This line of reasoning has some support from physicochemical considerations and modelling.

Due to its physicochemical properties it has the potential to be transported long distances.

Due to its physicochemical properties it has the potential to be transported long distances and it is persistent in the environment.

Due to its physicochemical properties it has the potential to bioaccumulate. Its listing as a possible human carcinogenic should also be of special concern.

The Ordinance was issued on the basis of the Law of 11th January 2001 on chemical substances and preparations (Journal of Laws No. 11, item 84 with subsequent amendments) The Ordinance elaborates the criteria that have to be met by organizational units which conduct - as required by the Law - tests of the physicochemical properties, toxicity and eco-toxicity of chemical substances and preparations.

It could be argued again that given the extreme persistence of PFOS, all PFOS-related substances would degrade to PFOS in a time frame that would contribute to the total environmental load. This line of reasoning has some support from physicochemical considerations and modelling. On the other hand there is limited experimental data to confirm this approach and it would be very time and resource-consuming to provide the experimental support that each and every individual derivative of PFOS degrades to contribute to the total environmental load of PFOS.