Summary:
This comment relates to the proposal for the restriction of PFASs submitted to ECHA on 7 February.
The restriction proposal aims to restrict the production, use and placing on the market of PFAS in
the future.
In terms of sustainable chemicals regulation, substances that pose unmanageable risks due to their
properties and use profile should be regulated based on scientific assessments. However, the ZVO
believes that a blanket regulation of entire substance groups, irrespective of the actual risk posed
by individual substances, is inappropriate. Therefore, the ZVO rejects the current form of the
restriction proposal. 10,000 various substa nces with different levels of risk are grouped together,
and for most of them , a ban is proposed as the sole regulatory action. Nevertheless, the toxicology
data is limited, and assessing the impact on industry and consumer goods is challenging.
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