When the Environmental Defense Fund (EDF) emailed me in December, hoping to daylight a manufacturer filing an anonymous application to use a toxic chemical, the message carried the sort of dire rhetoric that the EDF has, in past campaigns, unleashed on Dow Chemical Company and DuPont. The phrases “lung waterproofing” and “concern for systemic and male reproductive toxicity” glinted on my screen alongside a note from the EDF’s lead senior scientist, Richard Denison. Denison described a new product whose key chemical ingredient was rejected for commercial use by the Environmental Protection Agency (EPA) late in 2018, and then oddly approved by the same agency last June, through a decision-making process that is largely hidden from the public.

What was this noxious new stuff he was decrying? Insecticide? A solvent to degrease construction machinery? No, Denison and the EDF were focused on a lightning-fast ski wax.

The chemically complex glide wax was developed by Swix Sport, a venerated 74-year-old Norwegian company that today commands a 60 percent market share in the $150 million global ski-wax industry. Swix’s new wax compound has application for skiers in all disciplines and also for snowboarders, but it’s aimed mainly at nordic ski racers, who can save minutes in a single 50-kilometer event if their skis glide well. The wax’s active ingredient is a chemical whose tight molecular bonds, yoking fluorine and carbon, are super stable and thus both impervious to ski-slowing moisture and very resistant to breaking down. This chemical belongs to a large and notorious family of per- and polyfluoroalkyl substances, which are collectively known as PFAS. Often called “forever chemicals,” PFAS are sold in vastly greater quantities in firefighting foams and as a waterproof coating for frying pans, raincoats, and pizza-delivery boxes.

Fluoro wax has been a staple of cross-country racing since the late 1980s. Still, Swix’s rollout of a new fluoro seems oddly timed. The EPA has found PFAS to cause liver and kidney damage as well as cancer and tumors in lab animals. A just-released film, Dark Waters, stars Mark Ruffalo as an intrepid lawyer battling DuPont in the early 2000s after the chemical giant began making a PFAS-based product, Teflon, at its factory in Parkersburg, West Virginia, where chronic illness and untimely deaths spiked among nearby residents. Several states, New York and Ohio among them, have filed lawsuits that seek compensation for health problems caused by drinking water polluted by PFAS. DuPont and 3M are frequently defendants in these suits.

The ski world is conducting its own clampdown on fluoro wax. The FIS, the sport’s international governing body, which oversees nordic skiing’s World Cup, announced in November that it will begin enforcing a ban on fluoro in November 2020, citing its “negative environmental and health impact.” The FIS has yet to decide on penalties, but in many high school and collegiate nordic ski leagues in the U.S., along with youth and amateur leagues in Europe, fluoro is already banned. Scientists have found it lacing the snow on nordic trails in Norway, and while fluoro might have scant ill effects on casual ski racers who wax with it twice a year, a 2010 Scandinavian study showed that World Cup ski technicians had on average 45 times as much fluorocarbon in their blood as nonskiers.

Fluoro wax has been a staple of cross-country racing since the late 1980s. Still, Swix’s rollout of a new fluoro seems oddly timed.

And yet, according to documents provided to Outside by the EDF, Swix approached the EPA in November 2018 for approval of a new fluorocarbon chemical. (Later, a spokesperson for the company would inform Outside that the new compound was planned “for use in a small number of high performance waxes while [Swix] transitions to fully fluoro-free product lines.”) The company was able to seek what’s called a low volume exemption (LVE) and bypass the agency’s standard process for evaluating a new chemical, because it planned to produce less than the EPA’s threshold of 10,000 kilograms (approximately 22,000 pounds) of material a year. As such, the wax maker wasn’t required to make public its company name or the chemical makeup of its new product.

The EPA denied Swix’s request for approval, saying that the unnamed chemical would have a “high environmental hazard.” But Swix fought the EPA’s ruling, hiring a Washington law firm—Wiley Rein, which has also represented auto tire makers and the plastics industry—to write the agency and paint a dire picture of what would happen if approval weren’t granted. If the agency denied the exemption, Wiley Rein said, Swix might have “no choice but to revert to more environmentally harmful” wax-making processes simply to “stay in business.” The EPA wrote back two months later, reporting that it had “reconsidered its assessment.” It granted Swix a three-year exemption in a letter that equivocated over the wax’s likelihood to cause lung waterproofing, a condition in which the tiny air sacs in the lungs, the alveoli, become dysfunctional and unable to pump oxygen into the blood. The EPA said lung waterproofing was “not expected” before noting that “uncertainty” surrounded the issue.

In a written statement to Outside, a publicist contracted by Swix focused on the chemistry of its new compound, which is now incorporated into current versions of Swix’s fluorinated race waxes, and selling in shops and on the web. (Flourinated waxes make up about 30 percent of the products Swix sells.) She noted that it’s made of “C6 fluorocarbons,” which “are better for both the environment and for human health than C8 fluorocarbons.”

C6? C8? There are, in broad terms, two categories of ski wax containing PFAS. Historically more prevalent, C8 wax boasts eight fully fluorinated carbon molecules in its long backbone. C6 wax features only six such molecules and breaks down more easily, though how much easier is still unclear to scientists. A 2015 Food and Drug Administration report found that C6 lacked the “biopersistence and potent systemic and reproductive toxicity that are characteristic of C8 fluorocarbons,” but also acknowledged that few studies have been done on C6 toxicity and stressed that it’s not clear yet whether C6 is a “safer alternative.” The European Chemicals Agency (ECHA), a policymaking branch of the European Union, has called C6 “a substance of very high concern due to its very persistent and very bioaccumulating properties.” In July, the ECHA will begin enforcing its ban on the sale, manufacture, and import of all “nonessential” C8 products in Europe. It is now contemplating a ban of C6.

Swix is certainly attuned to the dangers of fluoro. The company has already spent ten years and hundreds of thousands of dollars trying to design a fast fluoro-free wax, and in September—three months after Swix gained approval from the EPA for its C6 fluorocarbon—Steve Poulin, CEO of the subsidiary Swix Sport USA, told SkiRacing.com, “What I want to happen is a fluoro-free environment. I am pushing Norway for a fluoro-free environment and a fluoro-free company. We need to lead by example, because we are a market leader.”

Swix did not break any laws by lobbying the EPA to let it introduce a new fluoro wax. But its hiring of Wiley Rein to appeal the EPA’s initial ruling certainly seems at odds with its eco-friendly rhetoric, as does the company’s continued use of fluoro at all. Both make business sense, though: despite the fact that the new wax won’t be legal on the elite racing circuit next winter, amateur racers will still use it in great quantities.

In its statement to Outside, Swix depicted its new use of C6 chemistry as “a short-term bridge to get the company to its ultimate goal of producing a high-performance fluoro-free wax by 2022. While the company is committed to the transition to fluoro-free, the new technology is not yet ready for commercial use.”

Despite what we know about fluoro’s environmental and health risks, nordic skiing isn’t likely to be free of it any time soon. There is simply no existing ski wax that is as hydrophobic—and hence as fast—as fluoro. Every serious skier out there has several bars of it in their wax kit, even if they’re fated to no glory greater than 11th place in their age bracket at the local 10K. And it’s likely that not a single world-class nordic skier is fluoro-free. Stores still sell the wax that the FIS is poised to ban, and the consumer who wants to avoid the most harmful stuff probably lacks the investigative impulses and chemistry knowledge to decipher wax makers’ careful fluoro messaging.

In Norway, a tiny nation that boasts one of the world’s top cross-country ski teams, the media is trying to help. In a scathing, ongoing series of stories on fluoro, the Oslo-based newspaper Dagbladet has argued that, while the industry says it has largely switched to a “so-called C6 technology,” science proves otherwise. (Waxes aren’t labeled with details of their chemical contents, let alone whether they’re C8 or C6 fluorocarbons.) In reporting a story that ran last month, Dagbladet bought 11 fluorinated waxes from ski shops, then took them to a chemistry lab at the University of Stockholm for a test of whether their C8 content exceeded the limit set by the ECHA—25 nanograms per gram. The lab found that the waxes’ C8 values were, on average, 134 times higher than the 2020 limit. Swix waxes were not the worst wax currently on the shelves, though—that distinction went to a Swiss company called Toko, which produced a wax that is 1,215 times over the current limit. (Swix bought Toko in 2010. In response to Dagbladet and Outside, the company said the wax was produced in 2009, is no longer sold, and should not have been on shelves when the publication did its test.)

The Dagbladet series alleged that “sky high” levels of a PFAS compound were found in the blood of workers at a now-defunct Italian factory called Miteni, which manufactured C8 wax for Swix as well as products for other companies. Ultimately, these workers suffered cancer, diabetes and cirrhosis, Dagbladet said, citing a 2019 study done by epidemiology researchers for the local government in Italy’s Veneto region. Miteni poisoned the drinking water of over 120,000 people, according to Dagbladet and a 2017 report by the World Health Organization.

In an email to Outside, Swix brand director Age Skinstad says that Swix’s current management knew nothing of the Miteni scandal until it was approached by Dagbladet in 2019. “Miteni didn’t inform Swix of the problems,” Skinstad said. “The way Miteni has acted is totally unacceptable and in breach of the contract Swix had with them.” Skinstad went on to suggest that even if Miteni caused environmental problems, it didn’t do so by making ski wax. Swix products constituted “a max. of 0.5% of the total production of Miteni and was not connected to the PFOA production,” he wrote to Outside, naming the particular PFAS chemical found in the workers’ blood.

The EDF hopes to highlight what it sees as the hypocrisy of a federal agency that now tolerates the corporate use of 86,000 chemicals.

Miteni went out of business in 2018, but products incorporating C8 are still manufactured in China. In the U.S., it’s still legal for any company, except those in the more heavily regulated carpet industry, to import it. C8 is still widely used by outdoor apparel makers. Only a few brands—Mountain Hardwear, for instance, and Patagonia—have transitioned to waterproofing with C6.

Most other makers of our foul-weather garments are unlikely to curtail their fluoro use anytime soon. Under President Donald Trump, the EPA has proven very friendly to the chemical industry. Last year it unveiled a new PFAS Action Plan, but critics have argued that it lacks teeth. “[It’s] all plan and no action,” wrote Scott Faber, a senior vice president for government affairs at the Environmental Working Group, in the newspaper The Hill. “Instead, it promises merely to ‘examine’ information about PFAS discharges. … EPA must still ‘determine’ whether to force utilities to filter PFAS from our water.”

“We’re very concerned that the EPA is allowing new chemicals onto the market without scrutinizing them enough,” says Richard Denison of the Environmental Defense Fund. What’s particularly troubling to Denison is the agency’s low-volume-exemption program, which has, since its inception in 1985, allowed applicants to cloak their identity. Each company submitting an LVE bid can opt to say it contains Confidential Business Information (CBI) and thus should remain private. If the EPA allows the CBI claim, the bid (and thus the company) are known to the public solely by its case number. Swix’s bid was numbered LVE L-19-0033, and you’re reading about it now only because an anonymous whistle-blower divulged the number to the EDF, which in turn filed a Freedom of Information Act request for files relating to that number, eventually sharing this information with journalists.

Denison stresses that his group didn’t set out to shame the ski industry. Instead, the EDF hopes to highlight what it sees as the hypocrisy of a federal agency that now tolerates the corporate use of 86,000 chemicals and, in Denison’s view, routinely “cuts corners,” green-lighting 89 percent of all the LVE applications it’s received since tweaking toxic-chemical rules in 2016.

“We were interested,” Denison says, “in finding a case in which [the] EPA denied use of a chemical and then decided to approve it, despite its own staff’s recommendations.”

If all this political strategizing sounds far removed from the sylvan splendors of gliding through the woods, have faith, for there are options for nordic skiers who want to avoid fluoro waxes. Hydrocarbon-based ski wax, which is sold by Swix and several other brands, breaks down much quicker than fluoro does, and it tends to be cheaper. Next fall, Swix also plans to introduce a new, fluoro-free race wax called Pure Marathon, which it claims will be “the most durable, eco-friendly wax available today.” Its chemical makeup is a proprietary secret, but Swix says it will be faster (and more expensive) than hydrocarbon. Meanwhile, an array of super woke, eco-friendly glide waxes have recently emerged on the market. Green Ice Wax, for example, sells “plant-based” waxes composed “entirely of renewable resources,” according to company literature.

For the foreseeable future, though, fluorinated wax will continue to sing with a dark allure to the nordic ski world. It remains legal at many recreational races, among them American Birkebeiner, which draws more than 10,000 competitors to Wisconsin each February, and its exit from school and college leagues is far from complete. “For anyone who wants to go fast, it remains a necessary evil,” says University of Vermont nordic ski coach Patrick Weaver, who this winter will don chemically resistant gloves and a $1,200 ventilated face shield to fluoro-wax 250 pairs of skis for his athletes. “Most of the ski world wants to get rid of it, but on wet days, if you don’t use fluoro, you’ll be greatly disadvantaged,” he adds. “Until it’s gone from the sport, fluoro wax is going to be tempting.”

On the FIS’s World Cup circuit, where top skiers rake in millions of dollars a year, the temptation could lead to a different problem. With C8 now banned, and the ban of C6 likely imminent, will there be cheating?

Under President Donald Trump, the EPA has proven very friendly to the chemical industry. Last year it unveiled a new PFAS Action Plan, but critics have argued that it lacks teeth.

Illegal blood doping and steroid use have been nagging problems on cross-country’s World Cup circuit for decades—and currently, the FIS has no streamlined system for testing whether a ski is fluorinated. In enforcing its ban, the governing body has engaged an Oslo lab, the Norwegian Institute for Air Research (NILU), which has developed a method for detecting fluorine in skis by using an ungainly washing-machine-size X-ray device. But the FIS still hasn’t “validated” this system, says Martin Schlabach, a senior chemist for the NILU. It also needs to spend about $200,000 to develop a mobile X-ray scanner capable of testing skis at a prerace starting line rather than at a remote lab, which could only deliver results days later.

As a stopgap, the NILU may open the 2020–21 season using specially trained sniffer dogs to suss out whether skis are fluorinated. “The dogs would give us a strong indication, but they would not be a final measure,” Schlabach notes.

Schlabach will, of course, be fighting an age-old human impulse. When I recently phoned Vince Rosetta, who chronicles World Cup nordic racing on his popular YouTube channel, Skiing Vinnie, his mind went at once to how, exactly, skiers will cheat the new rules.

“I can assure you that right now, in a basement somewhere, there are people focused on nothing but beating the system,” he said. “Maybe they’re looking for a masking agent—something to hide the smell of fluoro on skis so the dogs can’t detect it. Maybe they’re trying to think up a way to squirt some liquid fluoro onto skis, prerace, right after the test is done. We’ll only know what they’re up to after the first person gets caught.”