PFAS chemicals are now used in countless products. They leave traces in the environment and the human body. The long-term implications remain unclear, as do the most effective methods for dealing with so-called “forever chemicals” in future. This raises questions for many industries, not least the insurance industry. Underwriters must find appropriate methods for dealing with these difficult-to-estimate risks.
Anyone who enjoys walking by the sea will be familiar with the scene: foam residues often form where the waves meet the shore. Your feet sink into the foam, children play with it, and dogs chase after it. It’s an experience that’s associated with holidays and relaxation.
However, few people realise that in certain places this foam contains high concentrations of harmful PFAS chemicals (per- and polyfluoroalkyl substances). This was the conclusion reached by the environmental organisation Greenpeace after examining sea foam along German coastlines. The researchers found concentrations of up to 160,000 nanograms per litre of the chemicals in the samples. For comparison, Denmark has stipulated a limit of 40 nanograms per litre for bathing water. The German samples exceeded this value by a factor of 290 to 3,777.
But how do PFAS end up in the sea? Synthetically produced compounds have been in industrial use since the end of the 1940s due to their water-, grease- and dirt-repellent properties. The substances – also known as “forever chemicals” – are found in numerous products, including raincoats, Teflon pans, dental floss, lipstick, pizza boxes, silicone seals and fire extinguishing foams. PFAS compounds can also persist in the ground as production residues, bodies of water or industrial waste, such as sewage sludge. The problem is that these chemicals, many of which are classified as hazardous to health, are not easily biodegradable and progressively accumulate in the environment.
This is also a cause of concern for the insurance industry, as PFAS-related claims could lead to highly unpredictable costs. Here, we consider the topic of PFAS from the perspectives of science, law, industry and the insurance industry.
It is estimated that more than 10,000 PFAS substances are in circulation. “We distinguish between three groups”, says Michaela Müller from the Fraunhofer Institute for Interfacial Engineering and Biotechnology IGB. “Firstly, fluorosurfactants, which are found in fire extinguishing foams and cleaning agents among other things. Secondly, fluoropolymers, which are used in many production facilities and consumer products. And thirdly, fluorinated gases, which are employed in special industrial applications”.
Fluorinated gases not only contribute to the greenhouse effect, but also release harmful degradation products, such as trifluoroacetic acid (TFA), into the environment through precipitation. Fluorosurfactants also end up in the environment (e.g. through firefighting operations), where they pollute the soil and water. They also reach the human body via drinking water or food, such as fish and vegetables. In 2020, the European Food Safety Authority (EFSA) defined a tolerable intake of 4.4 nanograms per kilogram of bodyweight per week for four PFAS. This is due to the fact that certain fluorosurfactants are suspected of being harmful to the metabolism, reproductive system and immune system as well as promoting cancer and hormonal imbalances. Because of these health risks, individual fluorosurfactants have already been banned or strictly regulated. The toxicity of many other PFAS has not yet been adequately investigated.
Fluoropolymers exhibit an even greater chemical resistance than fluorosurfactants and are therefore considered somewhat less problematic. However, Müller points out: “It remains unclear whether these stable compounds will also break down into harmful substances in the distant future”.
Understanding PFAS:
A chemical classification
PFAS (per- and polyfluoroalkyl substances) are synthetically produced organic compounds made up of different lengths of carbon chains, in which the hydrogen atoms are completely (perfluorinated) or partially (polyfluorinated) replaced by fluorine atoms. The Organisation for Economic Co-operation and Development (OECD) classifies any substance containing at least one fully fluorinated carbon-fluorine bond as a PFAS. The PubChem chemical database lists nearly seven million substances that meet this definition. It is estimated that more than 10,000 of these are in circulation. Although PFAS have widely differing properties, they are united by their extreme stability: they are difficult to degrade in the environment.
Chemical Structure of the
Two Most Common PFAS
For several years, an increasing number of PFAS-related claims have been brought before the court, especially in the USA. In addition to PFAS manufacturers, users of PFAS – including firefighting equipment suppliers, the textile and paper industry and consumer goods manufacturers – have also been affected. The legal proceedings are proving to be extremely complex. “It is the combination of their chemical resistance, ubiquitous usage and sometimes toxic properties that makes the liability risk associated with PFAS particularly challenging”, explains environmental lawyer Mirjam Büsch from Franßen & Nusser, a law firm specialising in product and environmental law.
Most claims relate to environmental damage caused by PFAS-containing substances that have ended up in the soil and water. PFAS producers, such as the American technology group 3M, have already had to defend themselves in court on multiple occasions. In 2022, the company reached an agreement with the Belgian authorities to pay 570 million euros for the clean-up of pollution in the soil around a PFAS plant. One year later, the group agreed to pay up to USD 12.5 billion to settle a dispute with water utilities in the USA. Not least due to the growing number of lawsuits, 3M has announced that it will discontinue all PFAS manufacturing by the end of 2025.
In the case of damage due to PFAS, it is often difficult to clearly identify the responsible party. At the same time, the causal link between the source and the damage is decisive when it comes to the matter of liability and compensation. In court, environmental assessments play a key role in tracing possible pathways. “Courts may also rely on presumptions of causation”, explains Büsch: for instance, if a PFAS processing plant is located nearby or if it is documented that a fire was fought using PFAS-containing extinguishing foam.
It is even more challenging to prove health consequences. “There is as yet no scientifically reliable traceability”, explains Müller. “Many PFAS are not acutely toxic but slowly accumulate in the body and can promote a wide variety of diseases”. Despite these uncertainties, initial judgements have been issued. The Swedish Supreme Court has determined that over 150 residents in the south of the country have sustained personal injury, solely on the basis of significantly elevated PFAS values in their blood. They had been drinking contaminated water for years and sued the municipal water company. Whether this gives rise to a claim for compensation remains to be seen in further proceedings.
One thing is certain: the more frequently measurements are taken, the stronger the causal links, and the more convincing correlations will be in the future. Furthermore, stricter guidelines improve the legal basis for compensation claims. A current proposal to adopt a ban on all PFAS was submitted to the European Chemicals Agency (ECHA) by Germany, Denmark, the Netherlands, Norway and Sweden in January 2023 and is causing quite a stir. The EU is now evaluating the implementation of the initiative within the framework of the EU Chemicals Regulation (REACH). The goal is to regulate the entire group of substances and to comprehensively replace PFAS. Wherever this is not yet possible, exceptions and transitional periods will be applied. Büsch states: “The ban will be examined on a sector-specific basis – but this will take some time due to the complex review process”.
Worldwide
With the Stockholm Convention on Persistent Organic Pollutants, 186 states worldwide are committed to regulating persistent organic pollutants (POPs). The international treaty entered into force on 17 May 2004. It also lists three subgroups of PFAS – PFOS, PFOA and PFHxS – whose use is prohibited barring a few exceptions.
Europe
The European Union has implemented the Stockholm Convention through the EU POP Regulation 2019/1021. However, it regulates some substances differently. There are also further specific EU regulations and national regulations that set bans, restrictions and maximum levels of PFAS in drinking water, bodies of water, food and packaging. Furthermore, several subgroups of PFAS are regulated in the EU by the REACH chemicals regulation. A comprehensive restriction procedure under REACH is currently underway that aims to largely ban all non-essential PFAS in the EU.
A general ban on PFAS would have far-reaching consequences for the industry. Wherever PFAS perform essential functions, there is a threat of costly conversions, technological regression or even a halt in production. Orgalim, the European trade association representing the mechanical engineering, electronics and metalworking industries, warns that a blanket ban on the chemicals “would significantly impact on our industries’ ability to produce robust and reliable products”. After all, there simply are no alternatives yet in some sectors. Medical devices are one example. Here, PFAS are used in tubes, catheters and implants, among other things. Additionally, they play an important role in key technologies of the energy transition. They are found in the membranes of hydrogen fuel cells as well as in coatings for solar modules.
Müller predicts that more and more companies will withdraw from the production of PFAS in the long term. As a result, many products would disappear from the market or become considerably more expensive – and thus less attractive. “Some companies are switching to other PFAS variants, but many are also actively seeking out alternatives”, explains the scientist, who is developing substitutes at the Fraunhofer Institute.
The insurance industry is closely monitoring developments in the risks associated with PFAS, the growing number of lawsuits, and new regulations. There is increasing concern that PFAS cases could place enormous financial burdens on the balance sheets of insurers. The losses affect lines of business such as environmental, product and public liability as well as employers’ liability or D&O insurance.
“The greatest risk is posed by the contamination of the soil and water and the associated costly clean-up work”, says Anja Käfer-Rohrbach, Deputy Chief Executive Officer of the German Insurance Association (GDV). Many of these pollutants have already been lurking in the soil for years – and often decades. Rising awareness is now steadily prompting authorities to carry out appropriate sampling based on experience, primarily in the vicinity of industrial estates or former military airbases, since relevant findings are often made in these areas.
To deal with difficult-to-estimate PFAS-related risks, two basic strategies are currently emerging in the insurance industry. The first involves retreating as an insurer and categorically excluding risks related to potential PFAS exposure – for fear of being becoming engaged in problematic claims scenarios. This is already the norm in the USA. Exclusions are also on the rise in Scandinavian countries. In the German-speaking world, by contrast, such general PFAS exclusions have not become standard practice in the primary and reinsurance market.
The strategy observed here relies on dialogue and a risk-based approach, which Deutsche Rück is also currently pursuing (see interview further below). Primary insurers identify potentially exposed individual risks among their clients and assess them on a case-by-case basis. An in-depth PFAS analysis, for example using questionnaires, is also necessary. The results form the basis for specifically addressing PFAS risks in individual policies or, if necessary, excluding them altogether.
The GDV has recently developed a model clause for dealing with PFAS. It initially excludes coverage of PFAS liability, but it also contains a clause stating that insurers and clients should agree on exceptions to this rule. For example, under what kinds of conditions and to what extent damages caused by PFAS can be insured. “Blanket exclusions would be the wrong approach”, stresses Käfer-Rohrbach. “Nevertheless, insurers have to limit their risk”. Her argument: “The more information industry provides, the sooner both sides can come together. And the sooner insurers will be able to provide the most optimal and extensive coverage possible”.
Good environmental damage reports, comprehensive safety measures and regular monitoring are also incorporated into the risk assessment. Büsch believes industry is on the right path in this regard: “Many companies are now handling PFAS far more responsibly than they were a few years ago and are investing in precautionary measures and plant safety”.
Not least, the GDV hopes that its clause will encourage industrial policyholders to replace PFAS with less harmful substances. After all, one thing is clear: dealing with PFAS will not become simpler in future and a significant reduction in their use is unavoidable in the long term.
Interview
Many primary insurers and reinsurers are engaging in dialogue with industry regarding PFAS. Thomas Schroer, Senior Manager in the Liability, Accident, Motor Lines Management department at Deutsche Rück, explains how a more responsible approach to the complex risk can succeed.
The comparison falls short, as there are fundamental differences. With asbestos, it is usually easy to track the source of the contamination. Moreover, pathologies such as asbestosis are clearly associated with the substance. In the case of PFAS, such attributions are still rarely possible. For some PFAS, however, the indications of causal relationships are so strong that it is likely to be only a matter of time until this changes.
We are taking the PFAS risk very seriously. We attend specialist events, keep ourselves informed about ongoing lawsuits and, above all, we are in regular dialogue with our clients, who in turn work together with various risk groups. We understand that there are varying degrees of PFAS exposure that require an individual response. Blanket exclusions may be warranted, especially for manufacturers and users of PFAS. In this respect, we expect a precise identification and description of the risk from our clients. For all other companies with limited or indirect exposure to PFAS, it should be considered whether and how such risks could be managed responsibly within the portfolio. One example could be manufacturers in the biotechnology sector. When new risks such as PFAS arise, our primary objective is not to exclude them, but to make them as insurable as possible. Ultimately, we are not only risk bearers, but also supporters of business.
Before a risk is completely excluded, there are several possibilities to limit it. For example, an insurer could agree appropriately high deductibles or introduce a cap – such as by covering PFAS risks in principle, but only up to a certain amount. The targeted co-insurance of relatively unproblematic PFAS substances or certain product lines is also possible, as envisaged by the GDV approach. To place temporal restrictions on risks, existing contamination or clearly defined production periods could be excluded from insurance coverage. Businesses with a connection to the USA or Canada, such as direct exports to those countries, represent a special case. We regularly see special regulations concerning PFAS there – mostly in the form of exclusions.
With regard to industry, it would be desirable to significantly reduce the use of PFAS and find substitutes. For the insurance industry, it remains difficult to predict how the situation will develop. If major providers of primary insurance or reinsurance begin to exclude PFAS-related risks altogether, other insurers will likely follow, resulting in a domino effect. From a global perspective, we are already seeing that insurance coverage for PFAS-related liability is no longer available in certain regions. Despite this uncertainty, I believe that the odds are good for the risk-based approach that is favoured on the German market – provided that we exercise caution when dealing with the issue and protect ourselves as an industry with individually tailored policies.
Natural hazards are an existential challenge for the insurance industry. Severe losses in recent years have repeatedly demonstrated this all too clearly. Any organisation intending to meet this challenge requires sophisticated risk modelling. This risk modelling must be continuously optimised, while taking the impact of climate change into account. An essential part of this process is determining which climate change-related trends can be identified in the present time on the basis of past decades, and which are set to emerge in future.
Deutsche Rück has been using its own risk models for natural hazards in Germany for many years. Coverage of natural hazards has traditionally been the core business of the reinsurer. Given the strong market position of the public insurers in homeowners’ insurance, and the extensive data pool that is available as a result, the relevant expertise in the NatCat space has been ingrained in Deutsche Rück’s DNA since its founding in 1951. Indeed, Deutsche Rück pioneered the modelling of natural hazards within the German insurance industry. The company is now gradually rolling out updates for its natural hazards risk models.
With its comprehensive proprietary risk models, Deutsche Rück has a unique advantage in the German market thanks to its large data pool, whereas the purchase of third-party models remains the norm elsewhere in the market. With its risk models, Deutsche Rück operates at the interface between science and the insurance industry. The insurer can directly apply the latest research findings in the damage calculation. The further development of its risk models is primarily driven by two factors: the vast and growing quantity of data available today and the computing capacity to process it, which has increased sharply.
This is aptly demonstrated by Deutsche Rück’s new winter storm model, for which an update has already been available since the 2024/25 renewal. “We can now work with much larger volumes of data from the publicly available sources alone, such as the German Meteorological Service, and can thus analyse regional risks much more precisely greater depth than before”, says Dr Matthias Klawa, an expert from Deutsche Rück’s NatCat Centre.
Ensemble seasonal forecasts were used for the new model. These forecasts were produced using a uniform modelling method and based on the initial atmospheric conditions on the first day of each month since the 1980s, enabling the experts at Deutsche Rück to make multiple realistic “retrospective predictions” of the past.
The model utilises large volumes of data from the portfolio and claims information from the public insurers as leaders in the German homeowners’ insurance market, as well as the data of other primary insurance clients. Consequently, Deutsche Rück enjoys direct access to a large portion of the market. With its broad and deep catalogue of storm events and insights from portfolio and client data, the new model provides a close look at the individual clients and their respective lines of business – and thus serves as a reliable resource to draw on when offering clients tailored reinsurance solutions.
Dr Matthias Klawa, expert at Deutsche Rück’s NatCat Centre
What role does climate change play in this? Its impact on the risk of winter storms in Germany cannot be predicted with certainty, explains Klawa. “We see a flat – in some cases, even downward – trend in storm activity in Central Europe from the 1970s until today”. However, scientific climate forecasts for the coming decades differ significantly in their conclusions for this region. “There are climate models that predict very sharp increases, but also a few that actually anticipate future declines”, notes Klawa.
The same also applies to the new summer storm/hail model, which is expected to be published in two years. It will incorporate new damage patterns from major hail events in recent years as well as the latest climate research findings. It remains unclear whether the risk will continue to rise in future as a result of climate change or plateau at an elevated level, says Klawa. “We must determine which trends in the damage patterns are due to a possible shift in meteorological intensity and which can be attributed to a change in the susceptibility of buildings or cars to damage. With regard to the climate forecasts for the coming years, it is important to take into account the fact that hail can mostly only be indirectly simulated in climate and weather forecast models. Current climate change predictions for the future merely indicate that the probability of the occurrence of hail is rising”.
For the update of its flood model, Deutsche Rück is utilising a joint development project with the German Insurance Association (GDV) to which it made a major contribution as a member of the group. The reinsurer then augments this model with claims data from its clients concerning the most recent major flood events, such as “Bernd” in 2021. “Our clients benefit from the fact that we have carried out a much deeper analysis of the claims data and subsequently developed in-house claims functions for this market model, which we use to model client portfolios”, says Meike Müller, Natural Hazards Analyst at Deutsche Rück’s NatCat Centre. The update will be available for the 2025/26 renewal.
With regard to climate change, it is a similar story: the measurement series do not currently indicate any clear trends that attest to an increase in the flood risk as a result of climate change. “We have used various methods to analyse water level data from over 1,800 measuring points over a period of nearly 70 years. The German runoff-data show no clear tendencies. There are increases and decreases in discharge, but both have mostly been statistically insignificant so far”, explains Müller. However, the climate forecasts that suggest an increase in the flood risk are less ambiguous than those regarding storms and hail.
Despite this, there is considerable variability in the results – and the trends are widely divergent depending on the portfolio of the primary insurer. In addition, the new model gives greater consideration to topographic conditions, which can have an impact on the risk assessment and potential claims exposure.
Deutsche Rück is also in the process of launching an update for its earthquake model. To this end, the company has been working in close collaboration with the scientific community. In a joint project with the German Research Centre for Geosciences GFZ Helmholtz in Potsdam, a risk model was developed for use in the insurance industry. Damage modelling has been developed in collaboration with the Bauhaus University Weimar.
“The model uses current methodological approaches and incorporates the latest research on the earthquake risk in Germany”, reports Dr Thomas Bistry, expert at Deutsche Rück’s NatCat Centre. For example, the update considers weighted combinations of different model parameterisations and, as a special feature, uses a seismic fault model for the Lower Rhine region, an area that is particularly at risk of earthquakes.
The new model therefore delivers well-founded and realistic estimates of the probability of occurrence and the amount of possible earthquake damage in Germany. Simulations of historical earthquake events demonstrate the enormous potential for damage that exists in the particularly at-risk regions of Baden-Württemberg and – due to the high concentration of values – the Cologne and Aachen region.
With these and other comprehensive updates, Deutsche Rück is optimising its risk modelling in its core business of natural hazards – a critical undertaking against the backdrop of climate change. Thanks to the expertise it has accumulated over many years in the in-house development of risk models for the German market, Deutsche Rück is capable of optimally evaluating the quality of external risk models. In international markets where the reinsurer does not operate with proprietary models, this know-how is essential for the company’s own risk assessment processes when it comes to evaluating customer portfolios and providing consultation services.
Times have been tough for German motor vehicle insurers in recent years. Claims inflation has given rise to significant technical losses, and the recovery is proceeding at a sluggish pace. The return to profitability is still some way off in all areas. And even when achieved, the claims burden for repairs will remain high. In the past some insurers have even reached the limits of their capacity to cope with the high volume of claims, especially following accumulation events like major hail damage. Extreme weather events have always had the potential to challenge clients, brokers and insurers in equal measure.
Against this backdrop, many insurers are considering whether the increased use of artificial intelligence in motor vehicle claims management could be a solution to these problems. The enormous hype around AI that has gripped the industry in recent years has somewhat subsided. Nevertheless, the enticing prospect of accelerating claims settlement processes using AI solutions and reducing costs is at the front of many insurers’ minds.
“Insurers are more open to the practical application of AI today than they were in the past”, says Sascha Meyer, Head of Motor Vehicle Market, Product and Claims Management at the Association of German Public Insurers. “The issue is not seen as a threat scenario, but as an opportunity scenario”. However, it is important to avoid being swept up in blind enthusiasm, the expert warns. Initially, many insurers had a vision of fully automating claims processing with the aid of AI. However, on the German market at least, this idea has not yet really progressed beyond the testbed and trial stages. With the continuous development of the technology and the gradual accumulation of experience in using it, clearer fields of application are now emerging. Meyer therefore recommends a realistic perspective for the deployment of AI in claims settlement. When it comes to handling large quantities of information, it should essentially be about supporting people in decision-making processes. And due to the growing shortage of skilled staff in the coming years, the application of AI is also an opportunity to retain and make better use of the expertise of current claims handlers in future.
Moreover, it is conceivable that AI could provide assistance in sub-processes when handling mass claims. “After a major hailstorm, AI can apply intelligent controls to further automate the arrangement of appointments for necessary damage assessments and thus contribute to improved scheduling logistics. AI as an instrument for optimised scheduling would also boost client satisfaction. Ultimately, clients expect a quick response to their damage claim”.
Sascha Meyer, Association of German Public Insurers
In Meyer’s opinion, client expectations are an important aspect to consider regarding the use of AI in claims settlement. Many clients have now come to appreciate the merits of using a chat bot to address their queries. “But when an insured event occurs, face-to-face consultations are still highly valued. In this regard, many clients see the insurer and its claims handlers as a provider of support in an emergency”. The fully automated, AI-driven processing of simple claims could free up the capacities that insurers need in order to provide personal assistance for more complex claims. Empathy also plays a major role, especially when processing larger claims: the insurer is tasked with answering the client’s questions, providing reassurance, allaying fears and clarifying any outstanding issues. Personal meetings will continue to be the best option for resolving such matters going forward.
One key application of AI in claims management is fraud detection. If insurers use AI to stave off fraudulent claims in the interests of their honest clients, thereby protecting the insured collective, this is a strong argument for using the technology, argues Meyer. At the same time, of course, fraudsters are also making greater use of AI in order to manipulate damage photos and invoices, for example.
Ultimately, the further development of AI may also help to establish new solutions to the mounting challenges in claims management, such as the shortage of skilled staff and the management of accumulation events, says Meyer. “Together with the claims manager who act as advocates for their insurance clients, AI-assisted processes will also help to maintain the insurers’ accustomed high qualitiy standard in claims processing in future."
Some European markets are playing a pioneering role in the use of AI in claims settlement. Slovenia is one of them. The market leader there, Zavarovalnica Triglav, is already using AI in all client areas, from sales marketing through underwriting and claims processing to client communication. One prerequisite for the successful deployment of AI is an optimal use of cloud computing – but only within a secure, proprietary cloud environment – says Gregor Kovačič, Executive Director Digital Operations and Client Experience Division at Triglav. Another is access to the necessary data – including via suitable interfaces to legacy systems if necessary.
With regard to motor vehicle claims settlement, Kovačič sees full automation using AI as the major goal for the future. “We are approaching this objective little by little, but we still have a long way to go”. The vision is for AI to be capable of identifying and assessing damage as well as initiating the necessary repairs or financial settlements.
It took Zavarovalnica Triglav three years to reach this goal. After two years, it became clear that the algorithms being used were not functioning optimally and that the process would have to be completely redesigned. However, failures and learning from mistakes are also important aspects when dealing with AI, emphasises Kovačič. Having a willingness to innovate and the courage to experiment is the right recipe for success when introducing AI into a company’s culture.
The new model at Triglav has been delivering positive results for a year: “achieving a quality comparable to that of our human claims handlers”. Nevertheless, AI is only being used in around 20 to 30 percent of claims. It primarily allows the management of mass claims to be automated. This makes hail damage claims easy to process, for example. By contrast, using AI to record and assess “internal damage” to a car resulting from an accident remains a challenge.
However, the model also has limitations when it comes to simple claims. The results will not be optimal if the damage photos do not meet the specifications and are taken from the wrong angle. There is also a risk of attempted fraud. In this regard, the insurer relies on various control mechanisms, points out Kovačič. For example, clients can only submit damage photos via a mobile app specified by the insurer. The images are then transferred directly to the insurer from the app, to exclude the possibility of manipulation.
Gregor Kovačič, Zavarovalnica Triglav
Kovačič also believes that human contact still plays a crucial role in claims settlement. AI is not yet capable of empathy, and clients would not have faith in a purely AI-driven claims settlement process. “People want to know: ‘Is this the right decision for me?’ This requires a human to confirm whether they have done everything properly and that the whole process is running smoothly”.
Zavarovalnica Triglav is currently developing algorithms that guide the client through the entire claims settlement process. But it will still take some time until AI is able to inspire the necessary confidence in clients – unless the solutions become significantly better and more capable of empathy. In Kovačič’s view, this could already be the case in the next couple of years and this would take the use of AI in the processing of motor vehicle claims to another level.
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Published in July 2025
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