1. Short summary and outcome of the conference and workshop

1.1 Background and objectives

The Nordic countries have been part of the forefront on the science of PFAS and played active roles in the regulatory actions taken on PFAS in the EU and globally. For example, in January 2023, Sweden, Norway and Denmark, in collaboration with Germany and the Netherlands, submitted a proposal for a universal PFAS-restriction in the EU. A broad PFAS restriction is urgently needed to minimise the exposure to humans and the environment. The broad scope of the proposal entails that essentially all PFAS will be restricted (with some derogated uses). However, companies and enforcement agencies face many challenges in complying with and enforcing the upcoming restriction (and existing PFAS restrictions) as well as finding and implementing non-PFAS alternatives.

In response to these challenges the Nordic Conference on PFAS Substitution – Inspiration, Experiences and Tools was initiated by the Nordic Council of Ministers. The aim of the conference was to gather Nordic companies and agencies to highlight potential challenges and opportunities and to show the way forward toward a PFAS-free future. The goals were to increase the knowledge about the current and upcoming restrictions, spread information about tools for PFAS substitution, share experiences of analytical methods and inspire companies to phase out PFAS.

The aim of the back-to-back workshop was to gather Nordic agencies to share experiences of enforcement project and other activities on PFAS and to discuss challenges and opportunities for enforcement and compliance testing. Furthermore, ideas for possible future Nordic projects were discussed.

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1.2 Summary and key messages

Opening speech

The conference was opened by Romina Pourmokhtari, the Swedish Minister for climate and the environment. The Minister highlighted that the Nordic countries lead the way towards phase-out of PFAS. Furthermore, she said that sharing experiences of substitution, analytical methods and tools, which is the aim of the conference, is in line with the Nordic region as a pioneer in a competitive and innovation-driven transition. For the full speech, see Appendix 3.

Introduction

In the first out of two introductory presentations, Professor Ian Cousins from Stockholm University introduced the audience to PFAS - the definition, diversity, properties and uses. In summary, he pointed out that although PFAS comprise a heterogenous group of substances, the high persistence is the underlying driver of Nordic and global PFAS problems. Furthermore, the continuous release of PFAS will lead to accumulation somewhere in the environment until known or unknown effect thresholds are exceeded, and due to the substances’ high persistence, the exposure is poorly reversible.

In the second introductory presentation, Audun Heggelund from the Norwegian Environmental Agency gave the audience an overview of the existing and upcoming restrictions of PFAS. He highlighted the active role of the Nordic countries for the regulatory process on PFAS.

KEY MESSEGES – INTRODUCTION

All PFAS are extremely persistent or transform to other PFAS that are extremely persistent.
Continuous release of PFAS results in increasing levels in the environment and increased probabilities of known and unknown effects. If harmful levels are reached, exposure is difficult to reverse.
Regulations are a driver for substitution. A broad PFAS restriction is needed to avoid regrettable substitution to other PFAS while also sets framework for the substitution needed.

Inspiration

There are companies that strive towards offering PFAS-free products on the market. Many of these companies go beyond current legislations on PFAS and essentially already comply with the proposed universal PFAS restriction. At the conference, five companies shared their experiences from their journeys to phase out PFAS, including the challenges and opportunities they have encountered. They also gave advise to other companies that want to embark on the same journey.

KEY MESSEGES – INSPIRATION

If companies work together and raise similar requirements on suppliers it is possible to impact product development and the market.
Companies need to have internal policies and goals in place as a foundation for the substitution work. The substitution work needs to permeate the entire organisation, starting with management.
PFAS should not be used out of old habit. Companies and producers should question whether a product really needs PFAS for a certain treatment or function.
Knowledge is key for efficient communication down the supply chain. Companies that want to work on substitution of PFAS should consider seeking knowledge and help from external sources.
Companies are advised to start by mapping the materials that most likely contain PFAS, instead of starting with the whole product line at the same time, which can be overwhelming.
Companies can precede the legislations. Environmental claims can be a competitive advantage.
Companies that work with substitution of PFAS consider that the legislations should be strict, set into force faster, and be enforced more frequently. This would help to achieve a level playing field. Enforcement campaigns by agencies and exposure in media may drive companies to change.

Experiences

Several reports, funded by the Nordic Council of Ministers, have reviewed the range of analytical methods available for measuring PFAS in products (Nordic Council of Ministers 2022, 2024a, 2024b). Despite the advances in analytical chemistry of PFAS, compliance testing of products remains challenging due to the (i) need for multiple methods to test different limit values and (ii) general lack of standardised and validated methods for products. This section of the conference provided a brief overview of different types of analytical methods, introduced a workflow for tiered compliance testing of products and presented experiences from PFAS analyses of different products categories, including food contact materials, textiles, consumer electronics, cosmetics and ski wax.

KEY MESSAGES – EXPERIENCES OF ANALYSIS

Validated and standardised methods for testing of PFAS in products are urgently needed.
Companies, agencies, commercial laboratories and academia need to cooperate to develop analytical methods for PFAS in products.
Cheap, real-time screening methods have been developed for PFAS in ski waxes and could potentially be developed for some other product categories.
A universal PFAS restriction will potentially make compliance testing and enforcement cheaper and less time consuming compared to existing PFAS- restrictions as only one initial test for total organic fluorine may be required.
A systematic workflow provides a tiered approach for efficiently testing compliance with the proposed universal PFAS restriction. The workflow could be particularly useful for communication with contract laboratories.
A three-step workflow could be used for compliance testing of PFAS. The workflow includes a combination of analyses of total fluorine (including fluoropolymers), confirmation of PFAS content and target analysis of individual PFAS.

Tools

The group of PFAS is broad and includes substances that degrade into other PFAS. At the same time, the current restrictions each cover a large number of PFAS, which cannot all be measured by targeted analyses. Therefore, it can be difficult for both companies and enforcement agencies to determine if a product contains regulated PFAS. Thus, there is a need for tools that can help to identify PFAS and provide more insight on these substances in products and potential alternatives. In this section of the conference, the services provided by the Swedish Chemicals Agency, the Swedish Centre for Chemical Substitution, the International Chemical Secretariat (ChemSec) and the Nordic Swan Ecolabel were introduced.

KEY MESSAGES – TOOLS

Tools and other resources to facilitate substitution of PFAS are available, for example the PRIO database from the Swedish Chemicals Agency, the SIN-list, marketplace and the PFAS guide from ChemSec as well as different resources from the Swedish Center for Chemical Substitution. These tools can complement each other.
Companies can use the criteria of the Nordic Swan Ecolabel, or other Type 1 ecolabels, as part of their product development and at the same time use their active chemical work as a competitive advantage.
Ambition, goals and acceptance in the organisation is important as a starting point. Then, the tools can be used to reach the goals of the company.
Identification of suitable alternatives goes hand in hand with product development and is a continuous work. Substitution is a long-term investment.

Workshop on enforcement in the Nordic countries

On the 3^rd of September, representatives from Nordic enforcement agencies gathered at a workshop to discuss experiences from enforcement projects and other agency activities on PFAS.

The presentations included examples of enforcement projects on cosmetics, textiles, and food contact materials, an overview of the Danish national bans on PFAS, as well as examples of the use of the product register and the Danish EPAs surveys on consumer products. Furthermore, activities under PARC (Partnership for the Assessment of Risks of Chemicals) were discussed.

See section 3 for further information from the workshop.