Part A: Per- and polyfluoroalkyl substances (PFAS)

Citation: Ruhl, R., Blaauw, R., Thoden van Velzen, U., Booth, A.M., Sørensen, L., Maes, T., Hansen, B.H., Nepstad, R., Igartua, A., Fylakis, G., van Hulst, F., Del Savio, L., Cowan, E., van Leeuwen, J., Vlachogianni, T. (2024). SOS-ZEROPOL2030 Deliverable D4.1 ‘Knowledge and outcomes from T4.1-T4.4 summarised in the integrated analysis section of the individual case study pollutant template. Part A: Per- and polyfluoroalkyl substances (PFAS)’.

Executive Summary

The SOS-ZEROPOL2030 project aims to deliver a stakeholder-led European Seas zero- pollution framework to help achieve the European Union’s long-term ambition of ‘Zero Pollution’ in European seas. The SOS-ZEROPOL2030 project focuses on marine pollution, where (i) per- and polyfluoroalkyl substances (PFAS) and (ii) tyre wear particles (TWPs) were selected as example pollutant case studies for ‘chemical’ and ‘microplastic’ pollution, respectively. It is important to note that these two very complex case study pollutants were intentionally chosen to allow the zero-pollution framework to be stress-tested under the most challenging scenarios. As a part of Work Package 4 (Integrated Case Study Pollutant Assessments) within the SOS-ZEROPOL2030 project, this deliverable report (D4.1. Part A) provides an integrated assessment for PFAS, while a separate report (D4.1 Part B) is available for TWPs. The integrated assessment comprises four primary components: (i) Mapping of primary emission sources along the value chain, (ii) Determination of environmental risk, (iii) Mapping of existing value chain and technological actions and strategies for TWP emission reduction, and (iv) Mapping of current governance strategies/efforts/arrangements for TWP pollution.

Emission sources along the value chain: Estimations indicate that point sources (without end-of-life emissions) are associated with about 5% of the total PFAS emission volume, diffuse sources account for the rest. The largest point emission sources of PFAS in Europe are PFAS production locations, with the majority of the direct emissions from PFAS production processes are to the air (~98%). Production locations are estimated to emit between 27 and 57 tonnes PFAS per annum to surface waters in Europe. Textiles, gases, medical devices, construction, and electronics are the five ‘sectors’ associated with the highest PFAS emissions. It is not currently possible to estimate end-of-life emissions (e.g. at incineration plants or landfill sites) due to a lack of data. As a result of their diverse and diffuse sources, estimates of PFAS emission volumes per environmental compartment are not currently reliable. Generally considered as inert during the use phase, fluoropolymers represent the largest mass of PFAS in end products, and may cause emissions of other, more harmful PFAS during production or end-of-life. Although regulations around fluorinated gases (F-gases) are strict, they, dominate the heating, ventilation, air conditioning and cooling application markets, and leakage cannot be prevented. Some of the most common F-gases metabolize into trifluoroacetic acid (TFA), a mobile and persistent PFAS which is increasing in concentration in natural environments. As PFAS are used in a wide range of industrial sectors and consumer products, banning the production, use, and import of PFAS in the EU is unlikely to result in a rapid decrease in emissions and pollution. Recommendations include:

1. The PFAS restriction proposal could include derogations that allow time-limited use of specific PFAS for specific applications. With continued use comes continued production and/or import, as well as continued (but limited) emissions.
2. PFAS present in the environment may need to be removed from places where concentrations are high (e.g. airfields, military bases). Continued manufacturing, use, import and end-of-life treatment of PFAS requires continuous and stringent monitoring of PFAS in the environment.
3. A comprehensive sampling and analysis programme should ideally include various EU countries and types of landscapes, various environmental matrices, industrial sources and should investigate consumer products.

Environmental risk: The most marine environmental exposure data for PFOS, PFOA and novel PFAS is available for the Greater North Sea, Norwegian Sea, Barents Sea and Baltic Sea areas. Limited or no exposure data is available for Mediterranean and Black Sea. Sufficient toxicity data exists for PFOS and PFOA to conduct a hazard assessment, but sufficient toxicity data is only available for a minority of novel PFAS. A newly developed PFAS risk assessment tool indicated certain European sea regions have more than 25% of sampling stations with PFOS and PFOA levels above the toxicity threshold, while no European sea region had >14% of stations above the threshold for novel PFAS. Monitoring programmes sponsored by governmental bodies in which PFAS measurements are executed regularly and over a long time span are not yet in place in the EU. The combination of limited datapoints, constrained spatial and temporal coverage, and analytical limitations introduces significant uncertainty into the risk assessment of novel PFAS compounds. This uncertainty impacts not only the accuracy of current risk assessments but also the confidence with which environmental managers and policymakers can use these assessments to make decisions. Recommendations include:

1. Expanded monitoring programmes that systematically include novel PFAS, with consistent sampling across a variety of geographic locations and matrices.
2. Improved analytical methodologies that increase the sensitivity, reliability, and comparability of PFAS measurements, especially for emerging compounds.
3. Long-term data collection to support trend analysis and better understand the persistence and accumulation of novel PFAS in various ecosystems.

PFAS emission reduction measures: Product chains in which PFAS play a role are often highly complex and not transparent in terms of which chemicals are used. The synthesis or end-of-life treatments of a material not classified in the existing REACH regulation categories may cause (significant) emissions of harmful PFAS. Some products will remain in which PFAS are considered essential. The incineration of fluoropolymers in rotary kiln ovens at standard conditions for municipal waste or for hazardous waste suffices to destroy almost all PFAS, reducing PFAS emissions compared to landfilling. Importantly, measures to significantly reduce PFAS emissions from production processes have been demonstrated to be implemented successfully. Where essential uses comprise fluorinated gases, measures should be taken to prevent leakage and to enable reuse. Recommendations include:

1. An EU ban is required to force industries to move away from using PFAS in end products where possible. It is anticipated that safer alternatives can and will be found in a timespan of a few years for many products (by direct substitution with a safer chemical, redesign of a product, or finding a different product that fulfils the same function).

Governance strategies/efforts/arrangements for PFAS pollution: Governance analysis points to distinct regional differences in terms of political support (countries proposing the EU restriction all being in the Northeast Atlantic region, countries in the Black Sea region awaiting revisions of EU directives), levels of awareness (minimal awareness on the PFAS issue among stakeholders in the Black Sea region), institutional capacity (advanced research and monitoring programmes in the Northeast Atlantic, limited monitoring in the Black Sea). A disconnect appears to exist between the Bucharest Convention and EU-level governance of PFAS in the Black Sea, where EU-level regulatory developments happen rather independently from the regional sea convention. For the Northeast Atlantic there is more integration, where monitoring expertise at the OSPAR Convention is utilised in the updating of standards in EU legislation. Finally, there are limited national/regional level initiatives independent from EU level. The governance of pollutants of concern seems much stronger at the EU level than at the regional and national level. Recommendations include:

1. The EU should support Member States in better monitoring of PFAS pollution from source-to-sea.
2. In parallel to the various policies, production restrictions and regulations being prepared at the EU level, the EU should encourage best practices already happening.
3. The EU should leverage and amplify the movement of PFAS-free alternatives, already rapidly growing, and seek synergies with industries such as recycling that can accelerate a transition to pollution-free and circular economy.