On May 30, 2021, members of the Global PFAS Science Council commented in support of the proposed revision to the EU legislation on hazard classification, labeling and packaging (CLP) of chemicals, but they add that persistence should be considered a chemical class of its own. At the moment, the European Commission is considering forming four hazard classes that mix persistence with either bioaccumulation, mobility, toxicity, or some combination thereof (FPF reported, here and here).

According to the comment’s authors, “the root cause of most of the serious cases of environmental contamination in the last 50 years has been the high persistence of certain chemicals.” Persistent chemicals include polychlorinated biphenyls (PCBs, FPF reported), chlorofluorocarbons, and per- and polyfluoroalkyl substances (PFAS, FPF reported), the main focus of the group’s work.

The authors argue that future chemical decontamination after any health effects from persistent chemicals are discovered “will be technically challenging, energy intensive, and costly… and some contamination and adverse effects will be irreversible.” While considering persistence as a “stand-alone class” is only now being more openly discussed for chemicals, the EU has already begun similar work with microplastics under the REACH legislation due to the particles’ environmental persistence (FPF reported). In an interview with regulatory news provider Chemical Watch, co-author of the submitted comment Martin Scheringer also notes that the concept of applying a persistence-only approach for chemical hazards was already formally proposed over three decades ago in a scientific journal article in 1977.


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Global PFAS Science Panel (May 30, 2021). “The Global PFAS Science Panel comments on the EU Commission roadmap for Revision of EU legislation on hazard classification, labelling and packaging of chemicals.” European Commission

Andrew Turley (June 9, 2021). “Scientists: Persistence should be ‘stand-alone’ hazard class under CLP.” Chemical Watch