Universal PFAS Restriction

PFAS (per- and polyfluorinated alkyl substances) are a family of over 10,000 synthetic chemicals known as the ‘forever chemicals’ because they will last for generations in the environment. They are used in a variety of applications, from industrial uses to everyday products.

This is concerning because the vast amount of scientific evidence linking PFAS exposure to a number of serious health issues continues to grow. The extent of PFAS contamination has become increasingly clear over recent years, with a major mapping project revealing pollution hotspots across Europe and biomonitoring studies detecting PFAS in the blood samples of Europeans.

To limit the environmental and human health risks associated with PFAS, authorities in Denmark, Germany, the Netherlands, Norway and Sweden prepared a restriction dossier to restrict over 10,000 PFAS under the main EU chemicals legislation, REACH. This dossier is also known as the universal PFAS restriction (uPFAS). 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. 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.

The scientific bodies of the European Chemicals Agency (ECHA) are currently considering the restriction however, ECHA announced that in order to finalise the committee opinions by the end of 2026, it won’t do a specific evaluation for the additional sectors included in the Member State’s updated background document. ECHA said that these would instead be covered in horizontal assessments.

CHEM Trust is calling for the restriction to maintain its broad scope, covering all PFAS, with minimal derogations and transition times.

Policy timeline

June 2019: In its conclusions on the ‘EU Sustainable Chemicals Policy Strategy’, the EU Environment Council called on the European Commission ‘to develop an action plan to eliminate all non-essential uses of PFAS’.
December 2019: As a follow up to these Council conclusions, Denmark, Luxembourg, the Netherlands and Sweden submitted a report entitled ‘Elements for an EU Strategy on PFASs’ to the European Commission. The report calls for immediate action to cease the release and exposure of all PFAS, as much as possible, due to the potential health and monetary impacts of inaction. It also calls on industry to take more responsibility to phase out PFAS voluntarily.
May 2020: Denmark, Germany, the Netherlands, Norway and Sweden decided to prepare a joint REACH restriction dossier on PFAS, and opened up a stakeholder consultation on the use of PFAS.
October 2020: The von der Leyen Commission published its Chemicals Strategy for Sustainability, which included a commitment to phase out PFAS in all non-essential uses.
July 2021: Denmark, Germany, the Netherlands, Norway and Sweden opened a second stakeholder consultation on the use of PFAS.
January 2023: The Universal PFAS restriction dossier was submitted to the European Chemicals Agency (ECHA) by Denmark, Germany, the Netherlands, Norway and Sweden.
February 2023: Following a conformity assessment, ECHA published the universal PFAS restriction proposal.
March-September 2023: ECHA held a public consultation on the proposal.
August 2025: The five Member States who submitted the proposal reviewed the consultation responses and submitted an updated background document based on the comments. Read more about the updated proposal here.
Currently: The scientific committees of ECHA (RAC and SEAC), are examining the proposal by assessing PFAS uses in each sector (such as cosmetics and textiles) to form their opinion, for a detailed breakdown of the timeline see the figure below. This stage of the process was originally due to be completed during 2024, however due to the complexity of the file and the large number of public consultation responses, ECHA has advised that the assessment will take longer than expected. The current estimate is that their opinion will be published in 2026.
Next steps: Once RAC and SEAC have published their opinions on the dossier, the EU Commission will submit a draft restriction to obtain the opinion of the REACH Committee, formed by Member States, before it can adopt the restriction. After the restriction enters into force, sectors will have 18 months to transition to the new rules. For the sectors that have been given derogations, this transition period will be much longer (up to 13.5 years).

The timeline for the ECHA Committees, RAC and SEAC, to assess PFAS use in each sector.

The scope of the Universal PFAS Restriction Proposal

The universal PFAS restriction proposes to ban the manufacture, import and use of PFAS in the EU, including the intentional use of PFAS in articles. It covers both consumer and industrial applications – from cosmetics and cookware, to automobile and aerospace industries respectively. For some uses of PFAS, such as in medical devices, petroleum, the mining industry and technologies needed for the green transition, derogations of up to 13.5 years are foreseen. Biocides, pesticides, pharmaceuticals, and active ingredients in veterinary products are currently exempted from the scope of the restriction.

What do we want to see in the uPFAS restriction

CHEM Trust advocates for the precautionary approach, and for the PFAS family to be regulated as a group in order to accelerate the regulatory process.
PFAS alternatives are available and already in use in many sectors, and in certain other sectors such as in green transition technology, alternatives are available or up and coming – read our PFAS and the Green Transition FAQs for more information (find the full briefing here, and our summary here). Therefore, derogations should be kept to a minimum with a narrow scope, exclusively targeting specific uses which are critical and for which no acceptable alternatives are yet available; and with transition periods as short as possible.
There should be no time unlimited derogations.

CHEM Trust is calling on the European Commission to move as quickly as possible on the file as soon as ECHA has adopted its opinion.

Read our full recommendations for the uPFAS restriction here, in our response to ECHA’s public consultation on the restriction dossier.