PFAS

03.02.2026

With the publication of the final report evaluating 5,642 submissions on August 25, 2025, the European Chemicals Agency (ECHA) has reached an important first milestone in the PFAS regulatory process.

The comments received during the consultation provided extensive detailed information. These had a significant influence on the committees’ revised assessments, particularly with regard to possible alternatives and environmental and economic impacts.

In addition to the two regulatory options originally planned –

Option 1: Ban and

Option 2: Ban with time-limited exemptions –

the report proposes to consider a third regulatory option:

Option 3: Conditions that must be met to allow the continued manufacture, placing on the market, or use of PFAS instead of a ban.

This third option is intended to apply to certain applications for which no suitable alternatives are currently available and which have been assessed by the Committees for Risk Assessment (RAC) and Socioeconomic Analysis (SEAC). These include, among others:

  • batteries
  • fuel cells
  • electrolysers
  • medical devices
  • semiconductors
  • Fluoropolymers during manufacture, during service life and at the end of service life

With the introduction of this third regulatory option, ECHA is laying the foundation for differentiated consideration of individual applications and entire substance groups within the framework of PFAS regulation for the first time. Fluoropolymers also fall into this category when considering their entire life cycle, as there are currently no suitable alternatives available for them. This represents an important success in the joint efforts to counteract a blanket ban on PFAS and highlight the special significance of fluoropolymers.

Helsinki, December 17, 2025 – Building on previous assessments and initial preliminary conclusions, RAC and SEAC are currently reviewing the proposed restriction at several levels in parallel. These include possible concentration limits, PFAS management plans, recycling and replacement concepts, issues of practicability and monitorability, and an assessment of whether the proposed restriction is the most appropriate EU-wide measure to mitigate PFAS risks.

Based on the submissions, RAC and SEAC are preparing concrete draft opinions on the applications for authorization. In addition, the RAC has adopted its first harmonized classification and labeling opinion on a new hazard class: very persistent, very bioaccumulative (vPvB). Further details can be found in the annexes.

The 60-day stakeholder consultation on the draft opinions is expected to begin in March 2026, shortly after their adoption by RAC and SEAC.

Further information:

https://echa.europa.eu/de/-/highlights-from-december-2025-rac-and-seac-meetings

As ECHA’s official PFAS regulatory process will take several more years to complete, we advocate simplifying REACH and establishing clear and reliable framework conditions for PFAS regulation, as announced as a priority by the new President of the European Commission.

If you have any questions, please contact our Technical Sales Department:

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Annex and progress update on the per- and polyfluoroalkyl substances (PFAS) restriction process

27.01.2025

The five countries leading the universal PFAS restriction have published a progress report on the restriction of PFAS: https://echa.europa.eu/de/-/echa-and-five-european-countries-issue-progress-update-on-pfas-restriction

According to the report, in addition to the two regulatory options already considered (option 1 ‘ban’, option 2: ‘ban with time-limited exemptions’), a third regulatory option (option 3: ‘conditions that must be met to allow the continued manufacture, placing on the market or use of PFAS instead of a ban’) is to be considered for various areas of use.

This third regulatory option is to be considered (and assessed by RAC and SEAC) for various uses for which no suitable alternatives are available:

  • batteries
  • fuel cells
  • electrolysers
  • medical devices
  • semiconductors
  • Fluoropolymers during manufacture, during service life and at the end of service life

By introducing a third regulatory option, ECHA has created the prerequisite for exempting areas of application and entire groups of substances from PFAS regulation. This group of applications and products for which no alternatives are available also includes fluoropolymers, taking into account their entire life cycle. This is a success of our joint effort, with a total of 5,642 submissions in the public debate, to oppose the blanket PFAS ban approach and emphasise the particular importance of fluoropolymers.

As the official PFAS regulatory process of the ECHA will still take years, we urge the EU Commission to make a prompt preliminary decision in line with this restructuring of the submissions. The simplification of REACH and the creation of clarity in PFAS regulation are the top priorities announced by the new EU Commission President.

If you have any questions, please contact our Technical Sales Department:

Download:

Progress update on the per- and polyfluoroalkyl substances (PFAS) restriction process

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