HEJSupport reaction on ECHA opinions on PFAS restriction

ECHA opinions confirm the need for a strong PFAS restriction — with implications far beyond the EU 

HEJSupport welcomes the publication of ECHA’s opinions on the proposed EU restriction on per- and polyfluoroalkyl substances (PFAS). The core message of the final RAC and draft SEAC opinions is clear: PFAS risks are not adequately controlled, and an EU-wide restriction under REACH is the appropriate response. ECHA’s committees also confirm that regulating PFAS as a group is scientifically justified, reflecting the reality that these substances are highly persistent and that ongoing emissions contribute to long-term harm to human health and the environment.  

This is an important step for Europe’s chemicals policy — but it is also much more than that. PFAS contamination does not stop at EU borders. The decisions now taken in Europe will send a powerful signal through global supply chains, including to production countries, waste-affected communities, and downstream markets in the Global South. A weak restriction with broad derogations would risk externalising pollution, hazardous production, contaminated recycling streams, and waste burdens to countries with fewer resources for monitoring, enforcement, health protection, and remediation. A strong restriction, by contrast, can help shift markets away from toxic dependency and reduce future harm globally. 

For HEJSupport, the PFAS debate is not only about substituting one chemical group. It is about prevention, transparency, and environmental justice. Communities, citizens, and consumers have a right to know where hazardous chemicals are used, released, and circulated in products and waste streams. This is especially relevant for countries in the Global South, where imported products, textiles, firefighting foams, industrial goods, and waste can become major pathways of PFAS exposure, while data on chemical content often remain inaccessible. The EU should therefore pair restriction with stronger information systems, traceability, and disclosure obligations across value chains so that safer substitution is real, enforceable, and globally significant. 

We are encouraged that ECHA’s Risk Assessment Committee underlined that there are no safe emission levels for substances like PFAS and that emissions should be minimised as much as possible. This should guide the next phase of decision-making. The European Commission and Member States should resist pressure for wide or unjustified exemptions and ensure that any derogations are strictly limited, time-bound, and based on robust evidence. Delayed action only deepens contamination, increases cleanup costs, and prolongs inequitable exposure.  

HEJSupport is also concerned that recycled materials could become a loophole for continued circulation of PFAS. Circularity cannot mean recirculating toxic substances. Clean material cycles require the progressive elimination of highly persistent chemicals from production and products, not their indefinite management through contaminated recycling streams. This is particularly important for lower-income countries and communities that often bear the consequences of unsafe recycling, informal waste handling, and weak protection measures. 

The socio-economic discussion must also be framed correctly. The cost of phasing out PFAS must be weighed against the enormous and long-lasting costs of inaction: contaminated drinking water, polluted soils, occupational exposure, harm to women’s and children’s health, biodiversity loss, and expensive remediation that can continue for decades. The EU’s new harmonised PFAS monitoring obligations in drinking water already reflect the scale of the concern and the need for systematic public protection. 

The coming consultation on SEAC’s draft opinion, open from 26 March to 25 May 2026, is therefore a critical opportunity. It should be used to strengthen, not weaken, the proposal. By the end of 2026, SEAC is expected to finalise its opinion, after which the European Commission will prepare the legislative proposal for Member State discussion and vote. At this stage, Europe has a chance to show that chemicals policy can align precaution, health protection, and global responsibility.  

The EU should adopt a strong PFAS restriction with as few derogations as possible, prevent toxic substances from being locked into recycled materials and global supply chains, and ensure that the transition away from PFAS supports not only European citizens, but also communities and workers worldwide. What Europe decides on PFAS will matter far beyond Europe. 

More information 

ECHA communication: https://echa.europa.eu/sv/-/echa-supports-pfas-restriction-with-targeted-derogations 

Restriction proposal: https://echa.europa.eu/sv/-/echa-publishes-pfas-restriction-proposal 

NGO PFAS Manifesto: https://banpfasmanifesto.org/en/ 

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