Mapping industrial lobbying strategies in the EU PFAS restriction using AI-assisted text analysis
By Mohammad Sadia, Nathalia Bastos, Janne van Asselt, Thomas Timmerman, Marko Põldma, and Annemarie van Wezel
Environ. Int.
July 1, 2026
DOI: 10.1016/j.envint.2026.110398
The European Union’s proposed restriction of per- and polyfluoroalkyl substances (PFAS) prompted unprecedented stakeholder engagement. This study maps industrial lobbying strategies within the 2023 European Chemicals Agency public consultation, the largest in EU history. Combining manual qualitative coding with large scale AI-assisted classification, we analysed stance, exemption requests, and argumentation patterns across 4771 unique comments.
The analysis reveals a dominant strategy among industrial actors, who contributed 68.5% of all submissions. While 71% of industry stakeholders explicitly opposed the restriction, 78% of these opponents simultaneously requested technical exemptions. This approach contests the regulation’s legitimacy while ensuring technical derogations to weaken its scope. Argumentation clustered around four narratives: economic competitiveness, essentiality, scientific minimization, and responsible innovation. Beyond these empirical findings, we provide an open-access sectoral dashboard to facilitate regulatory oversight and visualize these lobbying patterns. Our analysis reveals an asymmetry in lobbying power by industries that rely heavily on PFAS functionality compared to other stakeholders. The results demonstrate how technical complexity and mass participation can be strategically leveraged to influence regulatory ambition and reframe a debate on chemical risks and public health, into one centered on European competitiveness and technological indispensability.
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