Support for EU-wide PFAS restriction with targeted derogations: what happens next?

On 26 March 2026, the European Chemicals Agency (ECHA) announced that its two scientific committees, the Risk Assessment Committee (RAC) and the Committee for Socio-Economic Analysis (SEAC), support an EU-wide restriction on the manufacture, placing on the market and use of per- and polyfluoroalkyl substances (PFAS), subject to specific derogations. 

The EU's Chemicals Strategy for Sustainability, published in October 2020, committed the European Commission to phasing out all PFAS except where their use is proven essential to society. ECHA’s announcement is therefore a major milestone and marks a significant step towards EU-level measures to address the long-lasting risks that PFAS pose to human health and the environment.

The restriction proposal

The proposal to restrict PFAS across the EU/EEA was submitted to ECHA on 13 January 2023. It is the most comprehensive chemical restriction proposed under the EU REACH Regulation, covering around 14,000 synthetic chemicals used across virtually every industrial sector. A public consultation on the proposed restriction ran from 22 March to 25 September 2023, and ECHA's scientific committees have been evaluating it since.

The committees' opinions

RAC adopted its final opinion on 2 March 2026. It considers that existing regulatory measures are insufficient and that further EU-wide action is needed. Importantly, RAC recommended that any derogations should be accompanied by risk management measures to minimise emissions, including site-specific PFAS management plans, supply-chain communication, consumer labelling and reporting of PFAS emissions to ECHA.

SEAC agreed its draft opinion on 10 March 2026. In the draft, SEAC supported targeted derogations for specific uses where alternatives are not yet available and where cost-benefit analysis justifies this, to ensure the restriction remains proportionate. 

Consultation and next steps

ECHA has since launched a 60-day consultation on SEAC's draft opinion, open until 25 May 2026. Stakeholders are invited to provide evidence-based comments through a consultation survey which raises specific queries for different sectors covering PFAS manufacturing; textiles, upholstery, leather, apparel and carpets; FCM and packaging; metal plating and manufacture of metal products; consumer mixtures and articles; cosmetics; ski wax; fluorinated gases; medical devices; transport; electronics and semiconductors;  energy; construction products; lubricants ; petroleum and mining. ECHA has published guidelines and a mapping of PFAS uses to assist contributors. 

Any business that manufactures, uses or is otherwise affected by PFAS should consider engaging with this consultation, as comments received will help shape SEAC's final opinion.

SEAC is expected to adopt its final opinion by the end of 2026. Both committees' opinions will then be formally submitted to the European Commission, which will propose a restriction for discussion and vote in the REACH Committee. 

Implications for industry and the UK

The committees' opinions reinforce the expectation that a broad EU PFAS restriction is a matter of “when”. Businesses across all sectors that manufacture, use or place on the market products containing PFAS should be considering their exposure, including the availability of alternatives, the potential for derogations and the likely transition periods. Supply chain transparency and emissions management are also likely to become increasingly important. 

The UK government published its PFAS Plan on 3 February 2026, which includes an indicative action to align “UK” REACH with the UK's "closest trading partners, especially the EU" by December 2028. For a commentary on the UK’s PFAS plan see here: PFAS Update: UK Government's Plan and Industry Implications. Under the Windsor Framework, Northern Ireland remains subject to EU REACH. This means that any EU-wide PFAS restriction, once adopted, is likely to  apply in Northern Ireland. 

The practical impact of the EU restriction will be felt by all businesses that export to the EU or form part of affected supply chains. 

Our previous updates include discussion of PFAS risks and regulation around packaging, toys, land ownership and development,  the water industry and industrial permitting including site condition reports. If you would like to discuss any aspect of this update which is relevant to your business, please contact   the authors listed below or your usual contact.