This week I had the pleasure of speaking with Dr. Jane Vergnes, Director of Toxicology and Vice President, Scientific Affairs, here at B&C and its consulting affiliate, The Acta Group (Acta®), about the regulation of PFAS under REACH. Many of our listeners know the European Chemicals Agency (ECHA) released on February 7 its long-awaited restriction proposal for the regulation of per- and polyfluoroalkyl substances in the European Union (EU) under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulations. The proposal is a monster -- complex, far-ranging, and very consequential. The six-month consultation period is open until late September, and regulated entities on both sides of the Atlantic are urged to read and comment on the proposal. Jane and I cover lot of territory in our discussion. We discuss the risk options ECHA considered, what it has proposed, some legal vulnerabilities with the approach ECHA has taken that commentators are discussing, and how best to prepare for the final restrictions, whenever they are issued and in whatever form.

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