PFASs-restriction proposal commentary on ECHA's Annex XV restriction report, proposal for a restriction, March 2023

Area of Science:

• Environmental Chemistry
• Toxicology
• Regulatory Science

Background:

• Per- and polyfluoroalkyl substances (PFAS) are a diverse group of over 10,000 chemicals characterized by their extreme persistence.
• Their widespread use stems from unique technical properties, but toxicological data is lacking for most compounds.
• The very high persistence of PFAS and their degradation products meets criteria for being classified as Very Persistent (vP) under REACH regulations.

Discussion:

• Grouping PFAS as a single class for regulatory action is proposed due to significant data gaps and the precautionary principle.
• Closing these data gaps to define subgroups would take centuries, an unacceptable timeframe given potential irreversible harm.
• The German Society of Toxicology's advisory committee supports this broad grouping approach.

Key Insights:

• A precautionary principle justifies treating all PFAS as one group in regulatory proposals, despite a lack of individual substance data.
• Current communication has led to misunderstandings, implying proven health hazards for all PFAS, which is not the case.
• Clear communication is needed to explain the rationale behind broad inclusion, acknowledge data gaps, and discuss essential use derogations.

Outlook:

• Addressing PFAS requires clear communication about data gaps versus current knowledge and the application of the precautionary principle.
• Exploring suitable substitutes is crucial to prevent unintended health consequences from replacements.
• Innovation in remediation techniques is essential to tackle existing persistent environmental contamination caused by PFAS.