At the end of 2019, the then State Secretary Van Veldhoven announced that the Netherlands would spearhead a European ban on PFAS. Why do you believe it is important for PFAS to be banned?
We are advocating a ban on PFAS because these are substances that do not break down and can cause harm to humans, plants and animals. PFAS are potentially carcinogenic and can adversely affect the immune system. Our aim is to prevent the further manufacture of PFAS that end in up in products and our environment. We are also saying that PFAS should be banned all at once, so that harmful PFAS are not replaced with other PFAS that might also prove harmful over time.
In your opinion, what is the most urgent issue to address where PFAS are concerned?
Above all else, we must stop using PFAS. We also want to make sure that PFAS already present in the environment will not lead to harmful effects on humans and the environment in the long term. Both objectives require a significant amount of work. The issue that we’re facing is that there are many different PFAS, which are used in a wide range of applications.
We need to significantly expand our knowledge in a short period of time to establish precisely what actions will achieve the greatest effect: How do we best deal with the PFAS already present? What are the exact exposure levels and where is exposure highest?
Together with the industry, we are combining all our knowledge and reviewing what actions we must take as part of the PFAS Action Programme. We are joined in this effort by the other relevant departments – the Ministry of Health, Welfare and Sport and the Ministry of Agriculture, Nature & Food Quality. In order to reduce pollution from PFAS, our work in the context of the PFAS Action Programme includes finding custom solutions in collaboration with knowledge institutions and the industry , for example for fire-extinguishing foam and in papermaking. In addition to this, we are working with other relevant departments to update knowledge about PFAS exposure through food and drinking water and other sources, as well as identifying action strategies for further reducing exposure to PFAS.
Why should or does the Netherlands specifically want to play an important role in this? In your opinion, how do Dutch efforts in relation to PFAS link up with efforts on a European level?
The Netherlands announced the initiative on 15 July. Preparations for the European ban, a collaborative effort with Denmark, Germany, Sweden and Norway, are underway. The wide variety of applications and the many types of PFAS means there is a lot of work involved in laying a sound foundation for the proposed ban. That is why it makes sense to tackle this together. A European approach is the most effective strategy and will stop PFAS as close to their source as possible. This is our goal. After all, the Netherlands is not an island. To some extent, we’ll have to look in neighbouring countries for the causes and solutions. There is in fact broad support for a ban among Member States. This was also evident at the Environment Council of June 2019, which called on the Commission to introduce such a measure.
You ask why the Netherlands is among the countries taking a lead on this. PFAS pose a problem as they are harmful to us and our environment. This became more evident when we discovered PFAS pollution in our soil. However, this is by no means an exclusively Dutch problem. Other Member States are increasingly experiencing problems created by PFAS.
Another factor in us taking a leading role is the solid track record of RIVM in Europe. There is a great deal of trust in RIVM’s knowledge of substances and potential measures. And yet another factor is the presence of a large PFAS manufacturer in the Netherlands (Chemours). It has been shown that industrial emissions of PFAS can cause excessive concentrations in the environment. The good news is that emissions have already been reduced by 99%.
What PFAS reduction measures is the Netherlands putting in place ahead of the restriction?
Together with several government ministries, we are mapping out the issues of PFAS and ways to reduce them in the environment and products as comprehensively as possible.
We are not starting from scratch. There are already measures in place at national level to reduce emissions and from 2022 there will be a ban on the use of specific PFAS in food contact materials. We are also working to develop and implement a PFAS Action Programme.
At the European level, restrictions have been imposed on several PFAS applications and work has begun on a proposal to restrict the use of PFAS in fire-fighting foam.
We are researching sources in order to determine the key applications. We are also engaged in talks with businesses and other stakeholders to establish what can be done to limit exposure to PFAS now, ahead of the ban. Joint initiatives with local government bodies are also underway to limit current emissions of PFAS wherever possible and prevent the problem from becoming worse.
Key to the restriction is the concept of ‘essential use’. What is your view on this? Who should decide what qualifies as essential use and does this not offer industries an easy way out?
The Netherlands would like to see a broad ban that covers as many applications of PFAS as possible, with exceptions only for a handful of applications that are genuinely considered indispensable. PFAS also offer important features for specific applications, so it is necessary to carefully consider whether a ban would result in adverse effects. Exceptions should only be granted in very specific cases where the withdrawal of PFAS would genuinely lead to serious problems and where no alternative would be available in the short term. Examples could include specific applications in the medical industry. Exceptions should be temporary and there should for example be an opportunity to review them after a number of years. Ultimately it is the European Commission, the European Parliament and the Member States that will jointly need to decide in the years ahead what applications will and will not be deemed essential under the REACH regulation.
Are things moving fast enough in your opinion? And do you foresee any obstacles?
It is key that we develop an approach for this group of substances both at speed and with care. That is why it is a good thing that all preparations for the ban were launched in 2020.
The formal procedure in relation to this extensive restriction is subject to the same deadlines that apply to single or small groups of substances or applications. This means it is an enormous challenge to get everything done within that timescale. So the main obstacle is perhaps the natural tension between moving at speed and ensuring proper consideration. We want to ensure nothing is overlooked. That is why consultation will take place at several stages throughout the process. We will need all available information to ensure careful deliberation and a solid underpinning. If we do this successfully, this will ultimately help Member States to arrive at a good decision together.
What promise does this restriction hold in your opinion for the long term? What would be the ideal outcome?
The Dutch vision for the long term is clear – all manufacture and use of PFAS must stop, thus halting any new emissions to the environment. It would be very welcome if the ban were to lead to a wave of green innovations and safer alternatives for the current uses of PFAS.
And it would be equally desirable for us as a society to take a lesson from this. For designers of materials and products to consider the health and environmental effects for future generations very early on, if indeed they decide to use chemicals at all. Prevention is the best cure – that is what Safe and Sustainable-by-Design is all about.
