PFAS Restriction: the RAC final and SEAC draft opinions and next steps

In 2023, five European countries—Germany, Netherlands, Denmark, Sweden, and Norway—submitted a joint proposal to restrict PFAS across the European Union under the REACH regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals). This marked a major shift from targeting individual substances to addressing the entire PFAS group.

The proposal was formally submitted to the European Chemicals Agency (ECHA), which is responsible for evaluating chemical risks and drafting regulatory decisions in the EU. It covers thousands of PFAS substances, aiming to restrict or ban their manufacture, use, and placement on the market.

The two ECHA committees have assessed the Universal PFAS restriction proposal from the five national authorities. The Risk Assessment Committee (RAC) evaluated whether PFAS pose a significant risk to humans and the environment, assess the scientific evidence (toxicity, persistence, bioaccumulation, exposure) and determining if an EU-wide restriction is justified based on these risks.

The Socio-Economic Analysis Committee (SEAC) looks at the economic and societal impacts of the restriction by evaluating costs for industry (e.g., reformulation, substitution, compliance), assessing benefits (e.g., reduced healthcare costs, environmental protection), comparing different restriction options and transition periods and impacts on jobs, innovation, and supply chains.

The SEAC evaluated the socio-economic impact of the proposed restriction with particular attention to proportionality and cost/benefit and has published its draft opinion which is subject to a 60 day consultation process concluded on 25 May 2026. There are two consultation formats: i) a sector-specific survey which focuses on PFAS use cases in products, statistical data on PFAS usage, availability of alternatives and socio-economic impacts of a potential ban and ii) a general survey for open comments on any aspect of the SEAC opinion which allows feedback on PFAS uses not specifically assessed. This is the final opportunity for industry and stakeholders to provide socio-economic evidence before the committee adopts its final opinion expected before the end of 2026. ECHA will formally submit both opinions to the European Commission.  Based on the two final opinions, the Commission will propose a restriction for discussion and vote in the REACH committee, composed of EU member states.

ECHA summary: The RAC, in its final opinion, and the SEAC, in its draft opinion, support an EU-wide restriction, subject to specific derogations, on the manufacture, placing on the market and use of PFAS. The Committees also recommend that any restriction should be complemented by effective measures to minimise emissions. The scientific conclusions of RAC and the draft opinion of SEAC mark a major step toward EU-level measures on PFAS. See All news - ECHA.

The RAC final opinion: RAC concludes that PFAS pose growing risks to people and the environment. They are highly persistent, remaining in the environment for long periods, travelling long distances, contaminating groundwater and soil, while some cause serious health issues, such as cancer and reproductive harm. The Committee considers that regulatory measures currently in place are not sufficient to control their emissions and, therefore, further EU-wide regulatory action is needed to control these risks. RAC recommends risk management measures to minimise emissions if derogations for specific uses are confirmed by the decision makers.

The SEAC draft opinion: SEAC’s draft opinion highlights that PFAS are used in many different applications across Europe. EU-wide action is, therefore, needed to avoid trade distortions and maintain a level playing field in the internal market. The Committee considers that targeted derogations are needed for specific PFAS uses, when this is justified by the available evidence that alternatives are not available as well as by the assessment of costs and benefits, to ensure the restriction remains proportionate. The SEAC draft opinion also supports introducing risk management measures to minimise PFAS emissions for derogated uses, as recommended by RAC. However, based on currently available information, the Committee cannot conclude whether these specific measures are proportionate.

The RAC final opinion as it relates to F-gases (extracts)

• Based on the information on the expected emissions RAC concludes that the existing operational conditions and risk management measures are not sufficient to control the risks.
• Fluorinated gases in the scope of the proposed restriction that are currently used in significant quantities are also in the scope of the EU F-gas Regulation (Regulation (EU) 2024/573). While the F-gas Regulation applies to both HFCs and HFOs/HCFOs, its main focus is to prevent global warming. Therefore, part of its provisions are related to global warming potential. However, RAC also notes that several prohibitions of the F-gas Regulation apply to all fluorinated gases and represent a partial overlap with the current restriction proposal (e.g. domestic refrigeration, foams, technical aerosols).

The RAC comments that despite the ongoing efforts to reduce service life and end-of-life emissions (including the provisions of the F-gas Regulation), it can be considered that emissions in these life stages are still significant, and further emission reduction is required to control the related risks. However, RAC acknowledges that the prohibitions in the F-gas Regulation represent a potential overlap with the current PFAS restriction proposal. It also notes that another aspect is the ongoing decrease in leakage rates from HVACR equipment, which can be also at least partly attributed to the F-gas Regulation. The Dossier Submitter did not account for this aspect. Consequently, emissions may be overestimated. The information provided in the Background Document does not enable European Chemicals Agency’s Risk Assessment Committee (RAC) to assess the extent of overlap between the F-gas Regulation and the PFAS restriction proposal, nor to determine the resulting impact on emission reductions. As a consequence, RAC concludes that releases of PFAS in the sector “Applications of fluorinated gases” are not adequately controlled and should be minimised. The complete evaluation for application of F-gases is available here.

 The SEAC draft opinion as it relates to F-gases (extracts)

Mobile air conditioning (MAC) and transport refrigeration are assessed under “Transport” - see below.

SEAC identified significant overlaps with the F-gas Regulation which were not specifically addressed by the Dossier Submitter, therefore adopted an approach to take into account overlaps between the currently proposed restriction and the F-gas Regulation, as well as identify regulatory gaps for substances/applications which are not covered by either measure. This “scoping exercise” is part of the analysis of alternatives (section S-3) and informs SEAC’s assessment on costs, benefits, proportionality and derogations.

SEAC concludes that a REACH restriction remains the most appropriate risk management measure to address the concerns identified by the Dossier Submitter which are different from the F-gas Regulation (focused on global warming potential). In certain application-specific cases a restriction can be considered inappropriate for practical considerations, i.e. a prohibition under the F-gas Regulation indirectly already addresses (partially or fully) the risks identified by the Dossier Submitter.

The complete evaluation for application of F-gases is available here.

The SEAC draft opinion as it relates to transport

In the case of the use of fluorinated gases in mobile air-conditioning and transport refrigeration, SEAC notes that the F-gas Regulation (Regulation (EU) 2024/573) foresees the possible inclusion of prohibitions that target certain PFAS covered by the proposed restriction, but currently the concerns identified by the Dossier Submitter are not addressed and are in any case different from the F-gas Regulation (focused on global warming potential). Similarly, the Mobile Air Conditioning (MAC) Directive (2006/40/EC) also focuses on global warming potential (GWP) and only limits the use of fluorinated gases with a GWP > 150 in vehicle types M1 (passenger cars) and N1 class 1 (light commercial vehicles). Therefore, SEAC also concludes in these cases that a REACH restriction remains the most appropriate risk management measure.

SEAC concludes that non-PFAS alternatives have been identified, are already available and in use for certain transport applications. This is mostly the case for automotive vehicles for the transportation of passengers or goods/freight or other purpose by road (e.g. those falling under the European vehicle categories L, M, N and O). Further implementation of these alternatives will, however, still require some time due to the required redesign of the refrigerant circuits, which is only economically feasible at the start of a new model design cycle. As such, SEAC finds there to be sufficiently strong evidence for low substitution potential at entry into force.

It is unclear to what extent and in which timeframe non-PFAS alternatives can be implemented for transport vehicles and marine applications, excluding “automotive vehicles” covered above.

SEAC states there are several factors complicating its assessment for the use of fluorinated gases in transport HVACR. One of these is that the F-gas Regulation contains a review clause for mobile refrigeration equipment (article 35 point 3) which states that “by 1 July 2027, the Commission shall publish a report assessing whether cost-effective, technically feasible, energy-efficient and reliable alternatives exist, which make the replacement of fluorinated greenhouse gases possible in mobile refrigeration and mobile air-conditioning equipment, and where appropriate, put forward a legislative proposal to the European Parliament and to the Council to amend the list set out in Annex IV”.

The complete evaluation for transport is available here.