The Presence of Pfas in Wastes and Related Implications on the Current and Proposed European Regulatory Framework: A Systematic Critical Review

Nowadays the use of PFAS is widespread in products in modern society and their exposure can occur directly through emissions such as dietary intake, water intake, air inhalation, and skin contact. Additionally, exposure can happen indirectly through the environmental release and degradation of their precursors. To fully understand the potential for life cycle emissions, it is necessary to consider the waste stage, as it is an integral part of a substance life cycle, whether PFAS exists in its pure form as part of a mixture or within an article. Overall, knowledge about the impact of PFAS on current and future waste management remains limited. Therefore, this study conducted a critical analysis of the presence of PFAS in relevant waste streams (plastic; metals; textile and leather; paper and cardboards). It also discussed how this presence could influence waste management, taking into account ongoing updates of the legal framework, with particular attention to proposed new provisions regarding their restriction in the REACH regulation. Within the discussed limits of the critical review, only a very small number of outliers were found to exceed the considered limit of 25 ppb for each material category. The percentage of exceedances ranged from nearly 1% (PFOS measurements in paper and cardboard waste) to 8% ("Other PFAS" in textiles and leather waste). Regarding the analytical methods and current limits identified, a pragmatic solution is suggested. This solution combines "not targeted" and "targeted" methodologies in a stepwise procedure, building upon the OECD definition of PFAS