What you need to know about the updated PFAS restriction dossier
The five competent authorities that proposed the universal PFAS restriction have published a summary of the updated proposal to outline the changes made and support stakeholder understanding
07 Nov 2025On October 23, 2025, the document “What you need to know about the updated PFAS restriction dossier” was published by the five competent authorities (Germany, the Netherlands, Denmark, Sweden, and Norway) that proposed the universal restriction of per- and polyfluoroalkyl substances (PFAS) under Annex XVII of Regulation (EC) No 1907/2006 (REACH).
The document is a summary of the Background Document of the restriction proposal and examines in detail the potential environmental and human health risks associated with the use of “Forever Chemicals,” as well as the various restriction options analyzed to date.
In particular, the following key topics are addressed:
- PFAS: Risks to human health and the environment
Due to their high persistence and potential for mobility and long-range transport, the proposing authorities consider PFAS to be non-threshold substances, meaning that even minimal releases into the environment pose unacceptable risks. - Analysis of affected industrial sectors and emissions
The updated proposal expanded the analysis to 23 industrial sectors, estimating for each the volumes of use, expected emissions throughout the life cycle, and overall environmental impact. - Assessment of regulatory options and socio-economic impacts
Three restriction strategies were examined: total ban (RO1), ban with temporary derogations (RO2), and controlled use with strict limits (RO3). The analysis shows that RO2 represents the most balanced and proportionate option, offering the best compromise between environmental benefits—an estimated 83% reduction in emissions—and mitigation of socio-economic impacts compared to a total ban. The document also includes an overview of the derogations currently foreseen in the restriction proposal, with particular attention to spare parts, second-hand articles, and specific materials derived from recycling processes.
The overall objective of the document is to make it easier to identify key updates to the restriction proposal and facilitate understanding among stakeholders.
It is worth noting that the universal PFAS restriction proposal has been under discussion for almost three years. ECHA is committed to completing the entire evaluation process by next year, delivering the consolidated RAC and SEAC opinions to the European Commission by the end of 2026. It is therefore reasonable to expect that the Commission will adopt the regulation during 2027, which, once published, will formalize the restriction in question.