On 20 August 2025, ECHA published the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under EU REACH, which was submitted by the 5 National Authorities (Dossier Submitter). The restriction proposal was originally submitted to ECHA in 2023 and aims to reduce PFAS emissions into the environment.
Following formal consultation in 2023 and heated debates among the industry, the initial restriction proposal was updated to account for over 5,600 scientific and technical comments from third parties and newly gathered evidence.
In addition to the restriction update from the Dossier Submitter, the Committees’ (RAC & SEAC) evaluation was being carried out in batches, focusing on the 14 different sectors analysed in the original restriction proposal, as well as PFAS manufacturing and horizontal issues. These original sectors are ski wax, consumer mixtures and miscellaneous consumer articles, cosmetics, metal plating and manufacture of metal products, food contact materials and packaging, TULAC (textiles, upholstery, leather, apparel and carpets), petroleum and mining, construction products, applications of fluorinated gases, transport, energy, medical devices, lubricants, electronics and semi-conductors.
Response to Consultation
Eight additional sectors were assessed by the Dossier Submitter, which are now incorporated in the updated restriction proposal,
- printing, sealing, and machinery applications
- medical applications,
- military applications, explosives,
- technical textiles,
- broader industrial uses, such as solvents and catalysts
This updated report, will form the basis for the Committees’ opinions. The Dossier Submitter increased the number of derogations from 26 to 74, including for fluoropolymers. It provides a 3rd option (beyond a full ban or a ban with time-limited derogations), that would permit continued use in certain applications where risks can be controlled through alternative measures, provided they meet strict operating conditions that minimise emissions. The restriction proposal may still be updated further, based on the evaluation of the committees.
Timeline
ECHA clarified the timelines on the 27th August 2025, where they reaffirmed the commitment made in the Chemicals Industry Action Plan adopted on 8 July 2025 that “The scientific assessment of the Universal PFAS restriction by the ECHA’s committees is ongoing and scheduled to conclude in 2026“. They warned to include an additional 8 sectors into the Committees’ evaluations now would require significant time beyond 2026. Therefore, in the ongoing procedure, the Committees will not carry out a sector specific evaluation of these further eight sectors. However, the evaluation of horizontal issues will cover, amongst others, the hazard assessment and risk management measures of general applicability that are able to monitor and limit emissions of PFAS to the environment (e.g. reporting requirements, PFAS management plan). This plan has come under fire from NGOs such as ChemSec responding with “If the Committee for Risk Assessment (RAC) and the Committee for Socio-Economic Analysis (SEAC) omit the sectors from their opinion, the Commission would not have the full picture when shaping the final restriction proposal”. In order to meet the commitment to deliver the final RAC and SEAC opinions to the European Commission in 2026, ECHA will finalise the RAC opinion and carry out the consultation on the SEAC draft opinion in the first half of 2026. ECHA stated “it is expected that the final RAC and SEAC opinions, in combination with the updated restriction proposal will give the European Commission the possibility to consider in its decision making how to best address the different use sectors (14 sectors plus the additional eight sectors), PFAS manufacturing and horizontal issues.”
Published September 4th, 2025
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