The proposed restriction of PFAS across the EU continues to progress and could potentially impact various sectors, including for example aerospace and defence, automotive, aviation, food contact materials, textiles, leather and apparel, construction and household products, electronics, firefighting, food processing, and medical articles.
As a recap, the proposed restriction aims to address the risks to human health and the environment posed by the use of PFAS. The more than 10,000 substances in the scope of the proposed restriction are aligned with the OECD definition of PFAS being “any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it)”. Included in the OECD definition but excluded from the scope of the proposed restriction are a few fully degradable PFAS subgroups that are described in the proposal by their key structural elements.
The Committee for Socio-Economic Analysis (SEAC) of the European Chemicals Agency (ECHA) is expected to agree its draft opinion on impacts on society of the proposed EU-wide restriction of PFAS at its meeting in March 2026. Once this is done, the ECHA plans to launch a 60-day stakeholder consultation. The information submitted via that consultation will be reviewed by the SEAC before it adopts its final opinion (expected by the end of 2026).
Separately, the ECHA Committee for Risk Assessment (RAC) is expected to adopt its opinion in March 2026. Once finalised the opinions of both ECHA committees will be sent to the European Commission for decision-making. It is expected that the final opinions, in combination with the Background Document, will give the European Commission the possibility to consider in its decision-making how to best address the different use sectors (14 sectors[1] plus the additional eight[2] sectors), PFAS manufacturing and horizontal issues.
Guidance for respondents to the ECHA consultation can be found here. A link to the consultation survey will be available on the ECHA’s website.
Timelines, as well as additional information in relation to PFAS, are available here.
We are continuing to monitor the progress of this proposed restriction.
Contact us
For further information or advice on how your business may be impacted, please contact Matheson partners Maeve Delargy, Ruadhán Kenny and Susanne McMenamin.
[1] Ski wax, consumer mixtures and miscellaneous consumer articles, cosmetics, metal plating and manufacture of metal products, food contact materials and packaging, TULAC (textiles, upholstery, leather, apparel and carpets), petroleum and mining, construction products, applications of fluorinated gases, transport, energy, medical devices, lubricants, electronics and semi-conductors – see Background Document (link below) for details on these sectors.
[2] Printing applications, sealing applications, machinery applications, other medical applications, military applications, explosives, technical textiles, broader industrial uses – see Background Document (link below) for details on these sectors.