Universal PFAS: Update on the Restriction Proposal

On 20 August 2025, the updated version of the Universal PFAS restriction proposal was published. Originally submitted to ECHA on 13 January 2023 by the authorities of Denmark, Germany, the Netherlands, Norway and Sweden, the proposal received over 5,600 scientific and technical comments from third parties during the public consultation period.

The five authorities have completed the evaluation of the various comments received, leading to a revision that includes eight new sectors previously unspecified:

• printing applications;
• sealing applications;
• machinery applications;
• other medical applications, such as immediate packaging and excipients for pharmaceutical products;
• military applications;
• explosives;
• technical textiles; and
• broader industrial uses, such as solvents and catalysts.

The report outlines three main restriction options, comparing their effectiveness and costs:

1. total ban (RO1): would achieve the highest reduction in emissions (96%) but is considered difficult to implement and manage;
2. ban with time-limited exemptions (RO2): would reduce emissions by 83% with lower costs and greater feasibility. This option is seen as the most proportionate, effectively balancing environmental benefits with socio-economic impacts;
3. alternative options (RO3): would allow continued manufacture, market placement, or use of PFAS where risks can be controlled. These are considered suitable for specific sectors such as transport, electronics and semiconductors, energy, sealing applications, machinery applications, and technical textiles.

While all three options are considered sufficiently applicable and manageable, RO2 and RO3 are regarded as the most realistic in terms of feasibility and implementation.

The proposal is currently under evaluation by ECHA’s scientific committees (RAC and SEAC). The European Commission will make the final decision on the restriction following consultation with Member States.