Recommendations for regulatory coherence and effective management of persistent and mobile substances in the soil-sediment–water system to move the circular economy forward

Abstract

Persistent, mobile, and toxic (PMT) or very persistent and very mobile (vPvM) substances, such as many per- and polyfluoroalkyl substances (PFAS), pose a significant environmental and regulatory challenge due to their persistence in water, soil, and sediment. These substances bypass conventional treatment methods, endangering human and environmental health and impeding the European Union’s (EU) sustainability agenda, including the Green Deal, the Circular Economy Action Plan (CEAP), the Zero Pollution Action Plan (ZPAP), the Chemicals Strategy for Sustainability (CSS), and the EU Soil Strategy. The recent inclusion of PMT and vPvM hazard classes in the Classification Labeling and Packaging (CLP) regulation 1272/2008, via Delegated Regulation (EU) 2023/707 marks an important step in recognizing these properties. However, the current regulatory landscape for PMT/vPvM substances remains fragmented and complex, with different environmental compartments—soil, sediment, water, and sludge—addressed under separate downstream policies and with the translation of these criteria into coherent measures across environmental legislation still pending. Policy updates, as well as improvements, and additions to current regulations are urgently needed to ensure harmonized management of PMT/vPvM substances across the soil-sediment–water system and to achieve the EU’s circular economy and zero pollution ambitions. To this end, the Horizon 2020 project PROMISCES proposes eight policy recommendations across four policy fields: substance regulations, circular resource management, technology performance and pollution control, and tools and data management. These recommendations integrate PROMISCES research findings, stakeholder input, and regulatory analysis to support the EU circularity and zero pollution ambitions.