Position paper - Grouping of PFAS: Regulation by distinct PFAS classes is scientifically superior to classification by a broad PFAS group

Several Member States are gathering information that will be used to prepare an analysis of restriction options for Per- and polyfluoroalkyl substances (PFAS), and subsequently, a REACH restriction proposal.

The American Chamber of Commerce to the EU (AmCham EU) welcomes the openness for stakeholders to provide information to facilitate this process and takes this opportunity to emphasize that while a group-approach can save time and minimize the need for extensive vertebrate testing, it can, if applied too broadly, result in unnecessary restrictions: PFAS is a large and chemically diverse group of approximately 4,700 substances. These substances are not the same and should not be regulated as one group unless there is adequate and sufficient scientific evidence that this approach can be justified based on the principles of read across highlighted in REACH guidance (R.6.2). Please also see AmCham EU’s Consultation Response to Green Deal call area 8.