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The False Promise of the ‘Toxic-Free’ Society: The Case of the Proposed PFAS Restriction

open-access


Lucas Bergkamp

This work is distributed under the Creative Commons Licence Attribution 4.0 International (CC BY 4.0).



With the endorsement of the ideals of the toxic-free and pollution-free environment, EU chemical regulation is evolving rapidly and becoming more and more precautionary, moralistic, and consequently, unhinged. The proposed ‘universal’ restriction of thousands of diverse substances under the label of ‘all PFAS’ through the broadest ban on chemicals ever is illustrative of these trends. This article discusses the EU’s proposed ‘universal’ PFAS restriction and finds that the proposal flies in the face of science-based risk regulation and breaches the law. The proposal’s problematics include the equation of persistence with risk and the undisciplined use of the grouping approach. Rather than reducing chemical risk, the proposal may well increase risks for human beings and the environment while limiting product performance, eliminating a substantial part of the European chemical industry, and harming the economy.

Lucas Bergkamp is a medical doctor and lawyer (University of Amsterdam and Yale Law School) and Senior Policy Advisor to the Conference Board’s Environmental, Social & Governance Center. This article reflects solely the author’s own analysis and opinions.

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