BackgroundShort-chain PFASs (per- and polyfluoroalkyl substances) are widely used as alternatives to long-chain PFASs. Long-chain PFASs become gradually regulated under REACH (EC No. 1907/2006) and other international regulations, due to having persistent, bioaccumulative and toxic properties and/or being toxic for reproduction. The increasingly used short-chain PFASs are assumed to have a lower bioaccumulation potential. Nonetheless, they have other properties of concern and are already widely distributed in the environment, also in remote regions. The REACH Regulation does not directly address these emerging properties of concern, complicating the implementation of regulatory measures. Therefore, this study illustrates these environmental concerns and provides a strategy for a regulation of short-chain PFASs within REACH.ResultsShort-chain PFASs have a high mobility in soil and water, and final degradation products are extremely persistent. This results in a fast distribution to water resources, and consequently, also to a contamination of drinking water resources. Once emitted, short-chain PFASs remain in the environment. A lack of appropriate water treatment technologies results in everlasting background concentrations in the environment, and thus, organisms are permanently and poorly reversibly exposed. Considering such permanent exposure, it is very difficult to estimate long-term adverse effects in organisms. Short-chain PFASs enrich in edible parts of plants and the accumulation in food chains is unknown. Regarding these concerns and uncertainties, especially with respect to the precautionary principle, short-chain PFASs are of equivalent concern to PBT substances. Therefore, they should be identified as substances of very high concern (SVHC) under REACH. The SVHC identification should be followed by a restriction under REACH, which is the most efficient way to minimize the environmental and human exposure of short-chain PFASs in the European Union.ConclusionDue to an increasing use of short-chain PFASs, an effective regulation is urgently needed. The concerns of short-chain PFASs do not match the “classical” concerns as defined under REACH, but are not of minor concern. Therefore, it is of advantage to clearly define the concerns of short-chain PFASs. This might facilitate the following restriction process under REACH.

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Background: Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) are the most investigated substances of the group of per-and polyfluorinated chemicals (PFCs). Whereas for PFOS regulatory measures are already in force on international level (inclusion in Stockholm Convention on Persistent Organic Pollutants) such activities are missing for PFOA. The environmental concerns of PFOA, which are summarized in the present study, underline the necessity of regulatory measures on an international level for PFOA. Since it seems more likely to agree on a regulation within the European Union first, a regulatory strategy based on the European chemicals regulation REACH (EC No. 1907, is discussed in the present study.

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Over the past decades, thousands of different per- and polyfluoroalkyl substances (PFASs) have been produced and applied in various industrial processes and consumer products. Their structural diversity has reached a level that cannot be covered by classical target screening methods for individual compounds. Large-scale contaminations of soil, however, require the need to adapt new analytical methods that can describe a contamination more comprehensively. While sum parameters such as the total oxidisable precursor (TOP) assay have been developed in the past years, they are not yet applied in the regulatory context of PFASs.In this commentary, we provide an overview on different approaches of the TOP assay as well as its benefits and disadvantages to other sum parameters for PFASs in soil samples. Furthermore, we elaborate its opportunities and its challenges that need to be tackled to implement the TOP assay as a regulatory tool. With several different approaches of the TOP assay being available, a sound and standardised method needs to be agreed upon and more research is necessary to better describe the method. Although the complexity of PFAS contaminations in soil cannot be fully covered by any analytical method alone, the TOP assay can provide valuable data to detect and characterise soil contamination as an inventory for subsequent remediation measures. Therefore, the TOP assay should be implemented as a useful tool both in research and in the regulatory context of PFASs.