approach that considers the specific risks and benefits of each chemical may be more effective. Moreover, the proposed ban may also have unintended consequences for the environment as PFAS use is also associated with benefits such as reducing greenhouse-gas emissions and improving energy efficiency. Policymakers must carefully weigh up the potential consequences before making a final decision on the ban.

Keywords: ECHA; PFAS; health; perfluoroalkyl; pollution; polyfluoroalkyl.

Figure 1

A few examples highlight the huge heterogeneity of chemical structures of PFAS, which poses challenges for their regulation. The physical and chemical properties of PFASs vary widely depending on their chain length, branching, and functional groups. These properties affect their environmental fate and transport, bioaccumulation potential, and toxicity. The bonds between the atoms are represented by lines. CAS, Chemical Abstracts Service Registry Number, is a numeric identifier assigned by the Chemical Abstracts Service (CAS) division of the American Chemical Society (ACS). (A) Perfluorooctanoic acid (PFOA), CAS: 335-67-1; (B) perfluorooctanesulfonic acid (PFOS), CAS: 1763-23-1; (C) perfluorononanoic acid (PFNA), CAS: 375-95-1; (D) perfluorohexanesulfonic acid (PFHxS), CAS: 355-46-4; (E) perfluorodecanoic acid (PFDA), CAS: 335-76-2; (F) 2,3,3,3-Tetrafluoro-2-(heptafluoropropoxy)propanoic acid (GenX or HFPO-DA), CAS: 13252-13-6; (G) 2,2-difluoro-2-{[2,2,4,5-tetrafluoro-5-(trifluoromethoxy)-1,3-dioxolan-4-yl]oxy}acetic acid (C6O4), CAS: 682-238-0; (H) P,P-Bis(perfluoro-7-methyloctyl) phosphinothioic acid erbium(3+) salt (3:1), CAS: 500776-89-6; (I) perfluorodecalin, CAS: 306-94-5; (J) perfluorotripropylamine, CAS: 338-83-0; (K) perfluoro-2,3-dimethylbutane, CAS: 354-96-1; (L) perfluoroperhydrophenanthrene, CAS: 306-91-2; (M) perfluoro-(2,5,8-trimethyl-3,6,9-trioxadodecanoic)acid, CAS: 65294-16-8; (N) dotriacontafluorononakis(trifluoromethyl)nonaoxatriacontanoyl fluoride, CAS: 65150-88-1; (O) bis 18:2 fluorotelomer thioether.