Deliverable D5.8 - Modular recommendations for evaluation and implementation of relevant EU directives, strategies and action plans

Project ID N°: 101036449 Call: H2020-LC-GD-2020-3 box Topic: LC-GD-8-1-2020 - Innovative, systemic zero-pollution solutions to protect health, environment, and natural resources from persistent and mobile chemicals Preventing Recalcitrant Organic Mobile Industrial chemicalS for Circular Economy in the soil-sediment-water System Start date of the project: 1st November 2021 Duration: 42 months Main authors: Julia Hartmann (RIVM), Petra A.M. Hogervorst (RIVM), Peter Behnisch (BDS), Amélie Cavelan (BRGM), Julie Lions (BRGM), Carme Bosch (EURECAT), Adriana E. Sardi (INERIS), Pierre Boucard (INERIS), Sandrine Andres (INERIS), Valeria Dulio (INERIS), Veronika Zhiteneva (KWB), Steffen Kittlaus (TU WIEN), Matthias Zessner (TU WIEN), Millaray Sierra Olea (DECHEMA), Kaitlyn Carter (DECHEMA) Lead Beneficiary: RIVM Type of delivery: R Dissemination Level: PU Filename and version: PROMISCES_D5.8_Policy Recommendation (Version 1) Website: www.promisces.eu Due date: February 28th, 2025 D5.8 - Modular recommendations for evaluation and implementation of relevant EU directives, strategies and action plans D5.8 – Policy Recommendations 2 © European Union, 2025 No third-party textual or artistic material included on the publication without the copyright holder’s prior consent to further dissemination by other third parties. Reproduction is authorized provided the source is acknowledged Disclaimer The information and views set out in this report are those of the author(s) and do not necessarily reflect the official opinion of the European Union. Neither the European Union institutions and bodies nor any person acting on their behalf may be held responsible for the use which may be made of the information contained therein. D5.8 – Policy Recommendations 3 Document History This document has been through the following revisions: Version Date Author/Reviewer Description 0.1 Working document 0.2 30-1-2025 All authors First full draft shared with authors, discussed during writing team meeting on Feb 4 th 0.3 5-2-2025 Review by PROMISCES consortium, specifically: - Jochen Kuckelkorn (UBA) - Anita Sosnowska (QSARLab) - Floris Naus (RIVM) - Anne Togola (BRGM) - Ulf Miehe (KWB) Updated draft shared with PROMISCES consortium (main and secondary contacts, and, if not overlapping, CSL, WPL, WP5 members) 0.3 11-02-2025 RIVM review by Susanne Wuijts, Leo Posthuma and Louise van Mourik (only recom #7) Updated draft shared within RIVM 0.4 24-02-2025 All authors Merged changes in both versions 0.3 and revised document accordingly 0.5 04-03-2025 Julia Hartmann Removed all resolved comments, accepted changes, updated Tables 1, 4 and Executive Summary. Revised text according to some last comments. Version shared with EAB + Theo Traas (RIVM) 0.6 12-3-2025 Reviewed by: - Johan De Fraye (EAB) - Marco Falconi (EAB) - Philippe Quevauviller (EAB) - Dan Lapworth (EAB) - Theo Traas (department head RIVM) Merged revisions by EAB members + Theo Traas (RIVM), in TC 0.7 12-3-2025 Revised by RIVM, DECHEMA, TU WIEN, BDS Revised according to EAB + RIVM review of version 0.6. Revisions in TC. 0.8 14-3-2025 Julia Hartmann 14/3: Accepted all changes, removed resolved comments. One comment left regarding link to DSF. Put reference list in D5.8 – Policy Recommendations 4 the right font and added missing ref manually (to D3.6). Checked recommendations in Table ES, 1 and 4. 15/3: JH added a future research need to recom #7 and Chapter 5. Also, rephrased the text about relevant calls for funding. 18/3: JH removed reference to WHO evaluation in recom #7. 19/3: added temporary link for DSF 20/3: revised and validated by Valeria Dulio 0.9 20-3-2025 Julia Hartmann Accepted all changes in v0.8, removed comments. Version for quality control Authorisation Distribution This document has been distributed to: Authorisation Name Status Date Review J. De Fraye P. Quevauviller M. Falconi D.J. Lapworth EAB members March 8-11th 2025 Validation Valeria Dulio WP5 lead March 20th 2025 Quality Control Floriane Sermondadaz Admin. Manager March 21st 2025 Approval J. Lions Project coordinator March 21st 2025 Name Title Version issued Date of issue All partners Consortium Version 1 March 24st 2025 D5.8 – Policy Recommendations 5 Executive Summary Persistent, mobile, and potentially toxic (PM(T)) substances, such as many perand polyfluoroalkyl substances (PFAS), are substances that are not or hardly degraded in the environment, prone to spread across water, soil, and sediment systems, and that may negatively impact human and environmental health. The importance of regulating these substances has first been acknowledged in the amended Classification, Labelling and Packaging (CLP) Regulation (EC) 1272/2008 that came into force on April 20th 2023 and includes PMT and vPvM (very Persistent and very Mobile) as new hazard categories. Furthermore, addressing these substances is a critical component of the European Union’s (EU) sustainability agenda, including the Green Deal, Circular Economy Action Plan (CEAP), Zero Pollution Action Plan (ZPAP), Chemicals Strategy for Sustainability (CSS) and the EU Soil Strategy. However, the current regulatory landscape for PM(T) substances is fragmented and complex, with different environmental compartments – soil, sediment, water, sludge – regulated under separate policies. Given the environmental persistence and mobility of PM(T) substances, no single stakeholder or regulation can address the problem alone: a coordinated, multi-stakeholder approach is essential for achieving effective and sustainable solutions. Examples of current regulatory misalignment are differing or even completely missing threshold values for PM(T) substances across regulations and matrices. Policy updates, improvements of and additions to current regulations are urgently needed to ensure harmonized management of PM(T)s across the soil-sediment-water system and to achieve the EU’s circular economy and zero pollution ambitions. The PROMISCES project aims to develop innovative, systemic solutions to protect health, environment, and natural resources from PM(T) substances by addressing regulatory gaps and promoting circular economy principles. This deliverable, D5.8 – Modular recommendations for evaluation and implementation of relevant EU directives, strategies and action plans, in particular seeks to: • Identify inconsistencies, gaps, and challenges within the existing EU legal and policy framework related to PM(T) substances. • Promote harmonized regulatory approaches across environmental compartments. • Provide EU and national policymakers with actionable, evidence-based policy recommendations to improve the management of PMT(s) in the soil-sediment-water system (and beyond). • Emphasize that updated policy approaches address disparities and technical, financial and social challenges across Member States (MS). To ensure a structured and actionable approach, PROMISCES formulated nine key recommendations for EU and MS policymakers that are: Aligned with five key EU policy frameworks to enhance regulatory coherence, namely 1. Circular Economy Action Plan (CEAP) 2. Zero Pollution Action Plan (ZPAP) 3. EU Chemicals Strategy for Sustainability (CSS). This includes the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation ((EC) No 1907/2006), Industrial and Livestock Rearing Emissions Directive ((EU) 2024/1785) and the Safe and Sustainable by Design (SSbD) framework ((EU) 2022/2510). 4. EU Soil Strategy (EU Soil) 5. EU Water Directives and Regulations (EU WFD). This includes the Water Framework Directive (2000/60/EC) and its daughter directives (the Groundwater Directive (2006/118/EC) and the Priority Substances Directive (2013/39)), as well as related policies, such as the Drinking Water Directive ((EU) 2020/2184), Water Reuse Regulation ((EU) 2020/741), Urban Wastewater D5.8 – Policy Recommendations 6 Treatment Directive ((EU) 2024/3019), Sewage Sludge Directive (86/278/EEC) and the Environmental Quality Standards (EQS) Directive (2013/39/EU). Classified as either overarching or specific recommendations, where 1. Overarching recommendations evaluate the alignment and coherence of the various EU policy frameworks and propose suggestions for harmonization. 2. Specific recommendations address the process of implementation of existing policy by providing information that is relevant for risk managers, water operators, etc. Mapped to four policy fields to help policymakers identify priority areas for action. These policy fields are 1. Regulating Substances. 2. Circular Resource Management. 3. Technology Performance and Pollution. 4. Tools and Data Management. Overview of PROMISCES policy recommendations, their classification type, their alignment with the 5 EU policy, legal and regulatory frameworks and the level at which they should be enacted – EU/MS (combination of Table 1 and Table 4 from this report). # PROMISCES Policy Recommendation Type of Recommendation Relevant Policy Framework Implementation CEAP ZPAP CSS EU Soil EU WFD EU MS Regulating Substances 1 Member States Competent Authorities (MSCAs) should prioritize setting emission limit values as low as reasonably achievable for substances that are (potentially) PMT or vPvM and difficult to remove from soil, sewage sludge, sediment and water. Specific x 2 The European Chemicals Agency (ECHA) and MSCAs should request users and producers of potentially persistent, mobile, and/or toxic intermediates to provide sufficient comprehensive data on their physicochemical properties and toxicity to ensure these substances are properly assessed and regulated under the PMT/vPvM classification framework established by the CLP Regulation. Specific x x Circular Resource Management 3 The EC should align the list of regulated persistent, mobile, and/or toxic compounds between soil, sewage sludge, sediment and water to increase the safe circular use of these resources. Overarching x 4 To ensure the circularity of resources, the EC should coordinate the processes for selecting substances for the Surface Water Watch List and the Groundwater Watch List with Regulation (EC) No 2024/2865 on Classification, Labelling, and Packaging of Substances and Mixtures (CLP) and initiate a watch list for wastewater, soil, and sewage sludge. Overarching x D5.8 – Policy Recommendations 7 # PROMISCES Policy Recommendation Type of Recommendation Relevant Policy Framework Implementation CEAP ZPAP CSS EU Soil EU WFD EU MS 5 The EC should require emission modelling of PM(T) and vPvM substances into surface waters on the catchment scale, and modelling of transport via surface water into groundwater, to identify knowledge gaps regarding emission sources and pathways, enable risk assessment on entire river basins, and facilitate scenario evaluation. Overarching X Technology Performance and Pollution 6 The EC should establish evaluation criteria for technology providers to evaluate treatment technologies for soil, water, sediment and sludge, and require technology providers to report these criteria. Overarching x X 7 To achieve the Green Deal’s ambition for a toxic-free environment, the EC should consider non-animal based methods, such as PFAS CALUX, as an information source for risk assessment and management of PFAS. Overarching x Tools and Data Management 8 The EC should make PROMISCES tools and information from the PROMISCES Decision Support Framework (DSF) available to industry for the effective implementation of the Safe and Sustainable by Design (SSbD) framework in addition to the SSbD Toolbox. Specific x 9 The European Parliament should support the approval and implementation of proposal COM/2023/779 and ensure interoperability with existing substances data infrastructures developed by the scientific community. Specific x Beyond these nine recommendations, PROMISCES highlights key challenges that impact the effectiveness of PM(T) management across the EU. These include: • Disparities among MS in monitoring, analytics, watch lists and risk assessment, leading to gaps in data availability and regulatory implementation. We highlight suggestions and best practices, or “leapfrog recommendations”, to address these disparities. • Boundary conditions that shape the feasibility, implementation, and sustainability of management practices. These conditions include financial considerations, such as the costs of advanced treatment technologies and analytical testing; knowledge sharing aspects, such as mechanisms for sharing data and best practices across MS; and social dimensions, such as public awareness and perception of risks associated with these substances and acceptance of solutions. D5.8 – Policy Recommendations 8 Table of content 1 Introduction ................................................................................................................................... 12 1.1 PM(T) substances in soil-sediment-water system ................................................................. 12 1.2 Working towards EU sustainability ambitions in the face of PM(T)s .................................... 12 1.3 Complex regulatory context of the soil-sediment-water system .......................................... 13 2 Definitions and process for determining policy recommendations .............................................. 16 2.1 Objective of this deliverable .................................................................................................. 16 2.2 Identifying PROMISCES policy recommendations ................................................................. 16 2.2.1 Data collection .......................................................................................................... 16 2.2.2 Selection and prioritization ....................................................................................... 17 2.3 Structure of this deliverable .................................................................................................. 18 3 PROMISCES policy recommendations ........................................................................................... 20 3.1 Policy field: Regulating substances ....................................................................................... 22 3.1.1 Recommendation No. 1 ............................................................................................ 22 3.1.2 Recommendation No. 2 ............................................................................................ 24 3.2 Policy field: Circular resource management ......................................................................... 25 3.2.1 Recommendation No. 3 ............................................................................................ 25 3.2.2 Recommendation No. 4 ............................................................................................ 27 3.2.3 Recommendation No. 5 ............................................................................................ 29 3.3 Policy field: Technology performance and pollution control ................................................ 31 3.3.1 Recommendation No. 6 ............................................................................................ 31 3.3.2 Recommendation No. 7 ............................................................................................ 34 3.4 Policy field: Tools and data management ............................................................................. 35 3.4.1 Recommendation No. 8 ............................................................................................ 35 3.4.2 Recommendation No. 9 ............................................................................................ 37 3.5 Endorsement of ongoing policy activities ............................................................................. 38 3.5.1 Supporting regulatory and policy efforts at the EU level............................................ 38 3.5.2 Endorsing policy briefs on PM(T) management ......................................................... 38 4 Broader challenges and considerations for managing PM(T)s ...................................................... 41 4.1 Addressing member state disparities .................................................................................... 41 4.2 Boundary conditions for effective management .................................................................. 44 5 Outlook .......................................................................................................................................... 46 6 References ..................................................................................................................................... 49 D5.8 – Policy Recommendations 9 List of Figures Figure 1. The EU Green Deal includes various action plans and initiatives, such as the CEAP (European Commission, 2020a), ZPAP (European Commission, 2021b), CSS (European Commission, 2020b) and the EU Soil Strategy (European Commission, 2021a). Common to all these action plans is the need for pollution-free water resources. ............................................................................................................. 13 Figure 2. EU directives and regulations that manage PFAS in the water cycle. The textboxes explain the differences and inconsistencies in regulation approaches (in orange text). ......................................... 14 Figure 3. Within the context of the soil-sediment-water system and the EU’s goals of achieving circular economy and zero pollution, there is a broad set of fragmented, matrix-specific approaches that together form the regulatory context that should be considered – not only those that directly regulate water, but also those that regulate other relevant matrices (e.g. REACH, Sewage Sludge Directive, Plant Protection Products (EC 1107/2009) and Biocidal Products Regulation ((EU) 528/2012), Persistent Organic Pollutants (POPs) Regulation ((EU) 2019/1021), Waste Framework Directive (2008/98/EC), Landfill Directive (1999/31/EC), Classification, Labelling, and Packing (CLP) Regulation ((EC) No 2024/2865) and the Soil Monitoring Law (COM/2023/416 final). ........................................................ 15 Figure 4. Overview of PFAS drinking water limits across the EU and the EEA. Based on Malarkey and De Kervenoael (2024). ................................................................................................................................ 41 List of Tables Table 1. Overview of PROMISCES policy recommendations, their classification type , and their alignment with the 5 EU policy, legal and regulatory frameworks. CEAP = Circular Economy Action Plan, ZEAP = Zero Pollution Action Plan, CSS = EU Chemicals Strategy for Sustainability, EU Soil = Soil Strategy and EU WFD = EU Water Directives and Regulations………………………………………………………………………….20 Table 2. Treatment technologies assessed in PROMISCES, for which information on remediation yields for various PFAS or iPM(T)s is available in the upcoming CEN Workshop Agreement on “Soil-sedimentwater system - Solutions to deal with PMT/vPvM substances”, along with the media in which each technology was tested. .......................................................................................................................... 23 Table 3. Overview of European PFAS regulations in groundwater, surface water, drinking water, wastewater, sludge, soil, and sediment. ................................................................................................ 25 Table 4. Levels at which the PROMISCES policy recommendations should be enacted. ...................... 46 D5.8 – Policy Recommendations 16 2 Definitions and process for determining policy recommendations 2.1 Objective of this deliverable This report aims to provide policymakers at both the European and national levels with actionable policy recommendations to improve the management of PM(T)s in the soil-water-sediment system. The policy recommendations seek to help policymakers transition from fragmented, matrix-specific approaches towards a more integrated and coordinated effort that better protects human health and the environment when possible, and restores it where needed. A central objective is therefore to identify and address the inconsistencies, gaps, and uncertainties within the existing EU legal and policy framework. To achieve this, we align each of the PROMISCES policy recommendations with the complex web of EU strategies and regulations outlined in Chapter 1, including: 1. Circular Economy Action Plan (CEAP) 2. Zero Pollution Action Plan (ZPAP) 3. EU Chemicals Strategy for Sustainability (CSS). This includes the REACH regulation, IED2.0 and the Safe and Sustainable by Design (SSbD) framework 4. EU Soil Strategy (EU Soil) 5. EU Water Directives and Regulations (EU WFD). This includes the Water Framework Directive and its daughter directives (the Groundwater Directive (2006/118/EC) and the Priority Substances Directive (2013/39)), as well as related policies, such as the Drinking Water Directive ((EU) 2020/2184), the Water Reuse Regulation ((EU) 2020/741), UWWTD, Sewage Sludge Directive, Environmental Quality Standards (EQS) Directive (2013/39/EU). This alignment to the broader EU strategies and regulations highlights the interdisciplinary nature of the challenge posed by PM(T)s and the need for harmonized approaches to ensure effective management. Additionally, by linking each recommendation to one or more of these policy frameworks, this report highlights the direct relevance of the PROMISCES policy recommendations for advancing the EU’s sustainability goals. In this report, we provide policy recommendations that can be classified in the following two categories: • Overarching: These recommendations evaluate the alignment and coherence of the various EU policy frameworks and propose suggestions for harmonization. • Specific: These recommendations address the consistent process of implementation of existing policy by providing information that is relevant for risk managers, water operators, etc. 2.2 Identifying PROMISCES policy recommendations 2.2.1 Data collection The policy recommendations presented in this deliverable are the result of a triangulation of activities used within the PROMISCES project for data collection. These activities ensure that the recommendations were evidence-based, stakeholder-informed and aligned with the broader EU policy context. The following paragraphs provide an overview of the activities that were conducted and considered. D5.8 – Policy Recommendations 17 Expert World Café Brainstorming Session This activity was based on the Decision Support Framework developed by the PROMISCES consortium, which offers decision-makers solutions for managing PM(T)s via five modules: 1. PMT Assessment: to verify if a substance is persistent, mobile, and/or toxic according to multiple data sources. 2. Search Substances: to explore PM(T) chemicals across various chemical classes and sectors of use. 3. Diagnosis: to get a personalized diagnosis for a PM(T) case to support solution assessment. 4. Solution Assessment: to find solutions for prevention, assessment, monitoring and treatment of PM(T) substances. 5. Strategy Creation: to reference guidance and examples for developing strategies for PMT substances across sectors. Using the world café format, where groups rotate among topics for focused discussions, PROMISCES examined the four solution types (prevention, risk assessment, monitoring and treatment) to identify pathways to improve the effectiveness of existing regulations and address implementation challenges. Identifying Boundary Conditions through Local Stakeholder Workshops Using co-creation processes, PROMISCES organised local stakeholder workshops in conjunction with three project case studies: Case Studies (CS) CS#2, CS#3 and CS#41. The outcomes from these workshops, explained in detail in PROMISCES Deliverables D5.4 and D5.6 (Narain-Ford et al., 2025; Naus et al., 2025), provided insights into barriers and solutions for managing PM(T)s. The stakeholder input informed several policy recommendations and highlighted context-specific challenges and perspectives. Gathering External Input via the WaterProjectsEurope 2024 Event In collaboration with two other EU-funded projects, SCENARIOS and LIFE SOuRCE, PROMISCES organised the WaterProjectsEurope event with Water Europe in December 2024. Using an interactive audience survey, we gathered general perspectives on challenges and needs in various Member States (MS) related to PFAS and PMTs. This external input complemented the internal findings and provided important clarifications on the science-policy interface. PROMISCES’ Policy Work The PROMISCES project contributed to and produced two earlier policy briefs: 1) “Achieving zero pollution by 2050 needs regulatory change: a call for policy support of New Approach Methodologies (NAMs)” (Paparella et al., 2024) and 2) “Deliverable D5.3 - Policy brief on PM(T) concerns and actions in EU” (Wuijts et al., 2024). To ensure compatibility, the recommendations in this deliverable do not overlap with those of the earlier briefs, but instead target additional gaps and challenges identified during the project. As the recommendations from these two policy briefs are also relevant for achieving zero pollution and a circular economy, they are provided in Chapter 3.5 “Endorsement of ongoing policy activities”. 2.2.2 Selection and prioritization Using the input from the various activities explained in the previous section, PROMISCES identified a set of policy recommendations that are both overarching and specific (see definitions in Section 2.1). Additionally, future research needs and “leapfrog recommendations” were identified. The leapfrog 1 For information on the PROMISCES case studies, visit https://promisces.eu/Project/Case+Studies.html D5.8 – Policy Recommendations 18 recommendations address disparities between MS in their management of PM(T)s, providing best practice suggestions to bridge these gaps (see Section 4.1). To prioritize between the collected recommendations, we established three key criteria that each recommendation should fulfil: 1. Supported by PROMISCES results. Each recommendation is supported by findings from the PROMISCES project. While there are numerous policy gaps in the realm of PM(T)s, circular economy and water resource management, this deliverable includes only those policy recommendations that can be explained and justified using PROMISCES research results. In some cases, PROMISCES results not only support a policy recommendation but also reveal future research needs for the effective implementation of that policy recommendation. In those cases, we also include these future research needs in a textbox next to the recommendation. These research needs could be further explored in future funding calls, stakeholder dialogues, or policy update processes. 2. Scientifically significant and/or innovative. The recommendations aim to contribute to ongoing discussions surrounding PM(T)s and PFAS by offering new ideas or methods. Widely supported policy suggestions (e.g. PFAS bans) and the recommendations from the two previously published policy briefs are briefly acknowledged in Section 3.5, while this deliverable focuses on those that introduce novel approaches. 3. Relevant to EU policy frameworks. Each recommendation is directly relevant for one or more existing EU strategies, regulations and/or directives, highlighting opportunities to improve the alignment or implementation of existing policies. 2.3 Structure of this deliverable This deliverable is structured to provide a clear and accessible overview of the PROMISCES policy recommendations, ensuring policymakers can easily navigate and consider their impacts within the broader EU regulatory framework. To help policymakers easily identify relevant areas of needed policy action, we have grouped the PROMISCES policy recommendations into four main policy fields: 1. Regulating Substances (Section 3.1): Focuses on policies governing the use, restriction, and monitoring of PM(T) substances to ensure environmental and human health protection. 2. Circular Resource Management (Section 3.2): Addresses regulatory measures that support resource efficiency, wastewater reuse, and sustainable processes. 3. Technology Performance and Pollution (Section 3.3): Covers policies related to the effectiveness of treatment technologies, pollution control strategies, and performance standards for mitigation of environmental impacts. 4. Tools and Data Management (Section 3.4): Encompasses frameworks for data collection, monitoring, and decision support tools that enhance policy implementation. This classification ensures that related recommendations are organized according to their overarching objectives and their role in addressing regulatory gaps. Each policy field reflects a distinct aspect of governance relevant to the soil-sediment-water system. Additionally, to visually demonstrate the alignment of each policy recommendation with broader EU strategies and regulations, the five European policy frameworks listed in Chapter 2.1 are color-coded. An overview of the alignment of each recommendation with these policy frameworks is provided in Table 1, and coloured tabs on the right-hand side of each recommendation remind the reader of this alignment. By structuring the D5.8 – Policy Recommendations 19 deliverable in this way, PROMISCES ensures that its recommendations are both actionable and directly relevant to the evolving EU regulatory and policy landscape. 1. Circular Economy Action Plan (CEAP) 2. Zero Pollution Action Plan (ZPAP) 3. EU Chemicals Strategy for Sustainability (CSS) 4. EU Soil Strategy (EU Soil) 5. EU Water Directives and Regulations (EU WFD) Additionally, future research needs are highlighted in blue boxes at the end of some of the policy recommendations, where relevant, to identify gaps requiring further research for effective policymaking. As mentioned in Section 2.2.2, widely supported policy suggestions (e.g. PFAS bans) and the recommendations from the two previously published policy briefs )” (Paparella et al. (2024) and (Wuijts et al. (2024)) are briefly acknowledged in Section 3.5 Finally, a dedicated section on broader challenges and key considerations for managing PM(T) substances explores critical aspects that influence the effectiveness of policy implementation across the EU. Specifically, it addresses (i) disparities among MS and their challenges and needs when discussing for instance monitoring strategies, analytical challenges, development of watch lists, and risk assessment as well as their implications for implementing regulations (Section 4.1); and (ii) the boundary conditions necessary for effective PM(T) management, including financial considerations, knowledge sharing aspects and social dimensions (Section 4.2). By outlining these broader challenges, the report provides essential context for understanding the feasibility and impact of the proposed recommendations, ensuring that policy development accounts for both systemic and regional constraints. D5.8 – Policy Recommendations 20 3 PROMISCES policy recommendations Table 1. Overview of PROMISCES policy recommendations, their classification type , and their alignment with the 5 EU policy, legal and regulatory frameworks. CEAP = Circular Economy Action Plan, ZEAP = Zero Pollution Action Plan, CSS = EU Chemicals Strategy for Sustainability, EU Soil = Soil Strategy and EU WFD = EU Water Directives and Regulations. # PROMISCES Policy Recommendation Type of Recommendation Relevant Policy Framework Page Ref. CEAP ZPAP CSS EU Soil EU WFD Regulating Substances 1 For substances that are (potentially) PMT or vPvM and difficult to remove from soil, sewage sludge, sediment, and water, Member States Competent Authorities (MSCAs) should prioritize setting emission limit values as low as reasonably achievable. Specific 22 2 The European Chemicals Agency (ECHA) and MSCAs should request users and producers of potentially persistent, mobile, and/or toxic intermediates to provide sufficient comprehensive data on their physicochemical properties and toxicity to ensure these substances are properly assessed and regulated under the PMT/vPvM classification framework established by the CLP Regulation. Specific 24 Circular Resource Management 3 The EC should align the list of regulated persistent, mobile, and/or toxic compounds between soil, sewage sludge, sediment and water to increase the safe circular use of these resources. Overarching 25 4 To ensure the circularity of resources, the EC should coordinate the processes for selecting substances for the Surface Water Watch List and the Groundwater Watch List with Regulation (EC) No 2024/2865 on Classification, Labelling, and Packaging of Substances and Mixtures (CLP) and initiate a watch list for wastewater, soil, and sewage sludge. Overarching 27 5 The EC should require emission modelling of PM(T) and vPvM substances into surface waters on the catchment scale, and modelling of transport via surface water into groundwater, to identify knowledge gaps regarding emission sources and pathways, enable risk assessment on entire river basins, and facilitate scenario evaluation. Overarching 29 Technology Performance and Pollution Control 6 The EC should establish evaluation criteria for technology providers to evaluate treatment technologies for soil, water, sediment and sludge, and require technology providers to report these criteria. Overarching 31 D5.8 – Policy Recommendations 21 # PROMISCES Policy Recommendation Type of Recommendation Relevant Policy Framework Page Ref. CEAP ZPAP CSS EU Soil EU WFD 7 To achieve the Green Deal’s ambition for a toxic-free environment, the EC should consider non-animal based methods, such as PFAS CALUX, as an information source for risk assessment and management of PFAS. Overarching 34 Tools and Data Management 8 The EC should make PROMISCES tools and information from the PROMISCES Decision Support Framework (DSF) available to industry for the effective implementation of the Safe and Sustainable by Design (SSbD) framework in addition to the SSbD Toolbox. Specific 35 9 The European Parliament should support the approval and implementation of proposal COM/2023/779 and ensure interoperability with existing substances data infrastructures developed by the scientific community. Specific 37 D5.8 – Policy Recommendations 22 3.1 Policy field: Regulating substances 3.1.1 Recommendation No. 1 For substances that are (potentially) PMT or vPvM and difficult to remove from soil, sewage sludge, sediment, and water, Member States Competent Authorities (MSCAs) should prioritize setting emission limit values as low as reasonably achievable. Relevant Policy Context: CLP, IED 2.0, WFD Article 56 of the IED 2.0 states: When setting emission limit values for polluting substances, the competent authority should consider all substances, including substances of emerging concern, which may be emitted from the concerned installation and may have a significant impact on the environment or human health. In doing so, the hazard characteristics, quantity and nature of the substances emitted and their potential to pollute any environmental media should be considered. The best available technologies (BAT) conclusions, where relevant, are the reference point for selecting the substances for which emission limit values are to be set, although the competent authority may decide to select additional substances. […] reference should be made to the list of pollutants in Annex II to Regulation (EC) No 166/2006 of the European Parliament and of the Council. To protect the quality and foster the circular use of soil, sewage sludge, sediment, wastewater, surface water and groundwater, MSCAs should prevent the emission of, or – if emission cannot be prevented – prioritize setting emission limit values as low as reasonably achievable (ALARA) for substances that are: 1. PMT or vPvM according to Regulation (EC) No 2024/2865 on Classification, Labelling, and Packaging of Substances and Mixtures (CLP); or 2. Potentially PMT or vPvM based on model predictions; and 3. Difficult to remove from soil, sewage sludge, sediment and water. Please consult Hansson (2013) for details on the ALARA concept. When identifying and prioritizing substances using these criteria, MSCAs can use the results from the PROMISCES project. For criteria 1 and 2, MSCAs can consult the PMT assessment module of the Decision Support Framework (DSF). If data to complete the PMT assessment is missing and the substance of interest is an on-site isolated intermediate, please also consult Recommendation No. 2. There are two major sources of information from the PROMISCES project that provide details on remediation yields for different PFAS and industrial PM(T)s (iPM(T)s) from the assessed treatment technologies: 1) the solution module of the PROMISCES DSF and 2) the upcoming CEN Workshop Agreement on “Soil-sediment-water system - Solutions to deal with PMT/vPvM substances”2. The information from these two sources can be used for assessing substances according to criterion 3. Based on two types of criteria, compounds of concern can be defined in general as compounds with limited (here: <50%) removal by several treatment technologies (here: >1). Based on PROMISCES results, such a list would, at the time of writing, encompass, but is not limited to compounds such as diuron (biocide, antifouling agent, CAS: 330-54-1), benzotriazole (anti-corrosion agent and an anti2 The CEN Workshop Agreement (CWA) on „Soil-sediment-water system - Solutions to deal with PMT/vPvM substances“ is expected to be published online in April 2025 at https://www.cencenelec.eu/news-andevents/news/2023/workshop/2023-12-13-promisces/. D5.8 – Policy Recommendations 23 fogging agent, CAS: 95-14-7), triethyl phosphate (industrial catalyst, plasticizer, flame retardant, CAS: 78-40-0) and temazepam (pharmaceutical, CAS: 846-50-4). Limiting the emission of these substances is thus deemed important. This list is not comprehensive, and concerns compounds frequently studied, a complete list would encompass compounds with similar fate behaviour and characteristics. Table 2. Treatment technologies assessed in PROMISCES, for which information on remediation yields for various PFAS or PM(T)s is available in the upcoming CEN Workshop Agreement on “Soilsediment-water system - Solutions to deal with PMT/vPvM substances”3, along with the media in which each technology was tested. Technology Target media In situ non-newtonian fluid flushing Soil, water Sediment washing Sediment Membrane filtration (nanofiltration, reverse osmosis) Landfill leachate Plasma Landfill leachate, water, sludge Co-pyrolysis of membrane concentrates and sewage sludge Landfill leachate sludge and concentrate, sewage sludge Ultrasonic cavitation Water Activated persulfate with ferrate Water E-peroxone based electrochemical advanced oxidation process (EAOP) Water 3 The CEN Workshop Agreement (CWA) on „Soil-sediment-water system - Solutions to deal with PMT/vPvM substances“ is expected to be published online in April 2025 at https://www.cencenelec.eu/news-andevents/news/2023/workshop/2023-12-13-promisces/. D5.8 – Policy Recommendations 24 3.1.2 Recommendation No. 2 The European Chemicals Agency (ECHA) and MSCAs should request users and producers of potentially persistent, mobile, and/or toxic intermediates to provide sufficient comprehensive data on their physicochemical properties and toxicity to ensure these substances are properly assessed and regulated under the PMT/vPvM classification framework established by the CLP Regulation. Relevant Policy Context: REACH, CLP The Regulation (EC) No 1907/2006 on REACH defines an intermediate as a ‘substance that is manufactured for and consumed in or used for chemical processing in order to be transformed into another substance (hereinafter referred to as synthesis)’ (Article 3(15)). Different types of intermediates – such as non-isolated, on-site isolated and transported isolated intermediates – are subject to varying requirements under REACH. For further details, see the “Guidance on Intermediates“ (European Chemicals Agency, 2023). The PROMISCES project found that over 90 percent of the REACH registered intermediates studied in the project (n=3298) are potentially (very) persistent and (very) mobile, as determined through modelled data (Sardi, 2025). Despite this, at the time of writing, no experimental information on the physico-chemical properties, toxicity and uses of these substances is required by the European Chemicals Agency (ECHA) to fill out their registration dossiers. To protect the soil-sediment-water system, PROMISCES urges ECHA to review the registered isolated intermediates with PMT and PBT potential listed in Sardi (2025) and request sufficient comprehensive data as needed. These substances should be thoroughly assessed and regulated under the forthcoming mandatory PMT/vPvM classification, as required by the CLP Regulation ((EC) No 2024/2865). For the on-site isolated intermediates provided in the aforementioned database, which are manufactured and used under strictly controlled conditions, dossier and substance evaluation requirements do not apply under REACH (Article 49). However, the MSCA responsible for the manufacturing site has the authority to request additional information. We ask the relevant MSCA to exercise this power and assess whether these intermediates qualify as PM(T) or vPvM substances and whether their associated risks are properly controlled according to REACH (Article 49). D5.8 – Policy Recommendations 25 3.2 Policy field: Circular resource management 3.2.1 Recommendation No. 3 The EC should align the list of regulated persistent, mobile, and/or toxic compounds between soil, sewage sludge, sediment and water to increase the safe circular use of these resources. Relevant Policy Context: DWD, WFD and its daughter directives, UWWTD, Sewage Sludge Directive (SSD), Proposal COM/2023/416, Proposal COM/2022(540), Environmental Quality Standards (EQS) Directive (2013/39/EU) In Europe, the regulation of PM(T) substances in groundwater, surface water, drinking water, wastewater, sludge, and soil is incoherent and inconsistent. This incoherence and inconsistency appear both in the set of regulated parameters and in the determined threshold values is illustrated with PFAS as an example for PM(T) substances in Table 3. Immediate action is required to harmonize regulations across environmental compartments to prevent further contamination and ensure resource circularity. Table 3. Overview of European PFAS regulations in groundwater, surface water, drinking water, wastewater, sludge, soil, and sediment. Matrix Regulated Parameter(s) Threshold Value(s) Respective Regulation Surface Water, Sediment Sum of 24 PFAS 4.4 ng/L (as PFOA equivalents) Proposal COM/2022(540) Amendment of Directive 2000/60/EC on water policy, Directive 2006/118/EC on pollution of groundwater and Directive 2008/105/EC on quality standards in water policy Drinking Water Sum of 20 PFASA 100 ng/L Drinking Water Directive (EU) 2020/2184 Total PFAS 500 ng/L Surface Water Perfluorooctane sulfonic acid and its derivatives (PFOS) Annual Average of 0.65 ng/L for inland surface water and 0.13 ng/L for other surface water Directive (EU) 2013/39 as regards priority substances in the field of water policy Groundwater Sum of 20 PFASB 100 ng/L COM(2022) 540 final Sum of 4 PFAS 4.4 ng/L Urban Wastewater Sum of 20 PFASA NAC Directive (EU) 2024/3019 EU concerning urban wastewater treatment (UWWTD) Total PFAS NAC Soil PFAS not specifically mentioned NA Proposal COM/2023/416 for a Directive on Soil Monitoring and Resilience (Soil Monitoring Law) Sludge/ Biosolids PFAS not specifically mentioned NA Directive 86/278/EEC on the protection of the environment, and in particular of the soil, when sewage sludge is used in agriculture A The 20 included PFAS do not completely overlap with the 24 PFAS included in the COM (2022) 540 for surface water, groundwater and sediment. B The 20 PFAS from the Drinking Water Directive (EU) 2020/2184 C The UWWTD only mentions monitoring of PFAS in inlet and outlet of wastewater treatment plants. In addition to these European limit values, certain MS have included other PFAS and thresholds in their national monitoring programmes, making the regulatory context even more complex. For example, D5.8 – Policy Recommendations 32 ultra-short chain PFAS (2-3 carbon atoms), short chain PFAS (4-6 carbon atoms) or long chain PFAS (> 6-8 carbon atoms).6 • The nature and quantity of matrices to be processed at output: Some techniques result in the production of concentrated matrices (e.g. water, activated carbon, concentrated PFAS/PM(T) waste stream), which must then be treated. • Safety and environmental impact: Ensure that the chosen technology does not aggravate existing environmental problems and is not harmful to human and environmental health, also in the long term. Remediation processes must guarantee the safety of workers and the population. Sub-criteria to consider here are for instance, the release of unwanted byproducts into the environment (e.g. new pollutants such as TFA, suspended particles), and unwanted effects on the physicochemical properties of the environment (e.g. pH, temperature). • Technological maturity: Technology Readiness Level (TRL), including current research gaps to overcome. • Economic cost: Both operational and capital expenditures, including maintenance, waste management, and costs of energy consumption. • Sustainability: Energy demand in kWh/m³ product, carbon footprint in emissions of CO2 equivalents per m³ product, water footprint in m³ H20 required per m³ product generated, regeneration of the media, and waste generation. • Regulatory compliance: Ensure that the technique meets current standards and complies with legal requirements (e.g. material/membrane complies with national drinking water treatment regulations). It is recommended that these evaluation criteria be integrated into the list of criteria already used for evaluating Best Available Techniques (BATs) in the BAT Reference documents (BREFs) under the IED 2.0. To ensure the reliability of the information provided, PROMISCES recommends that technology providers test their technology under real-world conditions for specific contaminants and a range of concentrations in various types of waters/matrices. Evaluating these criteria for PFAS remediation may be more complicated, due to the complexity of PFAS and the associated technical challenges. Aligned with the current procedures as part of IED 2.0, these harmonized evaluation criteria enable comparison of different types of technologies as well as their effects. By streamlining this information, companies, utilities, and regulators can make faster, more informed decisions about the suitability of specific technologies for their use cases. This is especially important as the number of stakeholders addressing PFAS and PMT contamination is expected to grow significantly in the coming years. Similarly, information on the impact of the treatment on the receiving environments tied with the characteristics of the output matrices and the specific features of the generated byproducts should be clearly communicated. This is to inform potential end users on what to expect. It will also help to reduce risk and costs by avoiding unnecessary expenditure on ineffective solutions. Future research needs: To realize the effective implementation of this policy recommendation, PROMISCES identified a specific need for further research on developing a methodology to evaluate the PFAS mass balance during treatment correctly. PFAS mass balance is based on the idea that in a closed system, the total quantity of a substance entering the system (the contaminated matrix) should 6 A need for further research on the development of a methodology to correctly evaluate the PFAS mass balance during treatment was identified in the PROMISCES project. To assess technologies based on these criteria, a validation test protocol needs to be followed. D5.8 – Policy Recommendations 33 be equal to the quantity leaving it (removed or mineralized), plus the quantity which is accumulated or not degraded in the matrix during treatment. For PFAS, this approach is crucial, as these substances are persistent and may not be completely degraded or removed. It enables the quantification of the elimination and losses of PFAS in a specific environment, such as a contaminated site or a treatment process. The aim is to ensure no substance is overlooked in the overall mass balance. Establishing a methodology to assess the PFAS mass balance could involve a revisable list of specific parameters or compounds to be monitored, along with recommendations on the quantification limits per parameter/compound. D5.8 – Policy Recommendations 34 3.3.2 Recommendation No. 7 To achieve the Green Deal’s ambition for a toxic-free environment, the EC should consider nonanimal based methods, such as PFAS CALUX, as an information source for risk assessment and management of PFAS. Relevant Policy Context: DWD, WFD PFAS is a large group of man-made chemical substances that do not occur naturally in the environment. These substances are associated with adverse health effects, such as liver damage, reduced birth weight and a decreased immune response in epidemiological studies. The effect on the immune system was observed at the lowest levels of exposure to PFAS (EFSA, 2020). The Organisation for Economic Cooperation and Development (OECD) has identified more than 4,000 PFAS, but there may even be more. Only a limited number of PFAS are well-studied. This presents a challenge for risk assessment and for aligning with the EU Green Deal’s goal of achieving a toxic-free environment. In this regard, bioassays, present a relevant source of information. In PROMISCES, various modes of action of PFAS were examined using cell-based bioassays, supplemented by in silico modelling, to include a broad range of PFAS (Behnisch et al., 2023). The results demonstrate that PFAS trigger endocrine mechanisms of action, particularly receptor binding and inhibition. These effects were primarily observed in the competition of up to 8000 PFAS with the thyroid transport hormone protein transthyretin. A potential way of using this knowledge to help with the EU Green Deal’s goal of achieving a toxic-free environment, is via trigger values derived using non-animal-based in vitro bioassays (such as PFAS CALUX). A study by Behnisch et al. (2021) published trigger values for water, which have been applied in several studies (Behnisch et al., 2023; de Schepper et al., 2023). PROMISCES has also implemented this toxic-free assessment approach using semi-quantitative in vitro toxicity bioanalysis tools in several case studies (e.g., CS#2 Danube River monitoring). If the observed activity measured by PFAS CALUX falls below this trigger value, it suggests that up to 8,000 PFAS are – considering current limits of quantification (LOQ), observed exposure levels and hazard characteristics – not present in the sample above critical levels (on a per-compound basis) for public health and the environment (Kowalska et al., 2023; Sosnowska et al., 2025). Furthermore, the results can be used for grouping of PFAS for the same molecular target and for prioritizing PFAS for further study. Kuckelkorn and Mittag (2024) showed a potential way of using trigger values for setting health-related indicator values for drinking water. Therefore, to achieve the EU Green Deal’s goal of a toxic-free environment, PROMISCES suggests that the EC considers non-animal based methods, such as PFAS CALUX, as information source for risk assessment and management of PFAS. By integrating the comprehensive database from PROMISCES, the EU could establish a more protective and adaptive regulatory approach to PFAS in (drinking) water. Future research needs: To support the implementation of this policy recommendation, a relevant future research direction would be establishing an effect-based trigger value for total PFAS based on a large data set of PFAS CALUX analyses in different kinds of water, such as surface water, drinking water and wastewater. The trigger value should be in bioanalytical equivalent concentrations following the example in Schepper et al. (2023). D5.8 – Policy Recommendations 35 3.4 Policy field: Tools and data management 3.4.1 Recommendation No. 8 The EC should make PROMISCES tools and information from the PROMISCES Decision Support Framework (DSF) available to industry for the effective implementation of the Safe and Sustainable by Design (SSbD) framework in addition to the SSbD Toolbox. Relevant Policy Context: REACH The 'safe and sustainable by design' (SSbD) framework is a pro-active, voluntary approach aimed at integrating safety, sustainability and, although indirectly, circularity into the innovation process for chemicals and materials, announced via the Commission Recommendation (EU) 2022/2510. To assist users in implementing the assessment framework, the JRC published methodological guidance documents, and the European Partnership for the Assessment of Risks from Chemicals (PARC) established an SSbD Toolbox that collects tools and models for each stage of the framework (European Commission: Joint Research Centre, Caldeira, et al., 2022; European Commission: Joint Research Centre et al., 2024; European Partnership for the Assessment of Risks from Chemicals (PARC), n.d.). The EC intends to continuously improve the methods, tools, and data availability for SSbD chemicals and materials, as well as to refine the framework and make it applicable to a wide variety of substances. The PROMISCES project has developed tools and delivered information complementary to the tools in the SSbD Toolbox, which are included in the PROMISCES Decision Support Framework (DSF). Relevant parts of the DSF in this regard are: • The PMT Assessment and Diagnosis modules. These modules can be used as a fit-for-purpose tool to identify (potential) PMT and vPvM substances and their sector of use. This is deemed important as the first step of the SSbD approach is to focus on the intrinsic properties of chemicals and materials and identify those that are inherently hazardous. PMT and vPvM substances are included in the category of the ‘most harmful substances’ (according to the Chemical Strategy for Sustainability) that should be prioritized for substitution, re-designed to reduce their adverse effects, or allowed only in uses proven essential to society. Furthermore, the SSbD framework acknowledges that available information could be limited and recommends using diverse information sources, like New Approach Methodologies (NAMs), to get data and generate knowledge. In the Diagnosis and PMT Assessment modules, different types of information sources are used (such as QSARs, etc.), which allow evaluation of whether the PMT/vPvM endpoint is likely to be fulfilled or not. • The Solution Assessment module and specifically the information related to Prevention. This module offers different measures that can be implemented to prevent the release of PM(T) substances into the environment. It provides information on PM(T) identification, substitution, and additional scientific and technical solutions for preventing contaminants. It also refers to Deliverable D1.5 (Behnisch et al., 2023), which describes a set of novel QSAR, grouping, readacross, and in vitro bioassay approaches for predicting relevant toxicological endpoints for PFAS/PM(T) chemicals, and Deliverable D2.1 (Sosnowska et al., 2024), which reports on publicly available in silico models for the identification of PMT properties of PFAS. To achieve the goals set out in the CSS, the ZPAP and the CEAP, the tools and information provided in the DSF should be made easily accessible to the industry. They are essential for applying the SSbD framework in a more effective and informed manner, helping to identify substances with potential PM(T) characteristics and prevent their use and/or emission into the environment. One way to do this would be to add the PROMISCES DSF link to the list of supporting information provided on the SSbD D5.8 – Policy Recommendations 36 webpage: Safe and sustainable by design - European Commission or directly in the SSbD Toolbox. The DSF will be integrated into the NORMAN Database System (NDS) of the NORMAN Network, ensuring the DSF‘s long-term maintenance and accessibility. Additionally, the mentioned PROMISCES models by Behnisch et al. (2023) and Sosnowska et al. (2024) could be directly added to the tools in the SSbD Toolbox. D5.8 – Policy Recommendations 37 3.4.2 Recommendation No. 9 The European Parliament should support the approval and implementation of proposal COM/2023/779 and ensure interoperability with existing substances data infrastructures developed by the scientific community. Relevant Policy Context: Proposal COM/2023/779, REACH The European Parliament is currently assessing a proposal by the Commission to establish “a common data platform on chemicals, laying down rules to ensure data that are in it, are findable, accessible, interoperable and reusable (FAIR) and to establish a monitoring and outlook framework for chemicals” (COM/2023/779). This common data platform aims to introduce a ‘one-stop shop' to access data on chemicals held by the European agencies and the Commission, compiled under EU legislation. Types of data include data on hazards, physicochemical properties, presence in the environment, emissions, uses, environmental sustainability of chemical substances, and ongoing regulatory processes. Currently, there is no common data platform widely recognized by scientists and policymakers enabling secure collaboration and integration of different types of data from multiple sources and databases. Gathering data from several sources and curating their formatting was a bottleneck during the development of the DSF in the PROMISCES project. The integration of data from different sources was time-consuming and difficult, since, for instance, substances are named differently depending on language, can have multiple identifiers, and there is no common protocol for comparing them. Therefore, PROMISCES strongly supports the approval and implementation of COM/2023/779. During the project, the NDS of the NORMAN Network served as a platform for retrieving data from relevant existing data sources as well as a repository for new data generated by PROMISCES. The NDS provides a comprehensive FAIR infrastructure for chemical substances data, facilitating stakeholders collaboration and data exchange. We recommend that the common data platform aimed for COM/2023/779 should be designed with interoperability as a core principle, ensuring it integrates effectively with existing infrastructures, such as the NDS. This close connection would enable streamlined access to scientific data housed in these platforms, serving as an interim repository for ongoing research and fostering better collaboration between regulatory and scientific communities. The objective is to enable seamless data exchange between the common data platform, primarily intended for substance regulation and other scientific databases continuously updated with the latest research. This approach emphasizes the importance of interoperability, which provides mutual benefits for both regulatory and scientific communities, creating a mutually advantageous framework. Finally, implementation of this recommendation could benefit the realisation of recommendations #3 and #4. D5.8 – Policy Recommendations 38 3.5 Endorsement of ongoing policy activities 3.5.1 Supporting regulatory and policy efforts at the EU level The PROMISCES project endorses all ongoing policy activities aimed at preventing the emission of PM(T) substances to the soil-sediment-water system and improving their removal. Several key EU-level initiatives are particularly relevant to PROMISCES’ objectives, including the proposed PFAS restriction under REACH (ECHA, 2023) and the Common Implementation Strategy (CIS) Work Programme (20252027) for the WFD (van der Hulst, 2024). PROMISCES fully supports the REACH-Annex XV Restriction Report for manufacturing, placing on the market and using PFAS prepared by the national authorities of Germany, the Netherlands, Denmark, Norway, and Sweden (ECHA, 2023). The importance of a PFAS restriction is also underlined by the results of a tiered in silico and in vitro testing strategy for up to 12,000 PFAS compounds applied in PROMISCES. The in silico predictions indicated that more than 7,500 compounds were identified as active, and over 100 PFAS compounds may cause even greater adverse effects than PFOA (Sosnowska et al., 2025). PROMISCES also acknowledges the recently published draft Common Implementation Strategy (CIS) Work Programme, which aims to strengthen the implementation of the WFD and related policies. PROMISCES findings can support several key CIS actions, including: • Revising priority substance and surface water and groundwater watch lists by 2027. This aligns with PROMISCES Recommendations No. 3 and 4, which suggest updates to the existing watch list selection processes as well as the implementation of additional watch lists for wastewater, soil, and sewage sludge. Further, PROMISCES results provide information on specific substances to be considered for the GWWL and SWWL and the proposed additional watch lists (Behnisch et al., 2023; Kowalska et al., 2023; Sosnowska et al., 2025). • Gathering data on hazard/toxicity of substances of potential concern to facilitate the prioritisation of candidate substances for the GWD Annex I and II review process by mid2026. This relates to Recommendations No. 2, 4 and 7, which call for improved data collection on PM(T) substance properties including physico-chemical properties and toxicity. PROMISCES supports integrating toxicological data with regulatory processes to ensure better prioritization of harmful substances. • Sharing experience of monitoring methods for PFAS by mid-2026. This aligns with Recommendations No. 3 and 4, which emphasize harmonized monitoring strategies for PFAS and other PM(T)s across environmental compartments. • Promoting water reuse in agriculture and other sectors/applications, provide support for risk management via guidelines, best practices and experience sharing by mid-2026. This aligns specifically with Recommendation No. 5, which showcases the use of emission modelling for risk management. Further, barriers to implementing water reuse and circular economy were identified in PROMISCES Deliverables 5.4 (Narain-Ford et al., 2025) and 5.6 (Naus et al., 2025) through co-creation stakeholder workshops and are highlighted in Chapter 4. 3.5.2 Endorsing policy briefs on PM(T) management PROMISCES also endorses the recommendations outlined in two PROMISCES policy briefs. The recommendations included in the policy brief published in July 2024 with sister projects from the Green Deal are deemed essential to achieve zero pollution in Europe (Paparella et al., 2024). The recommendations are: D5.8 – Policy Recommendations 39 1. Support using exposure, non-standard data, and chemical grouping for regulatory action. 2. Support the improvement and the validation process of NAMs. 3. Support leveraging uncertainty assessment for NAM recognition. 4. Provide support for the evolution of a NAM based next-generation regulation. 5. Support for the initiative to develop a European roadmap to an animal-free regulatory system. PROMISCES published a second policy brief on PM(T) concerns and actions in Europe (Wuijts et al., 2024), highlighting needed policy actions to achieve zero pollution and circularity: 1. The development of adequate strategies for enabling circular economy routes involving PM(T) substances strongly relies on the availability of accurate data on substance characteristics, tonnage, and type of use. With those data available, it is feasible to prioritize PM(T) compounds regarding hazards and risks on a per-compound and a (preferably) per-use basis and thus provide input to policy makers and other actors for developing adequate risk assessment and prioritization strategies. 2. However, in the current registration procedures under REACH and other regulatory frameworks like the Biocidal Products Regulation (528/2012/EC), and Pesticides Directive (2009/128/EC), the lack of detailed and accurate information on uses, especially downstream uses as well as confidentiality and the registration of substances as intermediates, obscures the identification of sectors of most concern regarding their use of PM(T) substances. 3. To achieve a comprehensive assessment of the impact of PM(T) substances throughout their lifecycle, it is essential to expand quantitative exposure data requirements, such as tonnage bands, beyond the scope of the REACH regulation. This extension should encompass other regulatory domains, including pharmaceuticals, biocides, cosmetics, in accordance to the One Substance-One Assessment (OSOA) approach as recently proposed by the European Commission. 4. Identifying substances with intrinsic PMT/vPvM properties and implementing the related CLP Regulation is essential to protect human health and the environment. Furthermore, it will be necessary to amend the nearly 20 EU regulations that rely on one or more CLP criteria, to incorporate the new hazard classes related to PMT/vPvM properties. 5. PM(T)s should be included as Safe and Sustainable by Design (SSbD) criteria and communicated to stakeholders, including through sectorial regulations. Policy development in a circular economy at the European, national, and regional levels should include the prevention of PM(T) substances in the environment as the basic design principle, as this is the most effective type of solution. To support this principle, PROMISCES is developing and applying tools, such as the PMT-assessment tool, to help identify PM(T). 6. Local stakeholders stress the need for tangible objectives and clear policies from the EU or from national governments on PM(T) substances. In addition, strong local partnerships with all stakeholders and authorities involved in the circular economy route and its context are needed to find the optimal (combination of) solutions. Recommendations No. 2, 8, and 9 from this deliverable specifically support policy actions #1, #2, #3 and #5 from Wuijts et al. (2024), while #6 from the same policy brief underscores the need for stronger stakeholder involvement at the MS level for adequate management of PM(T)s. While these ongoing policy efforts represent progress, several challenges and boundary conditions must still be addressed to ensure the successful implementation of these policies at the MS level. Differences in resource constraints, technical capacities and public engagement create disparities in PM(T) management across Europe. The following chapter discusses these gaps and boundary conditions, emphasizing the need for coordinated action at the EU and national levels. D5.8 – Policy Recommendations 40 Broader challenges and considerations for managing PM(T)s Beyond the specific policy recommendations presented in Chapter 3, broader challenges and contextual factors play a critical role in the effective management of PM(T)s. These include disparities among EU MS in addressing these substances, economic and technical constraints, and the need for public awareness and collaboration. This chapter provides a brief overview of these considerations to frame the implementation of the recommendations in a practical context. D5.8 – Policy Recommendations 41 4 Broader challenges and considerations for managing PM(T)s 4.1 Addressing member state disparities The capacity of European MS to manage and address PM(T)s varies widely due to differences in regulatory frameworks, monitoring programs and infrastructure, technical know-how, and available resources. While the entire EU is affected by these pollutants, progress in regulating and managing PM(T)s and PFAS has been uneven across MS. For example, a few MS have enacted stricter threshold values for PFAS beyond those established in the various EU directives. One such country is Denmark, which has imposed a stricter limit of 2 ng/L for the sum of 4 PFAS (PFOA, PFOS, PFNA and PFHxS) in drinking water, whereas the EU limit for drinking water is 100 ng/L for the sum of 20 PFAS (DWD). Figure 4 illustrates this disparity within the EU and the European Economic Area (EEA) using the regulation of PFAS in drinking water as an example (Malarkey & De Kervenoael, 2024). Figure 4. Overview of PFAS drinking water limits across the EU and the EEA. Based on Malarkey and De Kervenoael (2024). While some countries have developed advanced systems for identifying and mitigating PMTs and PFAS – such as the Netherlands, where all PFAS have been classified as substances of very high concern (Pascoe, 2024) – others are still in the early stages of establishing comprehensive management approaches. To strengthen the management of PM(T)s across Europe, a first step is to understand the general needs of MS and identify what challenges they face in implementing EU directives. To begin this, PROMISCES conducted two surveys, internally at a project meeting and externally at a joint public event with Water Europe. In both surveys, we asked participants what needs exist in their respective countries regarding approaches and awareness for addressing PM(T)s in the soil-sediment-water system. The respondents answered questions related to identifying MS needs as well as provided ideas for solutions. These solutions can largely be classified as “leapfrog recommendations”. Solutions proposed to address the disparities across MS can include regulatory actions, knowledge-sharing platforms, development of best practices or guidance, and communication needs. Some of the identified MS © GeoNames, Microsoft, Open Places, OpenStreetMap, TomTom Powered by Bing PFAS-20 total: 100 ng/L PFAS-47: 100 ng/L per PFAS PFAS-4 total: 2 ng/L PFAS-4 total: 4 ng/L PFAS-4 total: 20 ng/L D5.8 – Policy Recommendations 48 the analysis of implementation strategies for the presented policy recommendations as the development of a policy implementation road map was outside the scope of this deliverable. Another suggestion would be to direct funding towards the maintenance of the DSF on the NORMAN website. By addressing the proposed research gaps and indicated needs for funding, the EU can enhance its scientific understanding of PM(T)s and ensure that future policies are grounded in scientific evidence. Future research projects can build on the PROMISCES findings reported in this deliverable, addressing open questions and strengthening the science-policy interface further. This deliverable provides guidance on how to address the complex regulatory landscape surrounding PM(T)s with a particular focus on PFAS. We urge all stakeholders - policymakers, industry leaders, researchers, and the public - to work together to implement these recommendations and achieve a toxic-free environment. By implementing these recommendations, the EU can achieve its zero pollution and circular economy goals, safeguarding human health and the environment for future generations D5.8 – Policy Recommendations 49 6 References Behnisch, P. A., Besselink, H., Weber, R., Willand, W., Huang, J., & Brouwer, A. (2021). Developing potency factors for thyroid hormone disruption by PFASs using TTR-TRβ CALUX® bioassay and assessment of PFASs mixtures in technical products. Environment International, 157, 106791. https://doi.org/10.1016/j.envint.2021.106791 Behnisch, P. A., Sosnowska, A., Mombelli, E., & Kuckelkorn, J. (2023). Deliverable D1.5—Set of novel QSAR models/grouping/read-across and in vitro bioassay approaches predicting relevant toxicological endpoints for PFAS/iPM(T) chemicals. https://zenodo.org/records/14945574 Commission Recommendation (EU) 2022/2510 of 8 December 2022 Establishing a European Assessment Framework for ‘Safe and Sustainable by Design’ Chemicals and Materials, C/2022/8854 (2022). https://eur-lex.europa.eu/eli/reco/2022/2510/oj/eng Council Directive 86/278/EEC of 12 June 1986 on the Protection of the Environment, and in Particular of the Soil, When Sewage Sludge Is Used in Agriculture (Sewage Sludge Directive), OJ L 181, 4.7.1986 (1986). https://eur-lex.europa.eu/eli/dir/1986/278/oj/eng Council Directive 1999/31/EC of 26 April 1999 on the Landfill of Waste, OJ L 182, 16.7.1999 (1999). https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31999L0031 Council of the EU and the European Council. (2024). European Green Deal. https://www.consilium.europa.eu/en/policies/green-deal/ de Schepper, J. K. H., van Oorschot, Y., Jaspers, R. J., Hamers, T., Lamoree, M. H., Behnisch, P., Besselink, H., & Houtman, C. J. (2023). The contribution of PFAS to thyroid hormone-displacing activity in Dutch waters: A comparison between two in vitro bioassays with chemical analysis. Environment International, 181, 108256. https://doi.org/10.1016/j.envint.2023.108256 Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 Establishing a Framework for Community Action in the Field of Water Policy (Water Framework Directive), OJ L 327, 22.12.2000, p. 1–73 (2000). https://eur-lex.europa.eu/eli/dir/2000/60/oj/eng Directive 2006/118/EC of the European Parliament and of the Council of 12 December 2006 on the Protection of Groundwater against Pollution and Deterioration, OJ L 372, 27.12.2006 (2006). https://eur-lex.europa.eu/eli/dir/2006/118/oj/eng Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on Waste and Repealing Certain Directives (Text with EEA Relevance) (Waste Framework Directive), OJ L 312, 22.11.2008 (2008). https://eur-lex.europa.eu/eli/dir/2008/98/oj/eng Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on Environmental Quality Standards in the Field of Water Policy, Amending and Subsequently Repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and Amending Directive 2000/60/EC of the European Parliament and of the Council, OJ L 348, 24.12.2008 (2008). https://eur-lex.europa.eu/eli/dir/2008/105/oj/eng Directive 2013/39/EU of the European Parliament and of the Council of 12 August 2013 Amending Directives 2000/60/EC and 2008/105/EC as Regards Priority Substances in the Field of Water Policy Text with EEA Relevance (Environmental Quality Standards (EQS) Directive), OJ L 226, 24.8.2013 (2013). https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32013L0039 D5.8 – Policy Recommendations 50 Directive (EU) 2020/2184 of the European Parliament and of the Council of 16 December 2020 on the Quality of Water Intended for Human Consumption (Recast) (Text with EEA Relevance) (Drinking Water Directive, DWD), OJ L 435, 23.12.2020, p. 1–62 (2020). https://eurlex.europa.eu/eli/dir/2020/2184/oj/eng Directive (EU) 2022/2464 of the European Parliament and of the Council of 14 December 2022 Amending Regulation (EU) No 537/2014, Directive 2004/109/EC, Directive 2006/43/EC and Directive 2013/34/EU, as Regards Corporate Sustainability Reporting (Text with EEA Relevance), PE/35/2022/REV/1 (2022). https://eur-lex.europa.eu/eli/dir/2022/2464/oj/eng Directive (EU) 2024/1785 of the European Parliament and of the Council of 24 April 2024 Amending Directive 2010/75/EU of the European Parliament and of the Council on Industrial Emissions (Integrated Pollution Prevention and Control) and Council Directive 1999/31/EC on the Landfill of Waste (Industrial Emissions Directive 2.0), PE/87/2023/REV/1 (2024). https://eurlex.europa.eu/eli/dir/2024/1785/oj/eng Directive (EU) 2024/3019 of the European Parliament and of the Council of 27 November 2024 Concerning Urban Wastewater Treatment (Recast) (Text with EEA Relevance), PE/85/2024/REV/1 (2024). EC: DG Environment. (2012). Technical guidance on the preparation of an inventory of emissions, discharges and losses of priority and priority hazardous substances. Guidance document No 28 . Publications Office. https://data.europa.eu/doi/10.2779/2764 EC: DG Health and Food Safety. (2017). Technical guidance for deriving environmental quality standards. European Union. https://data.europa.eu/doi/10.2875/018826 ECHA. (2023). Annex XV Restriction Report: Proposal for a Restriction. DOSSIER SUBMITTERS: Federal Institute for Occupational Safety and Health, Bureau REACH, National Institute for Public Health and the Environment (RIVM), Swedish Chemicals Agency (KEMI), Norwegian Environment Agency, and The Danish Environmental Protection Agency. EFSA Panel on Contaminants in the Food Chain (EFSA CONTAM Panel), Schrenk, D., Bignami, M., Bodin, L., Chipman, J. K., del Mazo, J., Grasl-Kraupp, B., Hogstrand, C., Hoogenboom, L. (Ron), Leblanc, J., Nebbia, C. S., Nielsen, E., Ntzani, E., Petersen, A., Sand, S., Vleminckx, C., Wallace, H., Barregård, L., Ceccatelli, S., … Schwerdtle, T. (2020). Risk to human health related to the presence of perfluoroalkyl substances in food. EFSA Journal, 18(9). https://doi.org/10.2903/j.efsa.2020.6223 European Chemicals Agency. (2023). Guidance on intermediates—January 2023 - Version 3.1. Publications Office of the European Union. https://data.europa.eu/doi/10.2823/067 European Commission. (2020a). A new Circular Economy Action Plan For a cleaner and more competitive Europe. European Commission. (2020b). Chemicals Strategy for Sustainability Towards a Toxic-Free Environment. COM/2020/667 final European Commission. (2021a). EU Soil Strategy for 2030 Reaping the benefits of healthy soils for people, food, nature and climate. COM/2021/699 final European Commission. (2021b). Pathway to a Healthy Planet for All EU Action Plan: ‘Towards Zero Pollution for Air, Water and Soil’. COM/2021/400 final D5.8 – Policy Recommendations 51 European Commission. (2023). ‘One substance, one assessment’ chemicals assessment reform for faster, simplified and transparent processes [Press Release]. European Commission. https://ec.europa.eu/commission/presscorner/detail/en/ip_23_6413 European Commission: Joint Research Centre, Abbate, E., Garmendia Aguirre, I., Bracalente, G., Mancini, L., Tosches, D., Rasmussen, K., Bennett, M. J., Rauscher, H., & Sala, S. (2024). Safe and sustainable by design chemicals and materials—Methodological guidance. Publications Office of the European Union. https://data.europa.eu/doi/10.2760/28450 European Commission: Joint Research Centre, Caldeira, C., Farcal, L. R., Garmendia Aguirre, I., Mancini, L., Tosches, D., Amelio, A., Rasmussen, K., Rauscher, H., Riego Sintes, J., & Sala, S. (2022). Safe and sustainable by design chemicals and materials—Framework for the definition of criteria and evaluation procedure for chemicals and materials. Publications Office of the European Union. https://data.europa.eu/doi/10.2760/487955 European Commission: Joint Research Centre, Gomez Cortes, L., Marinov, Sanseverino, I., Navarro Cuenca, A., Niegowska, M., Porcel Rodriguez, E., Stefanelli, F., & Lettieri, T. (2022). Selection of substances for the 4th Watch List under the Water Framework Directive. Publications Office. https://data.europa.eu/doi/10.2760/01939 European Commission: Joint Research Centre, Huygens, D., García-Gutierrez, P., Orveillon, G., Schillaci, C., Delre, A., Orgiazzi, A., Wojda, P., Tonini, D., Egle, L., Jones, A., & Lugato, E. (2022). Screening risk assessment of organic pollutants and environmental impacts from sewage sludge management: Study to support policy development on the Sewage Sludge Directive (86/278/EEC). Publications Office of the European Union. https://data.europa.eu/doi/10.2760/541579 European Environment Agency. (2023). The European Commission’s zero pollution ambition [Page]. https://www.eea.europa.eu/signals-archived/signals-2020/the-european-commission-s-zero European Partnership for the Assessment of Risks from Chemicals (PARC). (n.d.). SSbD Toolbox. Retrieved 20 February 2025, from https://www.parc-ssbd.eu/ Fuchs, S., Kaiser, M., Kiemle, L., Kittlaus, S., Rothvoß, S., Toshovski, S., Wagner, A., Wander, R., Weber, T., & Ziegler, S. (2017). Modeling of Regionalized Emissions (MoRE) into Water Bodies: An Open-Source River Basin Management System. Water, 9(4), 239. https://doi.org/10.3390/w9040239 Hansson, S. O. (2013). Chapter 9—ALARA: What is Reasonably Achievable? Radioactivity in the Environment, 19, 143–155. https://doi.org/10.1016/B978-0-08-045015-5.00009-5. ICPDR. (2021). DANUBE RIVER BASIN MANAGEMENT PLAN - Update 2021. https://www.icpdr.org/sites/default/files/nodes/documents/danube_river_basin_managament_plan _-_update_2021_full_text.pdf Institut de Physique du Globe de Paris (IPGP). (2025). Deliverable D3.4—Assessing the treatment performance of PFAS degradation/immobilisation in the liquid and solid sediment fractions: A toxicity risk assessment. [Document in preparation.] International Organization for Standardization. (2018). Guidelines for performance evaluation of treatment technologies for water reuse systems. International Organization for Standardization. (2019). Guidelines for performance evaluation of treatment technologies for water reuse systems. International Organization for Standardization. (2021). Guidelines for treated wastewater use for irrigation projects—Part 4: Monitoring. https://www.iso.org/standard/73485.html D5.8 – Policy Recommendations 52 Jou-Claus, S., Pérez-Estrada, L., Bosch, C. , Llorca, M., Farré, M., Cano, A., Matamoros, V., López de Alda, M., Baeta, J., Mora, R., Behnisch, P. & Panda, D. (2025) Deliverable 3.6 - Selection of the best chemical treatment for the degradation of halogenated pollutants and PFAS from groundwater and performance at field-scale. [Document in preparation] Kowalska, D., Sosnowska, A., Bulawska, N., Stępnik, M., Besselink, H., Behnisch, P., & Puzyn, T. (2023). How the Structure of Perand Polyfluoroalkyl Substances (PFAS) Influences Their Binding Potency to the Peroxisome Proliferator-Activated and Thyroid Hormone Receptors—An In Silico Screening Study. Molecules, 28(2), 479. https://doi.org/10.3390/molecules28020479 Kuckelhorn, J., & Mittag, A. (2024). Deliverable D1.6 – Guidance document for an enhanced HRIV concept for drinking water. https://zenodo.org/records/14935779 Lancioni, N., Blumenthal, E., Sgroi, M., Fatone, F., Lazzazzara, M., Ribarova, I., Valchev, D., Frugis, A., Lyubomirova, V., & Lincheva, S. (2024). Deliverable D4.5—Mass flow and fate analysis for PFAS from landfill leachate in Bulgaria and Italy. https://zenodo.org/records/14502053 Lapworth, D. J., Lopez, B., Laabs, V., Kozel, R., Wolter, R., Ward, R., Vargas Amelin, E., Besien, T., Claessens, J., Delloye, F., Ferretti, E., & Grath, J. (2019). Developing a groundwater watch list for substances of emerging concern: A European perspective. Environmental Research Letters, 14(3), 035004. https://doi.org/10.1088/1748-9326/aaf4d7 Liu, M., Kittlaus, S., Meijers, E., ten Velden, C., Hartgring, S., Boisgontier, H., & Zessner, M. (2025). Modelling PFAS Emission and Transport at Large-Catchment Scale with a Regionalised Approach. Euroean Geosciences Union General Assembly 2025. Liu, M., Kittlaus, S., & Zessner-Spitzenberg, M. (2024). Regionalised Emission Model (MoRE) for PFAS from H2020 Project PROMISCES - Case Study 2 (Version 1.0.0). TU Wien. https://doi.org/10.48436/WG9DY-R9R31 Liu, M., Saracevic, E., Oudega, T. J., Obeid, A. A. A., Nagy-Kovács, Z., László, B., Derx, J., Kittlaus, S., Zoboli, O., & Zessner, M. (2025). Investigating the Extent of PFAS Contamination in the Upper Danube Basin across Environmental Compartments. Science of the Total Environment, Manuscript in preparation. Malarkey, B., & De Kervenoael, M. (2024, October). Understanding new PFAS regulations in the U.S. and EU. Roland Berger. https://www.rolandberger.com/en/Insights/Publications/Opportunitieschallenges-in-new-regulations-of-forever-chemicals.html Meijide Fernández, J., Herrero, J., Pérez-Estrada, L., Bosch, C., Pierina Orlando, D., Inés Bonansea, R., López de Alda, M., Llorca, M., Farré, M., Cano, A., Matamoros, V., Mas, T., Martínez, B., & Valero, S. (2025). Deliverable D4.3. - Recommendations on EAOP-CW based treatment system for water reuse applications. [Document in preparation.] Narain-Ford, D., Hof, M., Naus, F., Carter, K., Bosch, C., Sgroi, M., BOUCARD, P., Cavelan, A., Ribarova, I., & Hartmann, J. (2025). Deliverable D5.4—Solution strategies to reach a non-toxic environment for 5 PM(T) uses from a system perspective and how they are perceived by the different stakeholders in the system. https://doi.org/10.5281/ZENODO.14604168 Naus, F., Carter, K., Sierra Olea, M., Bosch, C., Sgroi, M., Oudega, T., Zessner, M., Cavelan, A., Boucard, P., Zhiteneva, V., Sermondadaz, F., & Narain-Ford, D. (2025). Deliverable D5.6—Guidance on transdisciplinary co-creation of solution strategies to reach a non-toxic environment and safe reuse of resources. [Document in preparation.] D5.8 – Policy Recommendations 53 Paparella, M., Hale, S., Lynch, I., Hartmann, J., & Schaffert, A. (2024). Policy Brief Achieving zero pollution by 2050 needs regulatory change: A call for policy support of New Approach Methodologies (NAMs). Green Deal Health Cluster Policy Brief July 2024.pdf Pascoe, R. (2024). All firms using PFAS chemicals told they must slash emissions. DutchNews.Nl. https://www.dutchnews.nl/2024/11/all-firms-using-pfas-chemicals-told-they-must-slash-emissions/ Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL Amending Directive 2000/60/EC Establishing a Framework for Community Action in the Field of Water Policy, Directive 2006/118/EC on the Protection of Groundwater against Pollution and Deterioration and Directive 2008/105/EC on Environmental Quality Standards in the Field of Water Policy, No. COM/2022/540 final (2022). https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52022PC0540 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Soil Monitoring and Resilience (Soil Monitoring Law), No. COM/2023/416 final (2023). https://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=celex:52023PC0416 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL Establishing a Common Data Platform on Chemicals, Laying down Rules to Ensure That the Data Contained in It Are Findable, Accessible, Interoperable and Reusable and Establishing a Monitoring and Outlook Framework for Chemicals, COM/2023/779 final (2023). https://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=celex:52023PC0779 Regulation (EC) No 1107/2009 of the European Parliament and of the Council of 21 October 2009 Concerning the Placing of Plant Protection Products on the Market and Repealing Council Directives 79/117/EEC and 91/414/EEC (Plant Protection Products (PPPs) Regulation), OJ L 309, 24.11.2009 (2009). https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1107 Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 Concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), Establishing a European Chemicals Agency, Amending Directive 1999/45/EC and Repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as Well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, OJ L 396, 30/12/2006, p. 1–850 (ET, LV, LT, MT, SK) (2006). Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on Persistent Organic Pollutants (Recast) (Text with EEA Relevance) (Persistent Organic Pollutants (POPs) Regulation), PE/61/2019/REV/1 (2019). https://eur-lex.europa.eu/eli/reg/2019/1021/oj/eng Regulation (EU) 2020/741 of the European Parliament and of the Council of 25 May 2020 on Minimum Requirements for Water Reuse (Text with EEA Relevance), PE/12/2020/INIT (2020). https://eurlex.europa.eu/eli/reg/2020/741/oj/eng Regulation (EU) 2024/2865 of the European Parliament and of the Council of 23 October 2024 Amending Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures (Text with EEA Relevance) (CLP Regulation), PE/108/2023/REV/1 (2024). https://eurlex.europa.eu/eli/reg/2024/2865/oj/eng Regulation (EU) No 528/2012 of the European Parliament and of the Council of 22 May 2012 Concerning the Making Available on the Market and Use of Biocidal Products (Biocidal Products Regulation; BPR), OJ L 167, 27.6.2012 (2012). https://eur-lex.europa.eu/eli/reg/2012/528/oj/eng Rückbeil, F., Saal, L., & Sperlich, A. (2024). Deliverable D4.2—Planning & design tool for drinking water treatment for PFAS & industrial chemicals. https://zenodo.org/records/13982527 D5.8 – Policy Recommendations 54 Rückbeil, F., Sperlich, A., Kuckelkorn, J., von Wichert, A., Dietrich, C., Hartmann, A., Behnisch, P., & Besselink, H. (2025). Deliverable D4.1 – Performance and assessment of drinking water treatment trains for removal of PFAS and industrial chemicals. https://zenodo.org/records/14923804 Sardi, A. E. (2025). ECHA registered intermediate substances with PMT and PBT potential [Dataset]. Zenodo. https://doi.org/10.5281/ZENODO.14752778 Sosnowska, A., Mudlaff, M., Mombelli, E., Behnisch, P., Szymon, Z., Besselink, H., Kuckelkorn, J., Bulawska, N., Kepka, K., Kowalska, D., Brouwer, A., & Puzyn, T. (2025). Identification of new PFAS for severe interference with thyroid hormone transport: A combined in vitro/silico approach. J. Hazardous Materials (Accepted with Minor Revision). Sosnowska, A., Puzyn, T., Peijnenburg, W., & Wassenaar, P. (2024). Deliverable D2.1 – Toolbox improved in silico models for identification of PMT properties. https://zenodo.org/records/14800915 UNISOFIA. (2025). Deliverable D4.6—Performance and comparative analyses of landfill leachate treatment options for the removal of PFAS. [Document in preparation.] van der Hulst, A. (2024). Draft Common Implementation Strategy EU Water Law—Work Programme 2025-2027. https://circabc.europa.eu/ui/group/9ab5926d-bed4-4322-9aa79964bbe8312d/library/9bc9c88a-6855-4611-b401-b4b384d8395c/details Wuijts, S., Naus, F., Hof, M., Sardi, A. E., Carter, K., Andres, S., & Narain-Ford, D. (2024). Deliverable D5.3—Policy brief on PM(T) concerns and actions in EU. https://doi.org/10.5281/ZENODO.14389628 Zessner, M., Baldwin, D., del Val Alonso, L., Derx, J., Devau, N., Janssen, G., Jou Claus, S., Kittlaus, S., Knoche, F., Lions, J., Liu, M., Markus, A., Marsman, A., Meesters, J., Meijers, E., Obeid, A., Oudega, T. J., Pathak, D., Sprenger, C., … Groot, H. (2025). Deliverable D2.4 – Guidance Document on emission-, fateand transport modelling for exposure assessment of surface and groundwater. [Document in preparation.]