[Viewpoint] Allowing unlimited PFAS manufacturing contradicts the core intention of the European Union’s PFAS restriction proposal
By Anna J. Miller, Amanda Rensmo, Ian Cousins, Rainer Lohmann, Gretta Goldenman, Dorte Herzke, Xenia Trier, Zhanyun Wang, and Martin Scheringer
Environ. Sci. Technol.
April 23, 2026
DOI: 10.1021/acs.est.6c04920
Emissions of per- and polyfluoroalkyl substances (PFASs) are a serious problem due to the extreme persistence of PFASs: once PFASs are present in the environment, it is technically and economically difficult, if not impossible, to remove them. Most PFASs have additional hazardous properties such as mobility, bioaccumulation, and (eco)toxicity and/or are transformed in the environment into hazardous PFASs. The proposal for a universal PFAS restriction in the European Union, submitted by five European countries (dossier submitters) in 2023, addresses the risk of PFASs to human health and the environment by intending to restrict PFASs as a group. (1) Its central ethos is clear: PFAS emissions must be minimized because no safe level of PFAS contamination exists.
The dossier submitters estimate future emissions of PFASs under “business-as-usual” conditions at ∼4.8 million t of PFASs in the European Economic Area (EEA) over a 30-year period, plus 50 000 t of emissions from PFAS manufacturing. (2) In the dossier, the term “PFAS manufacturing” is used to refer only to the synthesis of PFASs, not the downstream processing of PFASs for use in goods and industrial processes; this terminology is adopted in the present Viewpoint. This distinction is significant because viable alternatives for most PFAS uses already exist or are in development, (3,4) but for PFAS manufacturing, the idea of “alternatives” has no meaning, as PFASs are being made rather than used.
To accommodate uses of PFASs without suitable available alternatives today, the proposal allows for derogations. The updated 2025 version presents four restriction options (ROs) for PFAS manufacturing. RO1 is a full ban on manufacturing, use, and placing on the market of PFASs. RO2 allows manufacturing only to supply derogated uses for up to 12 years after the transition period. RO3a and RO3b would allow any PFAS manufacturing with emission control measures, either for 12 years (RO3a) or for an unlimited time (RO3b).
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