Input to Consultation: Restriction for per- and polyfluoroalkyl substances (PFAS)

November 2021

This document provides IOGP’s input to the consultation on a Restriction for per- and polyfluoroalkyl substances (PFAS).

Restriction of PFAS can have complex impacts and requires careful analysis, also in respect of non-PFAS alternatives. For example, effectiveness of the purpose for which PFAS are used may be impacted or there could be a resulting increase in emissions.

• Non-PFAS alternatives should be considered in a holistic manner i.e. potential impact on effectiveness and required volumes, as changes in volumes could have impacts on logistics (increased transport, increase in emissions)
• There should be awareness and consideration of potentially harmful substances in the proposed alternatives