Universal PFAS restriction proposal : ECHA expands evaluation and considers targeted exemptions
On August 20, 2025, the European Chemicals Agency (ECHA) published an updated proposal to the universal PFAS restriction REACH. The revision comes after authorities in Denmark, Germany, the Netherlands, Norway, and Sweden spent months reviewing more than 5,600 scientific and technical comments gathered during a public consultation in 2023. Their new background report broadens the scope of the original plan, adding assessments for eight sectors that had not been explicitly covered before, including printing, sealing, machinery, technical textiles, explosives, military applications, other medical applications such as immediate packaging and excipients for pharmaceuticals, broader industrial uses, such as solvents and catalysts.
Revising the EU’s Universal PFAS Restriction Under REACH
The updated proposal also signals a shift from the idea of a blanket ban toward a more nuanced approach. While a comprehensive phase-out remains on the table, the five authorities now consider tailored restrictions that could allow PFAS to remain in use under strict conditions where alternatives are lacking and risks can be managed, particularly in industries such as PFAS manufacturing, semiconductors, transport, energy, sealing applications, machinery applications and technical textiles. This balance reflects both the urgency of tackling persistent environmental and health risks and the recognition that these chemicals play a role in critical technologies that are difficult to replace overnight.
Why this update matters
ECHA’s scientific committees are now examining the updated restriction from two angles: one assessing risks to health and the environment, the other weighing socio-economic impacts.
They are assessing:
- The risks that PFAS pose to human health and the environment.
- The socio-economic impacts of a restriction at Union level.
Preliminary conclusions indicate that, while a restriction would significantly reduce exposure to PFAS, some essential uses currently lack technically or economically viable alternatives
The European Commission, , has also communicated that ‘The scientific assessment of the Universal PFAS restriction by the ECHA’s committees is ongoing and scheduled to conclude in 2026. The Commission is committed to presenting a proposal as soon as possible after receiving ECHA’s opinion, with the overall objective of minimising PFAS emissions’.
RAC and SEAC have already made substantial progress in developing their opinions on the 14 sectors covered by the original restriction proposal, as well as on PFAS manufacturing and a number of horizontal issues. Including an additional eight sectors in the Committees’ evaluations at this stage, however, would significantly delay completion of the opinion, extending the process well beyond 2026. For this reason, the Committees will not undertake sector-specific evaluations for these additional eight sectors within the current procedure. Instead, their assessment of horizontal issues will address, among other aspects, the hazard assessment and risk management measures of general applicability that can be used to monitor and limit PFAS emissions to the environment use.
The final consolidated opinion will be transmitted to the European Commission, which, in consultation with the Member States and the European Parliament, will decide on the appropriate regulatory measures.
On August 20, 2025, the European Chemicals Agency (ECHA) published an updated proposal to the universal PFAS restriction REACH. The revision comes after authorities in Denmark, Germany, the Netherlands, Norway, and Sweden spent months reviewing more than 5,600 scientific and technical comments gathered during a public consultation in 2023. Their new background report broadens the scope of the original plan, adding assessments for eight sectors that had not been explicitly covered before, including printing, sealing, machinery, technical textiles, explosives, military applications, other medical applications such as immediate packaging and excipients for pharmaceuticals, broader industrial uses, such as solvents and catalysts.
Revising the EU’s Universal PFAS Restriction Under REACH
The updated proposal also signals a shift from the idea of a blanket ban toward a more nuanced approach. While a comprehensive phase-out remains on the table, the five authorities now consider tailored restrictions that could allow PFAS to remain in use under strict conditions where alternatives are lacking and risks can be managed, particularly in industries such as PFAS manufacturing, semiconductors, transport, energy, sealing applications, machinery applications and technical textiles. This balance reflects both the urgency of tackling persistent environmental and health risks and the recognition that these chemicals play a role in critical technologies that are difficult to replace overnight.
Why this update matters
ECHA’s scientific committees are now examining the updated restriction from two angles: one assessing risks to health and the environment, the other weighing socio-economic impacts.
They are assessing:
- The risks that PFAS pose to human health and the environment.
- The socio-economic impacts of a restriction at Union level.
Preliminary conclusions indicate that, while a restriction would significantly reduce exposure to PFAS, some essential uses currently lack technically or economically viable alternatives
The European Commission, , has also communicated that ‘The scientific assessment of the Universal PFAS restriction by the ECHA’s committees is ongoing and scheduled to conclude in 2026. The Commission is committed to presenting a proposal as soon as possible after receiving ECHA’s opinion, with the overall objective of minimising PFAS emissions’.
RAC and SEAC have already made substantial progress in developing their opinions on the 14 sectors covered by the original restriction proposal, as well as on PFAS manufacturing and a number of horizontal issues. Including an additional eight sectors in the Committees’ evaluations at this stage, however, would significantly delay completion of the opinion, extending the process well beyond 2026. For this reason, the Committees will not undertake sector-specific evaluations for these additional eight sectors within the current procedure. Instead, their assessment of horizontal issues will address, among other aspects, the hazard assessment and risk management measures of general applicability that can be used to monitor and limit PFAS emissions to the environment use.
The final consolidated opinion will be transmitted to the European Commission, which, in consultation with the Member States and the European Parliament, will decide on the appropriate regulatory measures.
