Mapping industrial lobbying strategies in the EU PFAS restriction using AI-assisted text analysis

Area of Science:

• Environmental chemistry
• Regulatory science
• Political science

Background:

• The European Union proposed restricting per- and polyfluoroalkyl substances (PFAS).
• This led to significant stakeholder engagement, including a large public consultation by the European Chemicals Agency in 2023.
• Understanding industrial lobbying strategies is crucial for effective chemical regulation.

Purpose of the Study:

• To map and analyze industrial lobbying strategies during the EU's PFAS restriction public consultation.
• To identify common argumentation patterns and tactics used by industry stakeholders.
• To assess the influence of industrial lobbying on regulatory outcomes.

Main Methods:

• Analysis of 4771 unique comments from the European Chemicals Agency public consultation.
• Combination of manual qualitative coding and AI-assisted classification.
• Categorization of comments by stance, exemption requests, and argumentation narratives.

Main Results:

• Industry dominated submissions (68.5%) and predominantly opposed the PFAS restriction (71%).
• A significant majority of industry opponents (78%) simultaneously requested technical exemptions.
• Lobbying arguments focused on economic competitiveness, essentiality, scientific minimization, and responsible innovation.
• Asymmetry in lobbying power favoring industries reliant on PFAS was observed.

Conclusions:

• Industrial actors strategically used opposition coupled with exemption requests to weaken the PFAS restriction's scope.
• Lobbying efforts successfully reframed the debate from chemical risks to economic competitiveness and technological indispensability.
• Technical complexity and mass participation were leveraged to influence regulatory ambition, highlighting power imbalances in regulatory processes.