The 26th of March marks a significant milestone for the proposed EU universal PFAS restriction. The proposed restriction comes from the national authorities of the Netherlands, Germany, Denmark, Norway and Sweden and covers more than 10 000 PFAS across a wide range of uses. This date marks the publication of the Risk Assessment Committee (RAC) opinion and the Socio-Economic Analysis Committee (SEAC) draft opinion. The publication of the SEAC draft opinion, officially launches a 60-day public consultation period ending on 25th of May 2026. This is the last chance to comment on the proposed restriction!
While both opinions support an EU-wide restriction on the manufacture, placing on the market and use of PFAS, they do hold different opinions on the extent of derogations. RAC considers a full ban to be more effective, suggesting if any exemptions are granted, they must be accompanied by strict risk management measures. These measures include site-specific PFAS management plans for manufacturers and industrial users, with monitoring of emissions, supply-chain communication on PFAS use, clear consumer labelling and instructions for safe use and disposal. RAC also calls for Industrial sites to report emissions to ECHA.
While SEAC draft opinion also supports risk management measures, based on available information, they could not conclude whether these specific measures are proportionate. SEAC concluded that a full PFAS ban “is likely not proportionate”. Instead, supporting a ban with use specific derogations. However, while SEAC have supported derogations, they have expressed concerns over time unlimited derogations, instead supporting time-limited derogations for all uses to ensure eventual phase-out.
Public consultation
SEAC is expected to adopt its final opinion at the end of this year, after they have reviewed the comments from the public consultation. This consultation is limited to socio-economic
impacts, the availability of alternatives, and the feasibility of substitution.
The format of the final consultation on the SEAC draft opinion is different from the consultation that occurred in 2023. Instead, it will take the form of a structured survey for the specific sectors evaluated by both committees, and one general survey for other industries.
ECHA has published consultation guidelines to help contributors prepare and submit relevant information. This includes a map of PFAS sectors of use with a description of the different uses and applications evaluated by SEAC. In addition ECHA have developed a Q&A document specific to this restriction proposal.
Once the opinions are formally submitted to the Commission at the end of 2026, the Commission is required to prepare a draft amendment, generally expected within 3 months of receiving the final opinions, after which the majority of Member States must vote in favour of the proposal. A positive vote requires a qualified majority, meaning 55% of EU countries representing at least 65% of the total EU population.
Published March 30th, 2026
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