PFAS

Under the REACH Regulation, ECHA is currently evaluating a proposal on the restriction of PFAS.

Per- and polyfluoroalkyl substances (PFAS), otherwise known as “forever chemicals”, are a broad family of over 10,000 synthetic compounds known for their durability and resistance to breakdown. Because they persist in the environment and persist over time, PFAS have come under global regulatory scrutiny.  

In January 2023, five EU Member States, including Germany, the Netherlands, Norway, Denmark and Sweden, submitted a joint proposal to restrict PFAS under the REACH Regulation. The European Chemicals Agency (ECHA) has since reviewed and issued a revised proposal in August 2025, incorporating feedback from the public consultation.

The PFAS restriction proposal aligns with and builds on global efforts under the Stockholm Convention and the EU’s Persistent Organic Pollutants (POP) Regulation, which already restricts certain PFAS like PFOS and PFOA.

Why is it important?

The current proposal could introduce a sweeping restriction on the manufacture, use and market placement of all PFAS. While intended to protect the environment and public health, a full ban could also create serious unintended consequences, including:

  • Delays or barriers to the development of net-zero and clean energy technologies, such as hydrogen production.
  • Shortages of materials essential for industrial processes.

A balanced, risk-based approach is essential to achieve environmental goals without destabilising industrial innovation and the green transition.

  • EPMF KEY ASKS

The EPMF supports an approach that protects health and the environment while maintaining a competitive and innovative European industry. Our asks:  

  • In the case of use-driven derogations, PFAS uses in Green industrial applications must be derogated for at least 12 years.
  • A renewal mechanism for derogations must be established.
  • Exemption (RO3) must be granted if risk can be controlled (e.g.: for fuel cells, address the remaining concerns via the Circular Economy act)
  • A proportionate regulatory framework will ensure that Europe addresses the health and environmental challenges posed by PFAS while continuing to lead in clean and advanced technologies.

USEFUL RESOURCES:

  • Awaiting Update…