Universal PFAS Ban Proposal
Five EU member states (Germany, Denmark, Netherlands, Norway, Sweden) submitted a restriction proposal in January 2023 covering approximately 10,000 PFAS substances - the broadest chemical restriction ever proposed under REACH.
What's Being Proposed?
The EU restriction proposal aims to ban the manufacture, use, and placing on the market of PFAS in the European Economic Area. Key aspects include:
- Scope: Covers all PFAS as a class, not individual substances
- Definition: Any substance containing at least one fully fluorinated carbon atom
- Estimated substances: Over 10,000 individual compounds
- Transition periods: Varying by use sector (18 months to 13.5 years)
Timeline
Five countries submit universal PFAS restriction dossier to ECHA
6-month consultation period begins, receives record 5,600+ comments
RAC and SEAC evaluate proposal and stakeholder input
Commission drafts restriction with potential modifications
Restriction becomes law, transition periods begin
Affected Sectors
Textiles & Apparel
Water-repellent coatings, stain resistance treatments
Food Contact Materials
Non-stick coatings, grease-resistant packaging
Electronics
Semiconductors, cables, circuit boards
Automotive
Fuel systems, lubricants, coatings
Medical Devices
Implants, surgical equipment, diagnostics
Construction
Membranes, sealants, coatings
Firefighting
AFFF foams (already restricted in many uses)
Cosmetics
Long-wear makeup, waterproof products
Proposed Exemptions
The proposal includes time-limited derogations for uses where:
- No alternatives are currently available
- The use is critical for society
- Risks are adequately controlled
Sectors seeking longer transition periods must demonstrate the need and provide roadmaps for phase-out.
What Businesses Should Do Now
- Inventory: Map all PFAS uses in your products and supply chain
- Alternatives: Begin researching and testing PFAS-free alternatives
- Engage: Participate in consultations and industry associations
- Plan: Develop transition timelines for affected products
- Monitor: Stay updated on regulatory developments