As part of the EU’s landmark Green Deal package, the 2020 Chemicals Strategy for Sustainability called for an ambitious concept: achieving a toxic-free environment by 2030. A central pillar of this ambition is the proposal for a universal PFAS — per- and polyfluoroalkyl substances — restriction, addressing contamination and emissions from the controversial family of substances sometimes known as ‘forever chemicals’.
Action to tackle this family of chemicals is overdue, and European industry is ready to do its part. As the president of the Federation of the European Cookware, Cutlery and Houseware Industries (FEC), I welcome the initiative. FEC members pride themselves on providing safe and durable products to consumers, and were early to phase out these problematic substances. Despite this, the current restriction proposal still needs substantial changes to achieve its goals of protecting human health and the environment while balancing socioeconomic effects, impacts on carbon emissions and circularity.
While many elements of the proposed restriction are well justified, some risk damaging the EU industry’s competitiveness and hindering progress on the green and digital transitions, all while banning substances which are known to be safe. The European authorities need to understand the impacts of the proposal more thoroughly before making decisions which will harm consumers and the European workforce, and perhaps even result in worse environmental outcomes.
As the most complex and wide-ranging chemical restriction in EU history, it is essential that the institutions take no shortcuts, and take the time to clearly understand the unintended environmental and socioeconomic impacts on every sector.
The PFAS restriction proposal is broad, covering over 10,000 substances, many of which were not considered part of the PFAS family in the past. In an effort to catch all possible problematic chemicals that could be used in the future, the member countries which proposed the restriction have cast a net so wide that it also includes substances which pose no risk. Even the OECD, the source of the broad scope used by the authorities, concedes that its definition is not meant to be used to define the list of chemicals to be regulated.
In addition to the legacy PFAS substances, which have serious concerns for human health and the environment, the proposal also includes fluoropolymers in its scope, which are not mobile in the environment, not toxic and not bioaccumulative — a stark contrast to the controversial PFAS substances at the center of contamination scandals across Europe and around the globe.
Fluoropolymers are well studied, with ample scientific evidence demonstrating their safety, and unlike legacy PFAS, technologies exist to control and eliminate any emissions of substances of concern from manufacturing to disposal.
Fluoropolymers are not only safe, their safety is a primary reason for their widespread use. They provide critical functionality in sensitive applications like medical devices, semiconductors and renewable energy technology. They are also used in products we all use in our day-to-day lives, from non-stick cookware to electrical appliances to cars. While in some cases there are alternatives to fluoropolymers, these replacements are often inferior, more expensive, or have even more environmental impact in the long run. Where alternatives aren’t yet identified, companies will need to spend large sums to identify replacements.
In the cookware industry, for example, fluoropolymers provide durable, safe and high-performing non-stick coatings for pots, pans and cooking appliances used by billions of people across Europe and around the globe. Decades of research and development show that not only are these products safe, but their coatings provide the most high-performing, durable and cost-effective solution. Continued research and development of these products is one of the reasons that the European cookware industry is considered a world leader.
Given the critical role that fluoropolymers play in so many products and technologies, forcing a search for inferior or even nonexistent alternatives will harm the EU’s competitiveness and strategic autonomy. In the cookware industry alone, the restriction could cost up to 14,800 jobs in Europe, reduce the economic contribution of the sector to the GDP by up to €500 million, and result in a major shift of production from Europe to Asia, where the products would be made under much less stringent environmental rules. Consumers will also suffer, with new alternatives costing more and being less durable, requiring more frequent replacement and therefore resulting in a larger environmental impact.
Beyond this, companies that enable the green transition, deliver life-saving medical treatments, and ensure our technology is efficient and powerful will all be required to engage in expensive and possibly fruitless efforts to replace fluoropolymers with new substances. What would be the benefit of these costs and unintended consequences, when fluoropolymers are already known to be safe across their whole lifecycle?
The scale of the PFAS restriction is unprecedented, but so are the possible unintended consequences. Industry has contributed comprehensive evidence to help fill in the blanks left by the initial proposal, it is now up to the institutions to take this evidence into account. With such a far-reaching initiative, it is essential that the EU institutions and the member countries thoroughly consider the impacts and ensure the final restriction is proportional, preserves European competitiveness and does not undermine the broader strategic objectives set for the coming years.
Founded in 1952, FEC, the Federation of the European Cookware, Cutlery and Housewares Industries, represents a strong network of 40 international companies, major national associations and key suppliers spread over Europe, including in Belgium, Croatia, France, Germany, Italy, Spain, Switzerland and the Netherlands. Our mission is to promote cooperation between members, and to provide expertise and support on economic and technical topics.