The European Union’s push for a circular economy and zero pollution is running into a stubborn obstacle: substances that refuse to break down. These so-called persistent, mobile, and toxic (PMT) or very persistent and very mobile (vPvM) chemicals, including many per- and polyfluoroalkyl substances (PFAS), slip through conventional water and soil treatment systems like ghosts, accumulating in ecosystems and defying cleanup efforts. Julia Hartmann, a researcher at the Netherlands’ National Institute for Public Health and the Environment (RIVM), warns that without coordinated action, these substances could undermine decades of environmental progress.
“These chemicals don’t respect compartment boundaries,” Hartmann explains. “They move freely between soil, sediment, and water, making them nearly impossible to contain with current regulations. The EU’s circular economy ambitions can’t succeed if we’re constantly chasing contaminants we can’t eliminate.”
The challenge is structural. PFAS and similar compounds are prized for their durability and resistance to heat, water, and oil—traits that make them invaluable in industries from aerospace to food packaging. Yet their very persistence turns them into long-term liabilities. In water treatment plants, they slip through filtration systems. In soil remediation projects, they linger for decades. And in recycled materials—critical to the circular economy—they can re-enter the supply chain, creating new exposure pathways.
The EU took a step forward in March 2023 by formally recognizing PMT and vPvM hazard classes under the Classification, Labelling and Packaging (CLP) regulation. But as Hartmann and her team argue in a new paper in *Environmental Sciences Europe* (Umweltwissenschaften Europas), this is only the beginning. The regulatory framework remains fragmented, with laws governing water, soil, and waste often operating in silos. “We have laws for water, laws for soil, and laws for waste, but no law that truly sees the whole system,” Hartmann says. “That’s why contaminants like PFAS can slip through the cracks.”
The PROMISCES project, funded by the EU’s Horizon 2020 program, offers eight policy recommendations to bridge these gaps. These include updating substance regulations to reflect mobility as a hazard, integrating PMT/vPvM criteria into circular resource management policies, and investing in advanced treatment technologies capable of capturing these elusive compounds.
For industries like energy, where PFAS are used in everything from drilling fluids to fuel cell membranes, the implications are immediate. Compliance costs are rising as regulators impose stricter discharge limits and cleanup obligations. But Hartmann sees opportunity in the crisis. “This isn’t just a regulatory headache—it’s a market signal,” she says. “Companies that invest in detection, treatment, and substitution now will be ahead of the curve when stricter rules take effect.”
The energy sector, in particular, stands at a crossroads. Offshore wind farms, geothermal plants, and even traditional oil and gas operations rely on equipment that may contain PFAS. As the EU tightens its zero-pollution targets, firms will need to either phase out these substances or develop robust containment strategies. “The circular economy isn’t possible if we’re constantly battling contaminants we can’t control,” Hartmann notes. “This research is a call to action—not just for regulators, but for industries that will drive the next phase of sustainability.”
With the EU’s Green Deal, Circular Economy Action Plan, and Soil Strategy all hanging in the balance, the time for fragmented approaches has passed. The PROMISCES recommendations could help align policy, technology, and industry practice—but only if stakeholders act quickly. As Hartmann puts it: “We’re not just cleaning up pollution. We’re cleaning up the regulatory mess that lets it spread.”