On August 20, 2025, the European Chemicals Agency (“ECHA”) published the updated REACH PFAS Restriction Proposal.
Following the evaluation of more than 5,600 comments submitted during the 2023 consultation phase, the competent authorities of Denmark, Germany, the Netherlands, Norway, and Sweden (referred to as the “Dossier Submitters”) have updated their initial Annex XV REACH Report. This updated Report, referred to as a “Background Document”, serves as the basis for the opinions to be issued by ECHA’s RAC and SEAC Committees (further information is available at the following link).
The authorities have assessed and included eight additional industry sectors (e.g. sealing, machinery, medical and military applications, technical textiles, broader industrial uses) and expanded the number of derogated uses (from 26 to 74), which would benefit from longer phase-out periods (up to 13.5 years).
The Dossier Submitters are also proposing alternative restriction options, beyond a full ban or a ban with time-limited exemptions for certain applications. While these alternative options provide for the continued manufacture, placing on the market or use of PFAS, they impose certain operating conditions and risk management measures to control emissions of PFAS in the environment. The alternative options have been considered for, among others, electronics and semiconductors, PFAS manufacturing, transport, energy.
The Background Document also envisages either longer (of up to 20 years) or time-limited exemptions for PFAS-containing spare parts for the maintenance of complex objects (e.g. aircraft) with long service life across industries. The objective is to avoid premature obsolescence and high societal costs.
Next Steps
ECHA’s RAC and SEAC Committees will continue and aim to complete their work by the end of 2025. A public consultation on SEAC’s draft opinion is expected in the first half of 2026, with final opinions delivered to the European Commission later that year (see ECHA press release here). This upcoming consultation on the SEAC draft opinion will be the last opportunity for stakeholders to influence the scope of the future PFAS REACH restriction.
The consultation window will be only 60 days following the date of publication of the draft SEAC opinion. Thus, it is recommended that impacted companies begin to prepare their submissions.
