SRF media coverage on PFAS

As part of a pan-European media collective called ‘Forever Pollution Project’, SRF published several articles on 14 January 2025. Among other things, these focus on the lobbying against the planned total ban on PFAS at the European level (which the EU has since abandoned). As scienceindustries had participated in the corresponding EU consultation, we were asked to take part in the program. Based on the tendentious questions asked by Kassensturz, we only expressed ourselves in writing – the questions and answers are provided below.

Kassensturz:

• According to our investigation, industry representatives have put forward the argument around a thousand times during the consultation that fluoropolymers are ‘of little concern’ according to the criteria of the Organisation for Economic Cooperation and Development (OECD). Your association has also put forward this argument of ‘PFAS of low concern’ and demands that fluoropolymers be exempt from the PFAS ban. However, the OECD denies to the research cooperation that such criteria exist. Furthermore, the OECD has ‘not carried out an assessment of fluoropolymers’. What do you say to this?

scienceindustries:

We are happy to answer your questions regarding the OECD criteria for PFAS or ‘polymers of low concern’ and note:

• In the past, polymers were generally understood to be a group of substances with low risk potential. That is why they are exempt from the obligation to notify or register under Swiss and EU law. This means that in the past, all polymers were ‘polymers of low concern’. It was only with a broader understanding of relatively low-molecular poly- and oligomers – e.g. non-ionic surfactants based on fatty alcohol, fatty acid or fatty amine alcoxylates , which are polymers but do not correspond to plastics, have a certain oil and water solubility and are therefore bioavailable – the question arose as to whether these substances should be handled differently from polymeric plastics in regulatory terms.
   
• This discussion did not affect plastics, which continued to be understood as ‘polymers of low concern’, including fluoropolymers. This is evident from the discussions of the aforementioned OECD working group, the statements of which have been posted on the OECD website and to which we have referred in our statement. The relevance of polymers, and in particular their toxicological relevance compared to non-polymers, was discussed in the working group. In doing so, the working group came to the conclusion that there is likely to be no clear-cut distinction that is the same for all types of polymers.
   
• The working group agreed that the demarcation between ‘polymer of concern’ and ‘polymer of low concern’ should be in the range between 1,000 and 10,000 monomer units, i.e. if a polymer consists of more monomer units, it can be classified as ‘low concern’. The group was also unanimous in its view that the demarcation should be made on the basis of molecular weight rather than monomer units. It was decided that a molecular weight of 1000 g/mol should be set as the threshold, with a molecular weight of less than 1000 g/mol falling into the ‘concern’ category. Conversely, this also means that a polymer with a molecular weight of over 1000 g/mol, or a polymer with over 1,000 or 10,000 monomer units, is to be counted as a ‘polymer of low concern’.
   
• What is important here is that the working group did not focus on individual
  functional groups in the polymers, but rather on the question of the molecular size from which a combination of monomer units that are classified as hazardous due to their chemical/physical properties no longer have to be classified as hazardous because they increasingly lose these hazardous properties due to the size of the molecule. Since this diminishing hazard with increasing size applies to all polymers, it also applies to fluoropolymers. This clarification is important because the question of ‘polymers of low concern’ and PFAS was widely covered in the media following a publication by the NGO ‘CHEMSEC’.
   
• Where the afore mentioned working group agreed and where it did not could still be read on the OECD page in May 2024. Unfortunately, this compilation can no longer be found.
   

Kassensturz:

In a recent guest commentary in the NZZ am Sonntag, you stated that PFAS are ‘irreplaceable’ and a ‘blessing for society’. In its response to the consultation, scienceindustries also emphasised that there is no alternative to a number of PFAS. The SRF research collaboration has taken a closer look at the argument that there are no alternatives to PFAS. This argument is cited hundreds of times by industry in the consultation on the PFAS ban.

In the vast majority of cases, the companies and associations did not support their argument with specific examples, although the ECHA explicitly requests this. Only 134 of the 525 mentions of this argument that we identified in the documents are accompanied by further information. For example, you write in your consultation response: ‘Some PFAS applications are essential and today with no alternatives to achieve sustainability goals such as climate neutrality, energy efficiency or circular economy.’ It is not described which PFAS applications are involved here.

What do you say to this?

scienceindustries:

• Firstly, it should be noted that PFAS are not a simple group of substances with similar properties that can be summarised. The definition used by the EU includes gases, liquids and solids. Different substances with different properties are used for a wide range of purposes. To lump together all the different groups of substance classes that also correspond to the PFAS definition does not do justice to the complexity of the challenge. This has also been recognised by the EU Commission in the follow-up to the 2023 consultation, and in 2024 it held a series of events with a sectoral focus to better understand the breadth and relevance of the various uses of PFAS; these workshops will continue in 2025.
   
• Secondly, with regard to the specific question, the following example: a significant proportion of the heat pumps installed in the EU and also in Switzerland, which in turn replace oil and gas heating systems and significantly reduce CO2 emissions in buildings, work with heat transfer media that meet the PFAS definition, e.g. among others the agent R-410A, which is present as a gas under normal conditions. Over the past few decades, the installation of these heat pumps as replacements for fossil fuel heating systems has been subsidised by the building programme – tens of thousands of these heat pumps are in use. It is true that alternative media are available for use in heating/cooling units, such as ammonia, butane/propane mixtures or CO2. However, a heat pump designed for R-410A cannot be filled with any of the alternatives mentioned, because it would have to be dimensioned quite differently. Various arguments speak in favour of sensible planning for this application. Firstly, premature replacement of a heating system, i.e. before the heating system has to be replaced anyway due to its age, makes little sense and is economically unfeasible for many users. Secondly, although the alternative technology has basically been introduced to the market, there are not enough heat pumps that are designed for the alternative carrier media available for installation in the short term. Thirdly, the additional personnel required for the dismantling and disposal of the older heat pumps and the installation and commissioning of the newer ones would also be lacking for the foreseeable future. Furthermore, it must be ensured that the alternatives actually perform better overall than the systems currently in use, i.e. in terms of ecological, economic and safety considerations. Particularly in the case of heating systems, ammonia poses completely different challenges in specific applications due to its acute toxicity, and propane/butane mixtures due to their extremely high flammability.
   
• Thirdly, the considerations outlined in the second point must be seriously considered for each application. If this is not done, questions arise regarding sustainable development in economic, social and ecological terms.

Kassensturz:

If these 134 cases, which are described in more detail, are compared with data from the ZeroPM platform, viable alternatives to PFAS can be found in two-thirds of the cases. This applies, for example, to the energy and electronics sector (including lithium-ion batteries), the textile and transport industry or medical devices, but also to the construction sector (coatings, paints, adhesives).

What is your response to this?

scienceindustries:

• As mentioned in the previous point, the individual applications must be clearly defined. We can imagine that there are uses where the use of certain PFAS can be dispensed with without any major loss of system performance. However, this requires a more in-depth clarification of the circumstances of the applications, as well as clarifications regarding the overall ecological relevance of alternatives.
   
• Let us consider, for example, the use of PFAS in medical technology, specifically in instruments for minimally invasive surgery. Fluoropolymers are used in such instruments because their combination of special properties is crucial to success, for example their biocompatibility, low friction values, high electrical insulation capacity and high chemical and thermal stability, which is necessary for sterilisation. The simultaneous presence of the different properties is important here. The search for alternatives that are able to fulfil the entire catalogue of requirements is in full swing, but is proving to be extremely challenging.
   
• We are currently proceeding from the assumption that, in the medium and longer term, alternatives for applications that depend on one or only a few properties, such as those provided by fluoropolymers, will be found not only in research laboratories but will also be available on an industrial scale. Only then will comprehensive substitution be technically and economically possible. However, it is likely that there will be applications for which substitution will take a long time. This is particularly to be expected where a large number of the properties mentioned must be present simultaneously. A substitute material, according to current estimates, could then also have a comparable risk profile, which is not desirable.

Kassensturz:

The above examples show that Scienceindustries is also relying on questionable and false arguments in the consultation on the PFAS ban. What do you say to this?

scienceindustries:

We do not share your assessment. Our submission as part of the EU consultation in 2023, as well as the answers to your enquiry, reflect the best scientific information available to us at the time. They reflect existing know-how and the state of research in our industries.

Kassensturz:

Experts see the lobbying strategies of the tobacco industry as being evoked by the approach of certain companies that use PFAS. They say that risks are being played down even though they have been known for decades. What do you say to this?

scienceindustries:

We cannot confirm this statement. On the contrary, our industry is endeavouring to improve the level of information on PFAS, their uses, the alternatives and the pros and cons of these and to assess them as objectively as possible. To this end, scienceindustries has also supported the political initiatives (the Maret motion on limit values in ordinances and the Moser postulate on a PFAS action plan). scienceindustries actively seeks contact with the authorities in order to make the latest knowledge from industry and trade accessible and usable.

Kassensturz:

The research partnership has also used a scientific method based on data on drinking water, wastewater, etc. to calculate how much PFAS remediation could cost individual European countries in the future. The following figures are obtained for Switzerland: 1 billion Swiss francs over a period of 20 years or 52 million Swiss francs per year if the release of PFAS were to be stopped immediately and Switzerland were to remediate only long-chain PFAS at heavily contaminated sites. 26 billion francs or 1.3 billion annually if PFAS continue to enter the environment and Switzerland were to remediate heavily polluted sites for short-chained PFAS as well. Your association is committed to ensuring that PFAS continue to be used for many years to come; the remediation work could therefore become significantly more expensive. What do you have to say about this?

scienceindustries:

This accusation is also unfounded. scienceindustries is committed to promoting research and development in order to develop alternatives that are better overall than the substances currently in use. On the other hand, companies are constantly working to improve production methods to avoid unintentional emissions. Others are working on technologies that address existing environmental contamination. Research and development, both public and private, will be crucial to technological progress here as well.

Kassensturz:

The Swiss Federal Audit Office recommends ‘examining how the polluter pays principle should be designed in the future so that manufacturers and importers have to contribute financially to the remediation of damage.’ Since some of your members also offer PFAS in Switzerland (as can be seen, for example, from the websites of Chemgo AG and Sigma Aldrich AG), we would like to know from your association: What do you say to this proposal?

scienceindustries:

scienceindustries takes a rather critical view of this recommendation as long as there is no better understanding of the actual causes and emission pathways. The approach taken so far, according to which the polluter is held responsible, works sufficiently well from the industry's point of view and already holds the polluters responsible for environmental contamination to provide material remediation and financial compensation for the damage they cause. There are also doubts as to how a change to the process, which has worked well so far, should be implemented in practice without an escalating bureaucracy and control system significantly increasing prices for consumer products as well as for products used commercially and industrially, and making the high-price island of Switzerland even more expensive.

Kassensturz:

The Swiss Federal Audit Office concludes that Switzerland has so far taken hardly any measures to comprehensively regulate the PFAS group of substances and writes: ‘In line with the precautionary principle and risk reduction, Switzerland should initiate the legislative process for a comprehensive PFAS ban as of today in order to be able to catch up with the EU in terms of timing.’ In the interview with us, the representative of the SFAO stated that a ban would be welcome because it would reduce the amount of PFAS entering the environment and protect the population from further exposure. Why is scienceindustries opposed to such a comprehensive ban?

scienceindustries:

We do not share the view that Switzerland has so far taken hardly any measures to regulate the PFAS group of substances. For years, the FOEN has been subjecting various substances and substance groups that fall under the current PFAS definitions to restrictive rules or even bans in order to protect people and the environment. These include, for example, fire extinguishing foams and heat transfer gases, which are regulated in specific annexes to the Chemical Risk Reduction Ordinance (ORRChem).

A blanket ban is not the right approach. It is essential to understand that PFAS are not a simple group of substances with similar properties that can be summarised together. The definition used by the EU includes gases, liquids and solids. Different substances with different properties are used for a wide range of purposes. Treating all the different groups of substance classes that also meet the PFAS definition in the same way does not do justice to the complexity of the challenge.

This has also been recognised by the EU Commission in the follow-up to the consultation on the comprehensive proposal for a ban in 2023, and in 2024 it held a series of events with a sectoral focus to better understand the breadth and relevance of the various uses of PFAS; these workshops will continue in 2025.