
PFAS Regulation in the European Union
Per- and polyfluoroalkyl substances (PFAS) are a group of synthetic chemicals that are recognized for their persistence, mobility, and potential health risks. In response to increasing environmental and public health concerns, the European Union has ramped up its regulatory efforts to limit PFAS usage across various sectors.
Key Developments
Universal PFAS Restriction Proposal
In 2023, five EU member states—Denmark, Germany, the Netherlands, Norway, and Sweden—submitted a landmark proposal to the European Chemicals Agency (ECHA) to restrict the manufacture, use, and sale of over 10,000 PFAS chemicals under the REACH Regulation. This proposal is currently undergoing scientific evaluation by ECHA’s committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC). The evaluation is being conducted sector by sector, with provisional conclusions expected throughout 2024 and early 2025. Sectors under review include cosmetics, textiles, food packaging, construction, transport, and fluorinated gases.
Further reading: https://echa.europa.eu/documents/10162/67348133/upfas_evaluation_state_of_play_en.pdf/
Targeted PFHxA Restriction
On 19 September 2024, the European Commission adopted a targeted restriction under the REACH Regulation on undecafluorohexanoic acid (PFHxA), its salts, and related substances. These chemicals are part of the broader PFAS family and are commonly used as substitutes for previously banned substances like PFOA.
Why PFHxA?
PFHxA and its related compounds are:
• Extremely persistent in the environment
• Highly mobile in water systems
• Increasingly detected in soil, drinking water, and biota
• Often used in consumer products where exposure risks are high
The Commission determined that their use in certain applications poses an unacceptable risk to human health and the environment, especially where safer alternatives are available.
Scope of the Restriction
The restriction bans the sale and use of PFHxA and related substances in:
• Consumer textiles (e.g., rain jackets, outdoor gear)
• Food contact materials (e.g., pizza boxes, wrappers)
• Waterproofing sprays and other consumer mixtures
• Cosmetics (e.g., skincare and makeup products)
• Firefighting foams (specifically for training and testing purposes)
Importantly, the restriction does not apply to certain high-tech applications such as:
• Semiconductors
• Batteries
• Fuel cells for green hydrogen
These exemptions reflect the EU’s commitment to balancing chemical safety with the green and digital transitions and strategic autonomy.
Transitional Periods
To give the industry time to adapt, the regulation includes transitional periods ranging from:
• 18 months for most consumer applications
• Up to 5 years for more complex or critical uses
This phased approach is designed to minimize disruption while encouraging the development and adoption of safer alternatives.
Policy Significance
This restriction is a milestone in the EU’s broader PFAS strategy and aligns with:
• The EU Chemicals Strategy for Sustainability
• The Zero Pollution Action Plan
• Ongoing efforts to phase out non-essential uses of PFAS
It also complements the universal PFAS restriction proposal currently under evaluation by ECHA, which aims to regulate the entire class of PFAS chemicals.
Further reading: https://ec.europa.eu/commission/presscorner/api/files/document/print/en/ip_24_4763/IP_24_4763_EN.pdf
The European Environment Agency (EEA) has highlighted PFAS pollution as a significant barrier to achieving the EU’s goal of good chemical status for water bodies by 2027. This emphasizes the necessity for coordinated action across the environmental, health, and industrial policy domains.
Environmental Monitoring and Policy Alignment
In its December 2024 briefing, the European Environment Agency (EEA) issued a stark warning: PFAS pollution is widespread in European waters and poses a serious threat to achieving the EU’s target of good chemical status for all water bodies by 2027, as mandated by the Water Framework Directive.
Why This Matters
Key Findings from EEA Monitoring Data (2018–2022)
- 51-60% of rivers, 11-35% of lakes, and 47-100% of transitional and coastal waters exceeded the annual average environmental quality standards (EQS) for PFAS, one of the most studies PFAS compounds.
- These exceedances indicate chronic contamination and potential risks to both human health and aquatic ecosystems.
- The data also reveal significant gaps in monitoring, especially for lesser-known PFAS compounds, highlighting the need for expanded surveillance and more sensitive analytical methods.
PFAS, often called “forever chemicals,” are:
- Extremely persistent in the environment
- Highly mobile in water systems
- Capable of bioaccumulating in living organisms
- Linked to toxicological effects, including immune, reproductive, and developmental harm.
- The EEA emphasizes that PFAS pollution undermines the EU’s Zero Pollution Ambition and compromises the 2030 and 2050 goals for a toxic-free environment.
Policy Implications
To address this challenge, the EEA calls for:
- Coordinated action across environmental, health, and industrial policy domains.
- Inclusion of more PFAS on the list of priority substances under the Water Framework Directive.
- Review of PFAS limits in the Drinking Water Directive.
- Support for the upcoming European Water Resilience Strategy, which aims to strengthen water protection and pollution prevention.
Further reading: https://www.eea.europa.eu/en/analysis/publications/pfas-pollution-in-european-waters
Conclusion
The EU’s approach reflects a precautionary and group-based strategy aimed at preventing regrettable substitution and reducing overall PFAS emissions. The universal restriction could become one of the most comprehensive chemical bans in EU history, setting a global precedent. Industry stakeholders are urged to accelerate innovation in PFAS-free alternatives and prepare for regulatory transitions.
Next steps: final opinions from ECHA’s committees are expected by mid to late 2025, after which the European Commission will decide on the adoption of the restriction. Continued stakeholder engagement, scientific input, and socio-economic analysis will shape the final scope and implementation timeline.
For additional reading:
Wollin et al. (2023) – PFASs–restriction proposal commentary on ECHA’s Annex XV restriction report
This paper provides a detailed critique of the EU’s group-based restriction approach under REACH. It supports the use of the precautionary principle due to the extreme persistence and data gaps across PFAS substances. The authors argue that waiting for complete toxicological profiles is not viable given the potential for irreversible harm.
https://link.springer.com/article/10.1007/s00204-023-03597-y
Nature News Feature (2023) – Could the world go PFAS-free?
This article outlines the global implications of the EU’s PFAS restriction proposal, including its potential impact on industries such as aerospace, electronics, and refrigeration. It highlights the tension between environmental goals and technological reliance on PFAS. The article emphasizes the long-term transition plans, including grace periods and exemptions, and highlights the global implications of the EU’s leadership in PFAS regulation
https://www.nature.com/articles/d41586-023-02444-5
European Chemicals Agency (ECHA) – Universal PFAS Restriction Proposal (2023–2025)
ECHA’s ongoing evaluation of the universal restriction proposal is central to EU policy. The agency is assessing the risk and socio-economic impacts of banning over 10,000 PFAS chemicals, with final opinions expected by late 2025
https://link.springer.com/article/10.1007/s00204-023-03597-y
ECHA Scientific Evaluation Update (March 2025)
The European Chemicals Agency (ECHA) released a detailed update on the ongoing evaluation of the universal PFAS restriction proposal. The scientific committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) are reviewing the proposal sector by sector. As of March 2025, discussions and provisional conclusions have been made for sectors including:
• Applications of fluorinated gases
• Transport
• Construction products
• Textiles, food packaging, and cosmetics
The evaluation is based on updated background documents submitted by the five proposing countries (Denmark, Germany, the Netherlands, Norway, and Sweden), incorporating feedback from public consultations
https://echa.europa.eu/documents/10162/67348133/upfas_evaluation_state_of_play_en.pdf/
ECHA PFAS Portal (Ongoing)
ECHA maintains a dedicated portal on PFAS, which includes updates on the restriction process, scientific assessments, and stakeholder engagement. It also provides background on the environmental and health risks associated with PFAS, reinforcing the rationale for the EU’s precautionary approach
https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas