Emission control vs Restriction

The document argues that current EU legislation, including the Industrial Emissions Directive (IED), is insufficient to prevent PFAS pollution and cannot replace a REACH restriction. It highlights gaps in the IED's scope, a lack of specific emission limit values for most PFAS, and weak monitoring and reporting requirements. Furthermore, it finds that occupational health and waste management regulations fail to provide robust protection against PFAS risks. The briefing concludes that while emission controls are a necessary complement, only a REACH restriction can effectively cut pollution at the source.

• Existing EU regulations, such as the Industrial Emissions Directive (IED), occupational health and safety, and waste regulations, are insufficient to create a prevention framework comparable to a REACH restriction, with significant uncertainty regarding their implementation and enforcement.
• The IED has a limited scope that fails to cover all PFAS-emitting activities; for example, it does not extend to thousands of industrial sites, including over 61,000 installations that may emit C6 fluorochemicals and polymers with C6 side-chains and over 100,000 possible PFAS point sources.
• The IED lacks obligatory and strict emission limit values for the broader PFAS group, as most are not listed in the required pollutant categories, and permitting authorities often lack the incentive or requirement to set them for substances emitted in quantities they do not deem 'significant'.
• Current monitoring and reporting under the IED and the Industrial Emissions Portal Regulation (IEPR) are inadequate, with the IEPR only requiring reporting for PFOA and PFOS above a high threshold of 1 kg per year and excluding fluoropolymers.
• The revised IED's requirement for an environmental management system (EMS) and chemicals inventory by July 2027 is viewed as a tool for self-regulation that lacks enforceable prevention or reduction targets.
• Occupational health and safety legislation is inadequate for PFAS because most PFAS lack the CMR (carcinogenic, mutagenic, or reprotoxic) classification or indicative occupational exposure limit values required to trigger specific protection measures.
• Waste management frameworks, primarily the Waste Framework Directive (WFD), lack specific legal obligations for the recycling or full destruction of PFAS-containing waste and only apply strict requirements to a limited number of PFAS classified as hazardous.
• Voluntary industry initiatives and self-regulation are deemed insufficient replacements for binding regulation due to a lack of clear guidelines, an uneven playing field for businesses, and the inability of authorities to sanction non-compliance.

APA

Duguy, H., & Esen, S. (2025). Emission control vs Restriction. ClientEarth. https://www.clientearth.org/media/zjjdkzc3/emission-control-pfas-briefing-final-version-march-2025.pdf

Chicago

Duguy, Hélène, and Selin Esen. Emission control vs Restriction. ClientEarth, 2025. https://www.clientearth.org/media/zjjdkzc3/emission-control-pfas-briefing-final-version-march-2025.pdf.

Wikipedia

{{cite report |last1=Duguy |first1=Hélène |last2=Esen |first2=Selin |title=Emission control vs Restriction |publisher=ClientEarth |date=March 2025 |url=https://www.clientearth.org/media/zjjdkzc3/emission-control-pfas-briefing-final-version-march-2025.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{duguy2025emission, author = {Duguy, Hélène and Esen, Selin}, title = {{Emission control vs Restriction}}, institution = {ClientEarth}, year = {2025}, month = mar, url = {https://www.clientearth.org/media/zjjdkzc3/emission-control-pfas-briefing-final-version-march-2025.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }