Request a Demo
Starting on March 26, 2026, the European Chemicals Agency (ECHA) will open a 60‑day consultation on the draft opinion of its Committee for Socio‑Economic Analysis (SEAC) concerning the proposed EU-wide restriction of per‑ and polyfluoroalkyl substances (PFAS) under REACH.
The consultation, which runs until May 25, 2026, will collect evidence‑based input on the socio‑economic impacts of the proposed restriction and on the availability and feasibility of PFAS alternatives across affected sectors.
The new consultation is strictly limited to the SEAC draft opinion. Information related to RAC's remit (hazards, risks, emissions) will not be considered in this round.
SEAC draft opinion was agreed on March 10, 2026 and this consultation is the final step in SEAC's opinion‑making process before adoption of a final opinion, expected by the end of 2026. This will complete the scientific evaluation of the PFAS restriction proposal by ECHA's Committees, following the Committee for Risk Assessment (RAC) adoption of its final opinion on March 2, 2026. On the basis of the final RAC and SEAC opinions, the European Commission will prepare a restriction proposal for discussion and vote in the REACH Committee (EU Member States).
ECHA has published consultation guidelines and a mapping of PFAS uses to help contributors prepare and submit relevant information. The Agency encourages participants to carefully review the draft opinion and follow the guidelines to ensure their input is as useful as possible for SEAC. Any information marked as confidential will be treated appropriately.
SEAC Draft Opinion
SEAC supports a broad EU-wide restriction on PFAS under REACH as the most appropriate measure to address transboundary pollution and prevent regrettable substitution, but concludes that a full ban with a short transition period is disproportionate due to high societal costs and a lack of alternatives for specific uses. Instead, SEAC advocates for a ban with use-specific derogations where the socio-economic benefits outweigh the costs, alongside temporary exemptions for sectors requiring further evaluation.
While acknowledging the proposal is generally enforceable and monitorable, the Committee highlights uncertainties regarding the enforceability of additional risk management measures and emphasizes the need for harmonized guidance to ensure effective implementation.
Survey design and consultation structure
Input will be collected via the European Commission's EU Survey tool, accessed from ECHA's PFAS restriction page. The consultation consists of two complementary survey types:
Sector‑specific surveys
The sector-specific surveys are available for the 14 sectors individually evaluated by SEAC, plus PFAS manufacturing. (additional 8 sectors identified in the updated Annex XV restriction will not be included in the sector-specific surveys). It focuses on specific uses/sub‑uses and applications (the "SEAC evaluation levels"), as defined in the PFAS Use‑mapping annex. The Request detailed information include:
How and why PFAS (or alternatives) are used in a given process or product (function and application).
Whether suitable alternatives exist and, if not, whether constraints are driven by:
lack of sufficient quantities,
safety concerns (not safer than PFAS for human health or environment),
technical feasibility (performance requirements not met),
economic feasibility (operations not profitable with alternatives).
Time needed (in years, up to 20+) to develop alternatives to an implementable stage.
Annual PFAS volumes (tonnes/year) used or imported in the EEA, broken down by: non‑polymeric PFAS, polymeric PFAS, fluorinated gases.
Expected business impacts if PFAS could not be used in that application (e.g. permanent or temporary closure, relocation outside the EU, continued operations with higher costs/lower quality, or minor/no impact).
Average annual gross profit (EUR/year, three‑year average where possible) from PFAS‑dependent operations in the EEA.
Full‑time equivalent (FTE) jobs at risk in the EEA if PFAS use in that application ceased.
Additional negative societal impacts (beyond employment and profit), such as loss of functionality or quality in critical products, including qualitative descriptions and quantitative/monetised estimates where feasible.
For sectors where relevant, costs and feasibility of implementing risk management measures included in restriction option(s) RO3 in SEAC's sector‑specific evaluation.
General survey
The general survey sections covers the horizontal sections of the SEAC draft opinion that apply across all sectors and can be used for:
Cross‑cutting comments on SEAC's reasoning and conclusions (e.g. on costs, benefits, proportionality, practicality, monitorability, uncertainties).
Input on PFAS uses in sectors not individually assessed by SEAC, including the eight additional sectors introduced in the updated Annex XV Background Document (printing applications, sealing applications, machinery applications, other medical applications, military applications, explosives, technical textiles, broader industrial uses).
Confidentiality
ECHA has built confidentiality handling into the survey design. Each individual answer that contains confidential business information must be explicitly marked as confidential by the respondent. For each confidential answer, a justification is required. Failure to mark specific content as confidential may result in its publication, as all non‑confidential responses will be made publicly available on ECHA's website. For individual respondents (citizens), the person's name is always treated as confidential without separate justification.
For companies and associations potentially affected by a future PFAS restriction, participation in this consultation is the main remaining opportunity to influence SEAC's socio‑economic conclusions with sector‑specific data.
The consultation will be accessible on ECHA's webpage on March 26. The draft SEAC opinion is available here.
