In a press release published on May 4, 2017, the German Environment Agency (UBA) called for a “paradigm shift in chemicals evaluation,” suggesting that, both in research and in regulation, more attention should be given to persistent and mobile chemicals as opposed to the current focus primarily on persistent and bioaccumulative chemicals.

Due to their physico-chemical properties such as high polarity and low sorption tendency, ‘mobile’ chemicals can efficiently enter the water cycle, as they are typically highly soluble in water and at the same time do not bind to solids, neither in a natural setting such as soil, sand or sediment, nor in artificial filter materials such as activated carbon. If such chemicals also resist (bio)degradation, they may persist in the aquatic environment for a long time, and may also be transported over long distances. Therefore, UBA recommends that “industrial chemicals be assessed not only on the basis of their PBT [(persistent, bioaccumulative, toxic)] properties, but also on their mobility, that is their PMT [(persistent, mobile, toxic)] properties.” This novel approach would concern, in particular, the evaluation of chemicals within REACH, e.g. identification as a substance of very high concern (SVHC).

UBA presented its proposal during a workshop held on May 4, 2017, in Berlin. Workshop presentations and a document summarizing workshop discussions will be uploaded later this summer. According to an article by the editor Luke Buxton, published on May 11, 2017 by Chemical Watch, the European Chemicals Agency (ECHA) “welcomed the UBA’s proposal,” but pointed out that “mobility is ‘implicitly included’ in the approaches . . . on chemical safety assessment as part of fate assessment in quantitative risk assessment.” Michael Warhurst from non-governmental organization CHEM Trust applauded UBA’s proposal, saying that it is important to start “acting on persistent and mobile chemicals, as they spread widely in the environment and it is not possible to reverse this contamination if they are later found to be hazardous.”

The physico-chemical properties of potentially qualifying substances, along with a few known examples, have been summarized in a feature article by a group of European scientists, published in August 2016 in the peer-reviewed journal Environmental Science & Technology. Currently, UBA is working on putting together a detailed list of persistent and mobile chemicals, according to several criteria it has proposed during the workshop. The list is expected to be publicized later this summer.

Food contact material (FCM)-relevant substances that may be classified as ‘mobile’ include, for example, quaternary ammonium compounds, per- and polyfluoroalkyl substances (PFASs), and potentially perchlorates (CAS 14797-73-0).

Read more

UBA (May 4, 2017). “’Mobile’ Chemikalien – wenn Filter nichts mehr nützen.(in German)

UBA (April 2017). “REACH in der Praxis IV, Fachworkshop 5. REACH und Rohwasserschutz: PMT-Stoffe erkennen und ihre Emissionen vermeiden.” Projektnummer FKZ 3714 67 416 1 (pdf; in German)

Luke Buxton (May 11, 2017). “German environment agency calls for criteria for ‘mobile chemicals.’Chemical Watch


Reemtsma, T., et al. (2016). “Mind the gap: Persistent and mobile organic compounds—water contaminants that slip through.” Environmental Science & Technology 50(19):10308-10315.