The planned restriction of PFAS (per- and polyfluoroalkyl substances) is one of the most comprehensive chemical regulations in the EU. This group of substances, often referred to as “forever chemicals,” comprises thousands of compounds with a wide range of industrial applications. Companies across numerous industries are facing significant regulatory and economic challenges as a result.
Now is the decisive time to prepare strategically.
Current Status of the Procedure
The restriction proposal was submitted in February 2023 by five EU Member States to the European Chemicals Agency (ECHA). The objective is a broad regulation covering nearly all PFAS – from short-chain substances to polymers – due to their extreme persistence in the environment. Only a limited number of essential uses are expected to receive exemptions or transitional periods.
The process is being conducted under the European chemicals regulation REACH Regulation. Following opinions from the Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC), a further public consultation is expected in the first quarter of 2026. This phase provides companies with the opportunity to submit well-founded data and arguments into the decision-making process.
A revised background document already reflects thousands of comments received during the first consultation and includes additional analyses of affected uses and possible restriction options.
Affected Industries and Key Challenges
The upcoming 2026 consultation is critical. Well-documented submissions may support exemptions or realistic transition periods—particularly where substitution is technically impossible or economically disproportionate.
Key evaluation criteria within the procedure include:
- Lack of technically and economically equivalent alternatives
- High transition costs and potential restructuring of supply chains
- Uncertainty regarding the economic viability of future solutions
- Data gaps concerning emissions, exposure, and specific applications
- Unclear PFAS content in purchased components, auxiliaries, or operating materials
PFAS may be present, for example, in printed circuit board coatings, paints, or fluorinated surfactants. As a result, assessments along the entire value chain are highly complex.
Leveraging Strategic Influence
The upcoming 2026 consultation is critical. Well-documented submissions may support exemptions or realistic transition periods - particularly where substitution is technically impossible or economically disproportionate.
Key evaluation criteria within the procedure include:
- Effectiveness of risk reduction
- Proportionality of the measures
- Socio-economic impacts
- Effects on supply chains and SMEs
- Availability and assessment of alternatives
Both individual companies and industry associations can submit comments. Robust data, technical evidence, and clearly structured arguments are essential.
Reliable PFAS analytics are crucial for closing data gaps and meeting regulatory requirements. The selection of appropriate testing strategies depends on the application, material, and regulatory objective. We support companies in selecting suitable testing and assessment strategies tailored to their products, materials, and supply chains. Practical feasibility, regulatory compliance, and economic viability are central considerations. We also assist in identifying relevant regulatory requirements and integrating them systematically into existing compliance processes.
The PFAS restriction will fundamentally change the regulatory landscape in Europe. Companies should act now: close data gaps, assess alternatives, review supply chains, and actively participate in the consultation process. Those who take a proactive and strategic approach can minimize risks and make the best possible use of regulatory flexibility.