PFAS

Information on PFAS

03.02.2026

With the publication of the final report on the evaluation of 5,642 submissions on August 25, 2025, the European Chemicals Agency (ECHA) reached a first major 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 as well as environmental and economic impacts.

In addition to the two originally planned regulatory options—

Option 1: Ban and

Option 2: Ban with time-limited derogations—

the report intends to examine 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 evaluated by the Committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC). These include, among others:

Batteries
Fuel cells
Electrolyzers
Medical devices
Semiconductors
Fluoropolymers throughout their entire life cycle—from manufacture and use to end-of-life

With the introduction of this third regulatory option, ECHA is for the first time creating the basis for differentiated considerations of individual applications and entire groups of substances within the framework of PFAS regulation. Fluoropolymers also fall into this category when considering their complete life cycle, as no suitable alternatives are currently available for them. This represents an important success of the joint efforts to counteract a blanket PFAS ban approach and to highlight the special importance of fluoropolymers.

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

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

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

Since ECHA’s official PFAS regulatory process will still take several years, we advocate for a simplification of REACH as well as for clear and reliable framework conditions in PFAS regulation—as announced as a priority by the new EU Commission President.

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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/en/-/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 derogations”), a 3rd 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 3rd regulatory option is to be examined (and evaluated by RAC and SEAC) for various uses for which no suitable alternatives are available:

Batteries
Fuel cells
Electrolyzers
Medical devices
Semiconductors
Fluoropolymers during manufacture, service life, and at the end of service life

By introducing a 3rd regulatory option, ECHA has created the prerequisite for application areas and entire groups of substances to be exempted from PFAS regulation. Fluoropolymers also fall into this group of applications and products for which no alternatives are available, specifically when considering their complete life cycle. This is a success of our joint effort, with a total of 5,642 submissions as part of the public discussion, to oppose the blanket PFAS ban approach and to highlight the special importance of fluoropolymers.

Download:

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