Position paper - AmCham EU response to Green Deal call area 8: a zero pollution ambition for a toxic-free environment

Please see linked the paper titled "AmCham EU response to Green Deal call area 8: a zero pollution ambition for a toxic-free environment: Grouping of PFAS Regulation by distinct PFAS classes is scientifically superior to classification by a broad PFAS group."

The American Chamber of Commerce to the EU (AmCham EU) welcomes the opportunity to comment on the Green Deal call area 8: Innovative, systemic zero-pollution solutions to protect health, environment and natural resources from persistent and mobile chemicals. Although we support its objective of fostering further research into the health and environmental impact of PFAS substances as well as further development of reliable analytical methods to measure their presence, we are concerned by some statements made by the European Commission in this Green Deal call which we believe ignore scientific facts. From a scientific perspective, trying to restrict PFAS as a class is not scientifically justifiable because it attempts to classify inert solids, liquids, salts and gases in a single class where intrinsic properties such as hazard, vapour pressure, and environmental partitioning are enormously varied.