PICTOPLAN » PFAS – the latest regulatory changes in the EU and the current state of work on restricting their use. What do manufacturers, importers and users need to know?

The European Union is currently at a crucial moment in the development of regulations on PFAS — per- and polyfluoroalkyl substances, commonly known as “forever chemicals.” They represent one of the largest groups of synthetic chemicals, comprising more than twelve thousand substances (2025 estimates from the National Institute of Environmental Health Sciences indicate 15,000). What they have in common is high chemical stability — so high that their persistence has become a global environmental problem. PFAS are detected in groundwater and surface waters, soil, air, animal tissues and drinking water, and their migration is so extensive that they reach even Arctic regions. For these reasons, they have been the focus of regulators for several years, and the scope of measures undertaken by the European Union is unprecedented.

One of the key factors accelerating legislative work is growing toxicological knowledge. Many PFAS meet the criteria of very persistent substances (vP), some also possess bioaccumulative properties, and further studies suggest potential carcinogenic, immunotoxic or endocrine-disrupting effects. At the same time, these substances are used across hundreds of sectors — from textiles and electronics to automotive, and specialist applications in energy, firefighting, the semiconductor industry and medical technologies. This means that regulation must be multidimensional and carefully designed. In its communications, the European Commission has repeatedly emphasised that its objective is the gradual phase-out of all uses not considered essential[1].

The most advanced element of regulation currently is the ban on PFAS in firefighting foams. Commission Regulation (EU) 2025/1988, published on 2 October 2025, introduces a new entry 82 into Annex XVII to REACH, covering all substances that meet the definition — i.e. those containing at least one fully fluorinated carbon atom in a CF₂ or CF₃ group[2]. Firefighting foams were regulated because they were one of the largest sources of PFAS emissions into the environment. According to ECHA assessments confirmed by the RAC and SEAC committees, approximately 470 tonnes of PFAS were released into the environment each year as a result of foam use. The petrochemical, aviation, maritime, military and refinery sectors had the highest contribution. Crucially, experts concluded that the availability of fluorine-free foams is now sufficient to enable a full transition away from PFAS in this application while maintaining firefighting effectiveness. The regulation provides transitional periods but also imposes numerous obligations to prevent further PFAS emissions from existing installations. From autumn 2026, companies will be required to ensure appropriate foam labelling, management plans and selective waste handling. The full ban on PFAS-containing foams will apply from October 2030, except for critical sectors such as defence, offshore platforms, ships and installations covered by the Seveso III Directive, where the use of PFAS may be extended until 2035. The European Commission highlighted that this restriction will not only significantly reduce emissions but will also protect the health of firefighters, who were routinely exposed to PFAS during firefighting operations[3].

In parallel, the EU is progressing with a broad restriction proposal – an initiative to cover all PFAS uses through a single group restriction. The dossier, prepared by five Member States (Denmark, the Netherlands, Germany, Norway and Sweden), covers thousands of applications across numerous sectors. ECHA is conducting a thematic assessment, analysing textiles, transport, electronics, the energy sector, fluorinated gases, lubricants, medical devices and specialised applications such as fuel cells and semiconductors.

In November 2025, a draft use mapping document was published, showing the allocation of specific use cases to sectoral categories[4]. The document indicates, among other things, that both consumer and professional uses are being assessed, including textiles, PPE, medical devices, food contact materials, renewable energy production, batteries, metallurgy, transport, refrigerants and insulating gases, construction products, as well as a wide range of electronics and semiconductors. In some sectors, such as microtechnologies, semiconductors and certain medical devices, the analysis of alternatives is exceptionally complex — and it is there that time-limited exemptions may potentially appear.

Another key element of ECHA’s latest documentation is the substantial update of data on PFAS volumes placed on the European Economic Area market.

Compared to the information available before the 2023 consultation, these figures have increased across most sectors. According to the updated Background Document, between 190,000 and 340,000 tonnes of PFAS were placed on the EEA market in 2020. This includes large volumes of fluoropolymers (estimated at 84,000–199,000 tonnes), fluorinated gases (92,000–102,000 tonnes), and smaller but toxicologically significant amounts of non-polymeric PFAS such as PFAAs and their precursors (11,000–41,000 tonnes). Without restrictions, total PFAS use between 2022 and 2055 could reach as much as 27.1 million tonnes, with emissions amounting to approximately 4.7 million tonnes. ECHA emphasises that emissions occur at every stage of the life cycle — from PFAS production, through manufacturing of PFAS-containing articles and the user phase for consumers and industry, to waste management, including landfilling, incineration, recycling and wastewater treatment.

As part of the work on the general PFAS restriction, the dossier submitters analysed three regulatory options (“restriction options”). The first, RO1, envisages a complete ban on PFAS only eighteen months after entry into force. Although this option would deliver the greatest emission reduction, it was deemed disproportionate — in many sectors, alternatives are not yet available, and such a short transitional period would result in enormous socioeconomic costs and disruption of numerous supply chains. The second option, RO2, also introduced a ban, but with time-limited derogations lasting six and a half or thirteen and a half years, intended for uses where no technically feasible substitutes currently exist. The length of derogations was to be determined by standardised criteria covering the maturity of alternatives and the time required for implementation. The third option, RO3, would not phase out PFAS but would allow their continued use under stricter emission limits or additional environmental controls, effectively an expanded version of RO2. The detailed derogations under RO2 and their modifications compared to the March 2023 draft were included in the annexes to the dossier, while the technical and sector-specific justification was presented in the Background Document.

According to the current ECHA timeline, the final RAC and SEAC opinions are to be submitted to the European Commission at the end of 2026, and legislative decisions may be taken no earlier than 2027. This means that in the coming years businesses should monitor developments closely and prepare for extensive regulatory changes.

The implications for companies are far-reaching. They include the need for detailed inventories of PFAS in products and processes, supply chain analyses, risk assessments and the development of substitution strategies wherever feasible. In many cases, this will require the implementation of new technologies, changes in manufacturing processes, and alignment of documentation, labelling and waste management with future requirements. For businesses operating in high-risk sectors — such as firefighting, petrochemicals, medtech, transport or energy — early preparation may be crucial for maintaining compliance and competitive advantage.

The conclusions from current analyses are clear: PFAS have become one of the highest priorities of EU chemicals policy. The scale of PFAS use, confirmed by newly updated volume data, shows that hundreds of thousands of tonnes of PFAS are present in the economy each year, and in the long term — tens of millions of tonnes could enter the market and the environment without regulation. At the same time, the analysis of the three regulatory options — full ban, ban with derogations and continuation under strict emission controls — clearly demonstrates that regulatory decisions must be made in a balanced manner.

The ongoing broad PFAS restriction process, combined with Member State actions on drinking water quality and environmental monitoring, is creating a new regulatory landscape that will require long-term adaptation efforts from businesses. The coming years will be a period of intense technological investments, process adjustments and supply chain restructuring. For many companies, this will be a strategic moment shaping regulatory compliance, competitiveness and development directions for decades to come.

References:

[1] Communications from the European Commission on the Chemicals Strategy for Sustainability.

[2] Commission Regulation (EU) 2025/1988 — REACH Annex XVII.

[3] Justification to Regulation 2025/1988, ECHA data, RAC/SEAC assessments.

[4] “PFAS restriction proposal: Initial draft use mapping”, ECHA, 5 November 2025.

PFAS – the latest regulatory changes in the EU and the current state of work on restricting their use. What do manufacturers, importers and users need to know?

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