PFAS pollution is widespread across Europe. According to the Forever Pollution Project, nearly 23,000 sites across the continent are already contaminated with PFAS, while a further 21,500 sites are suspected of pollution (read more about PFAS here).
CHEM Trust responded to the recently concluded public consultation on the proposed universal PFAS restriction conducted by the European Chemicals Agency’s (ECHA) Socio-Economic Analysis Committee (SEAC). We concur with SEAC that regulating PFAS individually is ineffective and that only a comprehensive, group-based REACH restriction can solve the PFAS pollution problem. CHEM Trust also agrees with SEAC that distinguishing between industrial, professional, and consumer uses is challenging, and therefore urges the decision-maker to adopt a comprehensive PFAS restriction that covers both industrial and consumer uses.
But we are concerned that the proposed derogations and timelines are too long and urge stricter, time-limited exemptions and greater support for safer PFAS alternatives already being developed in sectors such as green energy and healthcare .
This article summarises the opinions issued in March 2026 by ECHA’s two scientific committees and offers recommendations for decision-makers to ensure maximum protection of both public health and the environment from these harmful chemicals.
What’s next on the EU’s universal PFAS ban?
After several years of thorough scientific analysis, ECHA’s scientific committees, Risk Assessment Committee (RAC) and Socio-economic Analysis Committee (SEAC), published their opinions in March 2026. While the RAC published its final opinion, SEAC concluded a 2-month-long public consultation on the 25th of May. SEAC will publish its final opinion by the end of 2026. After this, the European Commission will draft a definitive proposal. The Commission will base its proposal on the committee opinions, but it does have some flexibility in the scope and detail of the restriction it drafts. The final decision is taken in a comitology procedure with scrutiny involving the Member States and the European Parliament.
What are the main takeaways from the ECHA committees’ opinions?
1. There are no safe levels of PFAS emissions; a group restriction is the only way forward
- Both committees agree that there are no safe levels of PFAS emissions and that any release contributes cumulatively to environmental and health risks.
- The committees also conclude that all PFAS are problematic. While specific properties such as mobility, bioaccumulation, and toxicity may vary between PFAS, all PFAS share an intrinsic characteristic of extreme persistence, which underpins long-term risks to both human health and ecosystems. Therefore, both committees agree that using the Organisation for Economic Co-operation and Development (OECD) definition to regulate PFAS is the best way forward, as this approach enables the assessment of PFAS as a group rather than as individual substances and avoids regrettable substitution.
- Additionally, both committees agree that the evidence submitted by the dossier submitters to justify an exclusion of certain PFAS sub-groups (on the grounds that they are fully degradable) is insufficient. CHEM Trust agrees with both the committees’ conclusion that PFAS sub-groups should not be given derogations and also to regulate all PFAS as a group, based on the OECD definition.
2. Fluoropolymers: lifecycle is a major source of PFAS pollution
Some parts of the chemical industry argue that fluoropolymers should be excluded from the uPFAS restriction, on the grounds that they are polymers of low concern. However, the committees disagree with this claim and make it clear that PFAS pollution from fluoropolymers is mainly associated with their lifecycle i.e., manufacturing and waste stage and that fluoropolymers should therefore remain in scope of the restriction. Approximately 1.8 million people in Europe live within 10 km of fluoropolymer plants and are at risk of exposure. CHEM Trust fully supports the committees’ proposal on this point.
3. Not enough evidence to exclude biocidal, pesticide, and medicinal products from the restriction
The original proposal excluded biocidal, pesticide and medicinal products (all of which are sources of PFAS to the environment) from the scope of the restriction, based on the argument that these products have their own sector-specific legislation. However, RAC concludes that existing regulations for these products are insufficient to control PFAS emissions and that any possible exemptions should be supported with stricter emission controls. SEAC concludes that there is insufficient data to justify excluding these products from the scope of the restriction. CHEM Trust agrees that this needs to be addressed, as we already pointed out in our 2023 response.
4. The restriction is implementable, manageable and enforceable with additional guidance
- RAC supports the restriction on the manufacturing, use and placing on the market of PFAS and suggests that the associated risks should be managed through a range of compliance and monitoring obligations. RAC concludes that such a restriction is pragmatic, implementable, manageable, and enforceable. RAC indicates that such a restriction would be most effective if accompanied by minimal, time-limited derogations, noting that a restriction without derogations would yield the greatest reduction in emissions.
- SEAC broadly concurs with RAC’s assessment, agreeing that an EU-wide restriction under the REACH framework constitutes the most appropriate regulatory instrument. However, it highlights limitations in making a definitive conclusion to determine the proportionality of proposed derogations and transition periods because of insufficient data on alternatives, costs associated with phasing out PFAS, and the broader economic implications of the restriction.
- SEAC suggests additional derogations for some sectors and suggests giving time-limited derogations to the eight new sectors that were added in the 2025 dossier update, pending their further analysis. CHEM Trust agrees with SEAC’s recommendation that an evaluation of the eight specific sectors — for which detailed evaluations were not carried out — is performed as soon as possible, as we also highlighted previously.
5. Disentanglement into industrial, professional or consumer uses is difficult
CHEM Trust agrees with SEAC that clearly distinguishing between industrial, professional, and consumer uses is challenging, and therefore urges that the decision-maker maintain a comprehensive restriction scope that includes both industrial and consumer uses of PFAS.
CHEM Trust calls for an effective restriction
CHEM Trust acknowledges the considerable effort involved in evaluating the scientific and socio-economic evidence in the draft opinion and appreciates SEAC’s role in supporting measures to protect human health and the environment from PFAS. We remain concerned, however, about emissions arising from the proposed derogations and the length of some timelines. CHEM Trust’s research shows that innovative EU companies have already developed, or are developing, alternatives in critical sectors such as green energy and healthcare. Derogations should therefore be strictly time-bound and granted for specific uses rather than for entire sectors, and emphasis should be placed on accelerating the development and adoption of safer alternatives.
Recommendations for F-Gases
We also have concerns about SEAC’s suggestion that some F-gas uses are already covered by the F-gas regulation and that including them in the universal PFAS restriction would cause overlap. Overlapping regulatory frameworks are common within EU law, where different instruments address distinct risks and policy objectives. While the F-gas Regulation primarily targets climate impacts and greenhouse gas emissions, the universal PFAS restriction addresses persistence, mobility, and long-term environmental accumulation. This is particularly important for low-global-warming-potential F-gases such as many hydrofluoroolefins (HFOs), which are not completely addressed under the F-gas regulation. HFOs can degrade into TFA, for which Germany has proposed a Reprotoxic 1B classification. Given that F-gases account for around 58% of PFAS emissions in the EU, their inclusion in the universal PFAS restriction remains essential.
Dr Shubhi Sharma at CHEM Trust said:
The opinions of ECHA’s scientific committees make it abundantly clear that PFAS pose public health and environmental risks that are not adequately controlled. Several years of rigorous scientific assessment done by the two committees confirm their assessment of the need for a broad, EU-wide restriction on these extremely persistent chemicals across both consumer and industrial uses. Crucially, both committees highlight that all PFAS are problematic due to their persistence, underlining the need for comprehensive action rather than focusing on a small subset of substances. The Committees’ findings also show that such a restriction would be pragmatic, implementable, manageable, and enforceable.
While the socio-economic committee, SEAC, notes data gaps and suggests additional derogations in some sectors, uncertainty should not be used as a reason to delay action. A strong restriction with few, time-limited derogations is urgently needed to protect people and nature from exposure to these forever chemicals. The European Commission should now act on this evidence and bring forward an ambitious, EU-wide restriction.
