Sustainable PFAS Action Network Voices Concerns with Proposed REACH Restrictions on PFAS
Today, the Sustainable PFAS Action Network (SPAN) submitted a response to a proposed PFAS regulatory framework received by the European Chemicals Agency (ECHA) that proposes restrictions on PFAS pursuant to REACH.
SPAN encourages international cooperation on PFAS use and emissions reductions through efforts to harmonize approaches to PFAS manufacturing and use limitations. A disjointed approach will otherwise adversely impact critical and essential PFAS and PFAS-containing products made available through international supply chains. International coordination is critical to sustainable PFAS management to not create a patchwork of ineffective regulations around the world that would impede global economic progress and threaten the continued strengthening and development of international supply chains.
PFAS are integral to a vast number of sectors in the US economy as well as the European Community, and major markets around the globe. Renewable energy, automotive manufacturing, business equipment, defense and security applications, semiconductor production, medical devices and pharmaceuticals are just some of the industries that would be adversely impacted by unnecessarily broad and immediate restrictions on certain critical uses of PFAS and PFAS-containing products.
SPAN highlighted concerns with using an overly broad definition for PFAS, the absence of risk-based and essential use considerations, and the inevitable negative effect the restrictions will have on global supply chains. In addition, SPAN expressed a need for more government and private enterprise collaboration on research and development efforts towards remediation, identifying alternatives, and improving the understanding of PFAS effects on human health and the environment.
SPAN encouraged the Commission to implement substantial changes before making recommendations to adopt PFAS restrictions. Such modifications should include:
narrowing the PFAS definition and scope of the restrictions proposed;
providing additional derogation (exemption) based on essential use determinations while providing an established process for requesting additional essential use derogations going-forward;
removing the blanket restriction on PFAS-containing products and articles;
placing additional emphasis on reducing and mitigating PFAS emissions and contamination where they already occur;
and encouraging public-private-academic collaboration on PFAS research and the identification of technically feasible PFAS alternatives.
SPAN was formed to encourage responsible, risk-based PFAS management policies and approaches that are implemented in an orderly manner that protect the environment and human health while creating opportunities to maintain certain critical and essential uses until technically feasible alternatives for such uses and products can be identified and operationalized. For these reasons, SPAN is concerned about the scope and inevitable impacts of the proposed REACH Restrictions on PFAS.
Read SPAN’s full response to the proposed REACH restrictions here.
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