What you need to know about the updated PFAs restriction dossier
Europe is advancing efforts to regulate so-called “forever chemicals.”
A recent update to the European Union’s proposed restriction on per- and polyfluoroalkyl substances (PFASs) was published in August 2025 and it represents one of the most comprehensive and ambitious environmental regulatory initiatives ever developed within the REACH framework. This process has the potential to significantly influence manufacturing practices across a wide range of industries throughout Europe, including the automotive and cosmetics sectors [1].
The Background Document, comprising 3,300 pages, was prepared by regulatory authorities from Germany, the Netherlands, Denmark, Sweden, and Norway, and subsequently published by the European Chemicals Agency (ECHA). This document not only updates and expands upon the 2023 Annex XV report but also integrates feedback from more than 5,600 stakeholders. Furthermore, it provides an in-depth analysis of PFAS usage across 23 industrial sectors within Europe [2].
What is the problem?
PFASs, or “forever chemicals,” comprise over 10,000 synthetic substances used widely across industries for their durability, water and oil repellence, and resistance to heat and chemicals. Their persistence in the environment means that once released, they continue to circulate through air, soil, and water, contaminating ecosystems and entering the food chain.
Human exposure occurs primarily through contaminated food, drinking water, air, and consumer products. According to scientific studies, health risks linked to some PFAS exposure include effects on the liver, immune system, and reproductive health. From environmental perspectives, PFASs meet or exceed the “very persistent” (vP) criteria under REACH and exhibit properties similar to PBT/vPvB substances (persistent, bioaccumulative, and toxic or very persistent and very bioaccumulative). Their long-range transport potential means that PFASs can be found in remote areas far from their original sources [3].
Some scientific studies have concluded that PFAS substances have a range of properties, including toxicology and environmental effects. However, the Doddier Submitters conclude that there is no safe concentration threshold below which PFAS exposure is considered harmless, and conclude that any release constitutes an unacceptable risk. Therefore, the primary regulatory goal is to minimize emissions to the greatest extent possible [4].
Inside the EU’s Plan
To stop the accumulation, regulators are pushing for a group-wide restriction under REACH, which would ban or severely limit all PFASs as a class, rather than addressing individual compounds one by one.
The proposal outlines three possible regulatory paths:
- A full ban after an 18-month transition — the strictest but most economically disruptive option.
- A phased ban with time-limited exemptions (RO2)
- Allows continued use in specific applications for 6.5 or 13.5 years, depending on how soon substitutes can be found.
- Controlled use under strict emission caps (RO3) — applies mainly to PFAS manufacturing.
Who’s Affected?
The update provides a detailed, sector-by-sector analysis of PFAS use and emissions. Major sectors include transport, energy, construction, electronics, medical devices, textiles, lubricants, cosmetics and the RACHP sector as well. Each sector was evaluated for the availability of alternatives, costs, and emission reduction potential.
A key outcome of the updated assessment is a more nuanced approach to derogations—time-limited exemptions for uses with low substitution potential.
The path forward
The European Chemicals Agency’s scientific committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) are now reviewing the updated dossier. Their opinions will guide the European Commission and Member States, which will decide whether and how to implement the restriction.
The European Chemicals Agency plans to launch a consultation on the draft opinion of its Committee for Socio-Economic Analysis (SEAC) on the proposed EU-wide restriction of per- and polyfluoroalkyl substances (PFAS) following the Committee’s meeting in March 2026.
The European Chemicals Agency (ECHA) will soon launch a structured public consultation on the proposed restriction of per- and polyfluoroalkyl substances (PFASs). The consultation will use a detailed survey format, inviting participants to share insights on the potential impacts of PFAS restrictions across different sectors and to provide data on the availability and feasibility of safer alternatives. On 30 October, ECHA held a webinar to help industry prepare for the consultation. Recording is available here: https://echa.europa.eu/de/-/webinar-consultation-on-pfas-draft-opinion
The consultation will be divided in:
- General survey section: response length limits that vary by question, up to 5,000 characters.
- Sector-specific surveys: containing more detailed questions on the 14 original sectors evaluated by SEAC.
ECHA will publish two guidance documents:
1) a survey guidance document: mid-December
2) use mapping guidance: will be published in three stages:
- Stage 1 will be published after the webinar
- Stage 2 by mid-December
- Stage 3: it will provide further information on the uses evaluated by SEAC. It will be published before the beginning of the consultation in March 2026.
It is important to remember that confidential information will be handled properly, and anonymous responses are not permitted since a contact is needed for follow-up if required. In addition, feedback must be entered directly into the online survey fields, and attachments will not be accepted. The consultation will be open for only two months. For this reason, it is recommended to review, select and summarise the most important information on time.
The consultation is open to all stakeholders: industry representatives, NGOs, researchers, and the general public. ECHA encourages participants to prepare early to help ensure that the Committee for Socio-Economic Analysis (SEAC) can develop a scientifically sound and practical final opinion.
References
[1] https://echa.europa.eu/de/-/echa-publishes-updated-pfas-restriction-proposal
[2] https://echa.europa.eu/de/hot-topics/perfluoroalkyl-chemicals-pfas
[3] https://www.efsa.europa.eu/en/topics/per-and-polyfluoroalkyl-substances-pfas
[4] https://www.kemi.se/en/chemical-substances-and-materials/pfas