PFAS (per- and polyfluoroalkyl substances) pollution is pervasive across Europe. According to the Forever Pollution Project, almost 23,000 European sites are already polluted with PFAS, and a further 21,500 sites are suspected to be contaminated. These ‘forever chemicals’ are in our food, drinking water, air, soil, rivers, oceans – and our bodies. In some areas, pollution levels are so high that local authorities have warned residents not to drink tap water or eat their own homegrown food.
The EU is developing a restriction proposal for the entire PFAS group (universal PFAS restriction dossier) based on the fact that they basically don’t break down in the environment, combined with concerns about their mobility and the fact they can spread over large distances. Many have been shown to accumulate in wildlife and people. CHEM Trust has long advocated for the need to phase out PFAS chemicals due to their widespread pollution and the harm they pose to people’s and ecosystems´ health. This article highlights key issues needed for an effective PFAS restriction and reflects on some broader lessons to be learnt for the upcoming revision of the EU chemicals law REACH, including improvements needed in how REACH restricts the use of harmful chemicals.
State of play of the uPFAS restriction
The restriction dossier was submitted jointly by five European national authorities, and the EU Chemicals agency (ECHA)’s technical committees – the Risk Assessment Committee (RAC) and the Socio-economic Committee (SEAC) – have been analysing it since 2023.
In August 2025, the five member states submitted an updated background document, integrating a large amount of new information received during a public consultation in 2023 (with a record-breaking total of over 5,600 comments). A summary by the dossier submitters (“What you need to know about the updated PFAS dossier”) provides a comprehensive overview of the updated dossier – the full text is over 3000 pages!
The most significant additions are information on eight sectors that are using PFAS, including printing, sealing and medical applications. The update also significantly increases the number of proposed derogations, including for fluoropolymers. ECHA announced that in order to finalise the committee opinions by the end of 2026, there was no time for them to do a specific evaluation for the additional sectors, but that they would be covered in horizontal assessments.
Once the final committee opinions are agreed, they will be sent to the European Commission, who will draft a proposal for a restriction. The Commission will base its proposal on these ECHA committee opinions, but they do have some flexibility in the scope and detail of the restriction that they draft. The final decision is taken in a comitology procedure with scrutiny involving the Member States and the European Parliament.
4 points to ensure the PFAS restriction delivers
The dossier submitters have confirmed that it is not possible or appropriate to set a safe concentration limit of PFASs in the environment, given their persistence. Therefore, the stated objective is to minimise future releases of PFAS. However, many additional derogations have been proposed in the updated dossier, including for some fluoropolymer uses. For that reason, CHEM Trust is concerned that the restriction could end up with significant loopholes which would undermine protection and reduce the incentive for innovation to safer alternatives. We therefore see the following priorities for the final restriction:
- Keep the current chemical scope: It is important to cover the whole group of PFAS based on the OECD definition and not to exempt whole sectors, as demanded by certain parts of the industry.
- Ensure coverage of all relevant uses: The Commission’s restriction proposal should address the information from the eight sectors, even if they have not yet been subject to an in-depth evaluation by the ECHA committees. The Commission should task ECHA to assess them further (at the latest after finalising the assessment of the current dossier) to ensure alignment and predictability.
- Keep derogations limited and short: It is worrying to see the high number of newly introduced derogations proposed, including several that are unlimited. Some proposed transition times, including 23.5 years for recycled plastics, are much too long to achieve a clean circular economy in the foreseeable future. Shorter time limits are necessary to create an incentive to innovate towards safer alternatives. Also, all derogations must be linked to strict conditions and controls (see next point):
- Tight emission controls: The EU is already struggling with a massive PFAS pollution problem, and this problem will only worsen if emissions are not strictly minimised. REACH considers PBTs/vPvBs as non-threshold chemicals that are priority chemicals for phase out and exposure should be eliminated or strictly minimised. Therefore, if derogations are given, they must be linked to strict emission control and monitoring measures over the whole life cycle, including the waste stage. Important questions still need to be addressed: How will these emissions be better controlled than they currently are? How will authorities monitor and enforce them? How should companies report, and which data will be used as the baseline? Discussion about ´appropriate´ emission limits is problematic, as all new PFAS emissions add to the existing burden.
A major flaw to fix in REACH: companies benefit from not providing information
The fact that so much crucial information on the eight sectors was only submitted during the 2023 public consultation is very problematic, considering that the first call for evidence was in 2020. This reveals systemic obstacles that authorities face in implementing an efficient REACH restriction process. It also illustrates that if companies withhold information, they may be rewarded with more time before they face restrictions. The role of PFAS as a case study for flaws in current EU chemicals management has been highlighted previously, e.g. in the EEB report `From Risk to resilience´.
REACH obliges manufacturers to provide basic information as part of the registration process, but it is often not specific enough on uses and exposures. Downstream users are often unaware of whether they are using PFAS in their products and processes, meaning that government authorities have to try to gather this information before they can propose control measures.
The PFAS restriction is not the only instance where this systematic problem hampers effective risk management: very often, only limited data are available from the REACH registration and authorities are then confronted with large amounts of new information in the public consultation.
For example, an ongoing restriction proposal on a group of bisphenols had two calls for evidence in 2020 and 2021, yet new and crucial information was submitted only during the public consultation in 2023 on the draft restriction proposal. As a result, Germany withdrew the dossier in 2023 to rethink and rework their overall approach. A re-submission is only expected in 2026, meaning several years of delay in regulating these harmful chemicals that continue to be sold and used, with continuing exposure of people and the environment.
REACH revision must ensure more effective restrictions
REACH needs to be revised to ensure that pollution crises such as PFAS never happen again. Harmful chemicals have to be identified and controlled faster. The improvements needed include:
- Improved data obligations: more (specific) hazard, use and exposure information requirements during registration, including for chemicals in lower tonnage bands, so substances of high concern can be identified.
- Regulatory consequences in cases of non-compliance and stricter enforcement of the requirements to deliver data and update registration dossiers (with an option to withdraw the registration number).
- Data from downstream uses: introduce obligations for downstream users to report data on their uses by a specific deadline if a substance is in the REACH candidate list or has been earmarked for risk management in the Registry of Intentions. This would enable authorities to have accurate information as they start developing risk management proposals and prevent delays from late submission of use data as indicated above.
- Accelerate the substitution of the most harmful chemicals by improving the fast-track restriction process for uses in consumer products, including an obligation for the Commission to act, and by expanding the scope to include persistent chemicals and endocrine disrupters at a minimum.
If these changes are not carried out to fix the system, then this questions the whole basis of industry responsibility for the initial assessment of chemical safety, which was part of the logic of REACH. The alternative would be to move to a pre-market authorisation system so that chemicals cannot be used until all hazards, uses, and exposures have been gathered and evaluated by public authorities.
Useful Links for more background
For more info on CHEM Trust recommendations on REACH reform, see here.
PFAS alternatives and the green transition briefing
