Evaluating the Full Cost of PFAS: Considerations for Cost-Benefit Analysis and Regulatory Design

This report synthesizes recent research on the monetized damages caused by per- and polyfluoroalkyl substances (PFAS), a class of synthetic "forever chemicals" that accumulate in humans and ecosystems. The authors argue that while existing estimates of PFAS-related economic damages are substantial, they are likely significant understatements due to limited scopes in exposure pathways and health endpoints. Most current studies focus on drinking water and a small subset of compounds, omitting ecological impacts, property value declines, and various health conditions. The paper advocates for class-based regulation and a standardized set of methods for exposure assessment and valuation to support more robust and transparent policymaking.

The study identifies significant variation in damage estimates, stemming from different assumptions regarding exposure-response relationships and valuation techniques. For example, some U.S.-focused research estimates annual health damages in the tens of billions, yet these figures often ignore "precursor" compounds that degrade into terminal PFAS. Additionally, the costs of removing PFAS from the environment are found to be exceptionally high, making upstream restrictions on use and disposal a necessary complement to remediation. The report warns that narrowly targeted regulations may lead to "regrettable substitution," where firms switch to structurally similar but unregulated PFAS compounds that may be just as toxic.

Significant costs identified in the report include:

* Estimated annual health-related damages in the U.S. range from under $1 billion to over $60 billion.

* The cost per kilogram of PFAS removed from contaminated media ranges from $0.9 million to $60 million.

* One study estimated that the cost of destroying just one year's worth of global PFAS releases exceeds the annual global GDP.

* Routinely monitored PFAS often comprise less than 50% of total PFAS found in human exposure media like textiles and food packaging.

* EPA found strong evidence that PFOA exposure is associated with renal cell carcinoma, an endpoint quantified in at least one of the three major studies reviewed.

Safavi, Leila, and Peter Howard. *Evaluating the Full Cost of PFAS: Considerations for Cost-Benefit Analysis and Regulatory Design*. New York: Institute for Policy Integrity, New York University School of Law. October 2025. https://policyintegrity.org/publications/detail/evaluating-the-full-cost-of-pfas