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On August 20, 2025, the European Chemicals Agency (ECHA) released the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS). The proposal, jointly prepared by five member states—Denmark, Germany, the Netherlands, Norway, and Sweden—aims to comprehensively reduce the risks posed by these "forever chemicals" to human health and the environment under the EU's REACH regulation.
Proposal History and Recent Developments
The move to restrict PFAS has been a long-term effort. The five authorities first submitted their comprehensive restriction proposal to ECHA in January 2023, marking one of the broadest chemical restrictions in the EU's history, covering approximately 10,000 PFAS substances.
Following a six-month public consultation from March to September 2023, ECHA received over 5,600 scientific and technical comments from various stakeholders. Based on the evaluation of these comments, The five authorities updated their initial restriction proposal, which is now called the Background Document.
Key Changes in the Latest Proposal
The latest proposal has completed assessments for eight sectors that were previously not mentioned in the initial proposal. These sectors are:
printing applications;
sealing applications;
machinery applications;
other medical applications, such as immediate packaging and excipients for pharmaceuticals;
military applications;
explosives;
technical textiles; and
broader industrial uses, such as solvents and catalysts.
Based on the collected public information, thee hazard and exposure assessments are refined, and baseline information for more sectors are incorporated.
The proposal also includes updated analyses of the environmental and economic impacts of the restriction options, taking into account input from various sectors, including textiles, upholstery, leather, apparel, and carpets (TULAC), petroleum and mining, and food contact materials (FCM).
Derogations under the Restriction Option 2 (RO2) are updated based on the information collected from consultation. Under RO2, all PFASs will be banned after a transitional period of 18 months except for time-limited use-specific derogations. The duration of derogations is 5 or 12 years after the end of transtional period. The derogation is time-unlimited for certain uses.
Compared to the initial proposal, the number of time-unlimited derogations has increased from 3 to 13 specific uses, and time-limited derogations have expanded from 20 to 49 specific uses. Furthermore, derogations for fluoropolymers and perfluoropolyethers have risen from 6 to 25 specific uses.
In addition to a full ban (RO1) and a ban with specific derogations (RO2), the proposal also considers alternative restriction options. The possibility of allowing the continued manufacture, placing on the market, or use of PFAS has been assessed for the following sectors, provided that the associated risks can be adequately controlled:
PFAS manufacturing;
transport;
electronics and semiconductors;
energy;
sealing applications;
machinery applications; and
technical textiles.
Next Steps
ECHA’s scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) will continue to evaluate the proposed restriction. The assessment is being carried out in batches by sector, with meetings scheduled over the coming months to discuss areas including electronics, semiconductors, lubricants, and medical devices. Once the final opinions are formed, they will be sent to the European Commission, which will make the final decision together with the EU Member States.
The entire process is expected to conclude in 2025, with the restriction potentially taking effect in 2026 or 2027.
The updated proposal can be accessed here.
