Take a teaspoon of sugar and spin it into a fluffy cloud. That’s how you make cotton candy. As the EU edges closer to a universal PFAS ban, industry groups are applying the same principle to the facts about fluoropolymers, spinning a fluffy cloud of sticky misinformation about these PFAS plastics.

The aim is to convince regulators that fluoropolymers should be left out of the PFAS ban. But their cotton candy melts as soon as you shine a light on it. Two of the most recent industry reports on fluoropolymers:

• Contain built-in bias by commissioning writers embedded with the industry
• Systematically neglect authoritative research from the European Chemicals Agency, the European Environment Agency, and the OECD
• Exaggerate the importance of side issues that are irrelevant to the discussion of fluoropolymer risks
• Systematically present evidence selectively to favour the fluoropolymer industry

Here, as clearly and concisely as we can, ChemSec explains what you need to know.

Built-in bias

It would be foolish to suggest research paid for by industry is automatically wrong. But it must always be handled with care. Industry builds bias into its approach. This is not because the authors are dishonest, but because the client sets the parameters that shape their conclusions.

This is clear, for example, in industry’s choice of consultants to write about fluoropolymers. The Fluoropolymer Product Group commissioned its report from the consultancy Ramboll, which has a good track record of meeting industry needs on PFAS. In fact, The Financial Times describes Ramboll as “hired by big chemical makers contesting the science that justifies a stricter ban [on PFAS].”

Spectaris, a German trade association for high-tech businesses, also chose a safe pair of hands – a scientist who has spent the last 20 years working for a major manufacturer of products derived from fluoropolymers. Here is another insider who is unlikely to rock the boat.

Let’s examine the recent work by these consultants.

‘These omissions are like trying
to make cotton candy without
using any sugar at all’

Neglecting authoritative research

The Fluoropolymer Product Group (FPG) represents the world’s biggest fluoropolymer manufacturers. It has published a report on the risks posed by fluoropolymers when they become waste. The FPG is using this report to demand a full exemption of fluoropolymers from any PFAS ban.

However, its cotton candy dissolves under scrutiny like dipping it in a hot cup of tea.

First, this report appeared two whole months after a committee of top international scientists published a detailed investigation covering the same subject. This was the Risk Assessment Committee (RAC) of the EU’s chemicals agency ECHA. The committee consists of more than 50 experts nominated by EU Member States.

The FPG mentions this investigation once but says nothing about its findings, including its estimates of PFAS emissions from incineration, which are consistently higher.

Let’s pause here for a moment. A large group of scientific experts compiled the RAC’s opinion over three years. Consultants paid by the industry carried out the FPG’s study, and they failed to engage with this major report, which had been available well before the FPG published its own.

The FPG also ignores a 2025 briefing on fluoropolymers by the European Environment Agency (EEA), the EU’s in-house scientific body. In that briefing, the EEA concluded that incineration may not fully degrade PFAS polymers.

These omissions by the FPG are like trying to make cotton candy without using any sugar at all. But let’s go a little deeper into its reasoning.

(Continues below…)

Presenting evidence selectively

The FPG report systematically makes assumptions that favour the fluoropolymer industry.

Input and output:

To measure the destruction of fluoropolymers at end of life, you need to know how much goes into a waste incinerator and how much PFAS comes out.

The problem is, there are no such studies. Nobody knows how much fluoropolymer goes into any given incinerator. Instead, the FPG made an estimate of fluoropolymer input based on average concentrations of fluoropolymers in European waste. That is a major problem. If you don’t know how much went in, how can you know what percentage the incinerator destroyed?

The only research that has measured fluoropolymers going into an incinerator could not account for what happened to between 20% and 30% of the fluorine coming out. This means a incineration potentially formed and released a wide variety of other fluorinated substances, including PFAS.

As for the incinerator emissions, the research used by the FPG measured only a small number of PFAS compounds. As everyone knows, there are many thousands of these. Just because you don’t look for a particular PFAS does not mean it is not there.

One such compound is TFA, about which there are growing concerns. One study (not cited by the FPG, by the way) found that incineration of fluoropolymers could account for up to 14% of TFA found in rainwater.

Mineralisation or destruction?

Ideally, incineration of fluoropolymers should lead to their mineralisation – full breakdown into their basic elements so no toxic fragments remain. In practice, incineration does not fully mineralise fluoropolymers. The remainder is transformed into other PFAS. If you measure only the mineralisation efficiency, you will therefore overestimate the destruction efficiency.

For this reason, the RAC expressly distinguishes destruction from mineralisation. The FPG does not. Its headline estimate of destruction efficiency is therefore misleading.

General waste or hazardous waste?

Hazardous waste incinerators burn at a higher temperature. The RAC notes that non-hazardous incineration is therefore likely to produce more PFAS emissions.

The FPG, however, decided the two different kinds of incinerators are “comparable” in terms of dealing with fluoropolymers. This is a big assumption to make. One that favours industry, and one the RAC explicitly rejects.

The real world is very different

The FPG neglects the findings of a recent study of fluoropolymers by the OECD. This study shows real-world waste-disposal temperatures are often far below those the FPG assumes operate in the EU. Even these EU standards are not high enough for fluoropolymer disposal, the OECD adds.

Monitoring around incinerators in several EU countries shows they emit PFAS, the OECD points out. Even at incinerator temperatures much higher than EU law requires, fluoropolymer waste can still form PFAS. The OECD also makes the point that in many parts of the world, people burn waste at temperatures far lower than in the EU’s commercial incinerators.

‘This is a big assumption to make. One that favours industry’

Exaggerating side issues

A recent report from Spectaris, the trade association of German high-tech industry, covers much of the same ground as the FPG, and makes the same omissions. It also ignores the heavyweight RAC, EEA and OECD reports, for example.

Its main argument is that fluoropolymers are a unique kind of PFAS and therefore regulators should not lump them together with all the rest. But this is a side issue, a distraction.

“Polymers of low concern”

Not only are they unique, Spectaris argues, but fluoropolymers are of “low concern” because they have chemical, physical and biological properties “predictive of low health and environmental hazards”. This deeply misleading opinion is widespread within industry.

The very person who first floated the notion that fluoropolymers are of “low concern” wrote the Spectaris report. At the time, fluoropolymer manufacturers either paid or employed her and all her co-authors. They claimed the OECD had agreed to this concept, which the OECD has repeatedly denied. Independent researchers have challenged the concept — a fact Spectaris also neglects to mention.

Spectaris is spinning cotton candy out of thin air. The RAC explicitly rejects the concept of “low concern” (and Spectaris again neglects to mention this fact).

A distraction from the real issue

Nobody denies fluoropolymers are different from other PFAS, or even that they have properties that imply lower health and environmental hazards during their use phase. These are big, stable molecules — characteristics that limit their bioavailability and toxicity.

As we have seen above, however, this fact is irrelevant to the real issue: manufacture and disposal create other PFAS. Arguing for the uniqueness of fluoropolymers is therefore a diversion, a distraction, a side issue.

The manufacturing phase

The Spectaris report states that “a reduction in emissions from fluoropolymer manufacturing and processing facilities has been documented in peer-reviewed journals and by regulatory authorities.” Remarkably, it fails to reference this crucial claim. That is most likely because no such documentation exists. Indeed, peer-reviewed literature explicitly states that no one has documented this data.

The existing peer-reviewed literature documents emissions, not reductions in emissions. Indeed, a 2026 global inventory of fluoropolymer production plants found consistent patterns of PFAS contamination around all the plants.

The Spectaris report confirms that fluoropolymer manufacturers can use a large number of PFAS in the process. But nobody knows where they end up during manufacture and end-of-life, or in what quantities.

We should welcome industry’s efforts to clean up its manufacturing processes. Its lack of transparency on these issues, however, undermines its case.