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The province of Zeeland calls for a rapid and total ban of PFAS This contribution reflects the position of the province of Zeeland on this consultation. The province of Zeeland supports the proposal for a complete ban on PFAS, to protect the environment and the health of our inhabitants. To avoid substitution of one PFAS for another, we support the fact that the restriction proposal targets the entire group of PFAS. Moreover, the province of Zeeland believes that it is irresponsible to postpone a ban. Since PFAS are forever chemicals and won't disappear from our environment, it is undesirable to take 12 years to phase out PFAS. Especially given the fact that the quality of soil, air and water are increasingly under pressure. In Europe, there is increasing attention to a healthy living environment and stricter standards are being set for pollution of soil, air and water through the Soil Health Directive, the Air Quality Directive and the Water Framework Directive. Setting strict environmental standards for PFAS while at the same time letting new PFAS into the environment is counterproductive. A cross border issue Given the impact PFAS are already having on our living environment in combination with the uncertainties that still surround PFAS, the province also sees the importance of a European approach. The PFAS problem is transnational as is clear from the elevated PFAS concentrations in the river Westerschelde, which originate from a factory across the border in Belgium. Since 2020, the Netherlands has been working with Germany, Denmark, Sweden and Norway on a proposal for a European ban on PFAS (Per- and polyfluoroalkyl substances). On February 7th 2023, your agency published a proposal for a ban (restriction) on PFAS. In parallel, a consultation was issued to gather input on this proposal. Why does the province of Zeeland support the restriction? One off the tasks of the province, as a regional authority, is to ensure a clean and healthy environment for its residents. PFAS are increasingly known to have harmful effects on the health of humans and animals. PFAS are generally very stable, once in the environment PFAS compounds spread easily through soil, air and water. PFAS are used in countless products, which means that PFAS are present in the environment throughout the Netherlands (for illustration, see references 1, 2 and 3). Research shows that all kinds of (consumer) products and waste streams contain PFAS and that people are exposed to PFAS even in their own homes (4). As a result of this ubiquitous presence humans, animals and the environment are permanently exposed to PFAS with potential risks to human and animal health. Research by the RIVM, the Dutch national institute for health and environment, shows that people in the Netherlands already ingest too much PFAS through food alone (5). People living in close proximity to Chemours (a fluorpolymer plant in Dordrecht) are even advised against eating from their own gardens (6) and at several locations in the Netherlands people are advised against eating self-caught fish (e.g. 7). The drinking water companies in the Netherlands (see the reaction submitted to ECHA by VEWIN) point to the inability to completely remove these substances during the production of drinking water. Lastly, in a few recreational lakes around Dordrecht the province had to give a negative swimming advice due to excessive concentrations of PFAS (8). Social importance Public concern about PFAS is high. This is mainly because the effects of PFAS on humans, animals and the environment are not yet clear. Residents living near a PFAS plant or near PFAS-contaminated land or water are rightly concerned about the effects on their health. Heightened media attention is increasing the public awareness of possible harmful effects and public support for these substances is decreasing. The role of industry To date, several industries are continuing to produce and use PFAS, thus releasing them into the environment. Moreover, PFAS are released not only during the production process, but also during use and at the end of their lifetime. In most waste incinerators PFAS are not completely destroyed, which means that even after phase-out, PFAS will continue to be released into the environment. The province of Zeeland is aware that a total ban will demand a lot from the industry, however, trusts in the inventiveness of the market to come up with sustainable, safe and circular alternatives. We believe that a rapid and total ban is a good incentive for companies to change their processes. Where exceptions are allowed, the risk assessment of PFAS should be handled more thoroughly. The province of Zeeland advocates a stricter burden of proof if companies want to continue using PFAS, as an exemption to the new regulation. A rapid total ban is therefore the only correct course. References: 1. PFAS concentraties in de Zeeuwse Wateren, Universiteit Utrecht (2022) 2. Landsdekkend beeld van PFAS in Nederlands grondwater, RIVM (2021) 3. PFAS in seaspray, Vrije Universiteit Amsterdam (2022) 4. PFAS in products and waste streams in the Netherlands, Arcadis, 28 mei 2021 5. Risk assessment of exposure to PFAS through food and drinking water in the Netherlands, RIVM, 2023-0011 6. Risicobeoordeling van PFAS in moestuingewassen uit moestuinen in de gemeenten Dordrecht, Papendrecht, Sliedrecht en Molenlanden, RIVM, 2022-0010 7. Consumptie van producten verontreinigd met PFAS uit de Westerschelde, RIVM, 2002-0020 8. Risicoschatting van PFAS in recreatieplas Merwelanden in Dordrecht, RIVM, KU-2023-0013