PFAS: EU faces balancing act with ‘forever chemicals’ clampdown

The move is happening in response to the perceived health risks and environmental impact of PFAS, a class of approximately 10,000 fluorinated chemicals used in everything from beauty and healthcare products, to clothing, semiconductors, medical equipment, in food and drinks packaging, in cleaning chemicals, and in firefighting foam, among other things.

PFAS chemicals serve different purposes – depending on the chemical and the product, they have a wide range of uses, including making products resistant to oil, water, or heat, for example. Some of these chemicals are, however, known to degrade very slowly – data is not available on all of them – which has led to the colloquialism ‘forever chemicals’ being used to describe them.

As more regulation is considered, there is a need to balance industrial needs with consumer and environmental safety. This remains a complex challenge that requires ongoing innovation and collaboration.

Below, we look at some of the specific initiatives planned to restrict PFAS where this balancing act is in train.

Comprehensive restriction proposal under REACH

In January 2023, authorities from Germany, the Netherlands, Denmark, Sweden, and Norway submitted a proposal to the European Chemicals Agency (ECHA) to restrict the manufacture, use, and marketing of all PFAS under the EU’s Registration, Evaluation, Authorisation and Restriction of Chemicals regulation (REACH). Their proposal recommends wide ranging restrictions on the manufacture, placing on the market and use of around 10,000 PFAS.

Following the 2023 consultation on the proposal, the five authorities who submitted the proposal, along with ECHA’s scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC), have been considering the 5,600 comments received.

In November 2024, ECHA provided an update, focusing on the contributions on risks, available alternatives, and socio-economic implications. These responses have highlighted the uses of PFAS that were not specifically named in the original proposal, including sealing applications, technical textiles, printing applications and other medical applications, such as packaging and excipients for pharmaceuticals.

The original proposal suggested two options: a full ban or a ban with time limited derogations where alternatives are not yet available. Consideration is also now being given to whether restriction options other than a ban may help to reduce PFAS emission following these comments, in addition to the need for appropriate derogations.

Provisional conclusions have been reached on five sectors: consumer mixtures and miscellaneous consumer articles, cosmetics, ski wax, metal plating and manufacture of metal products and petroleum and mining. These conclusions will be documented in the final consolidated opinion from both RAC and SEAC, sent by ECHA to the European Commission.

This assessment is currently underway for the use of PFAS in certain industrial applications, such as batteries, fuel cells and electrolysers. The same assessment will also be carried out for other sectors, for example medical devices and semiconductors, provided that such information has been brought forward in the consultation. In addition, information has been submitted in the consultation that may form a basis for alternative restriction options for, for example, fluoropolymers in manufacturing, service life and end of life, while still adhering to the purpose of the proposal to minimise emissions to the environment. Final opinions from ECHA’s scientific committees are expected in 2025, and a decision by the European Commission could follow soon thereafter.

This ongoing work – future evaluations are planned this month, with discussions on fluorinated gases, transport, and energy applications, followed by reviews on lubricants, medical devices, and electronics and semiconductors – means that draft legislation may not be ready until later into 2025.

The European Commission’s upcoming chemicals industry package marks a critical milestone in Europe’s transition towards a more sustainable and efficient chemical regulatory system. With the REACH revision and PFAS restrictions at its core, the package promises to create a healthier environment while supporting businesses through clearer regulations and innovative incentives.

Packaging and Packaging Waste Regulation

In March 2024, EU law makers reached a provisional agreement on the Packaging and Packaging Waste Regulation (PPWR), which will introduce several significant changes to packaging regulations, including restricting the use of PFAS in food contact packaging. This measure aims to safeguard consumer health while also aligning with the EU’s circular economy goals.

The regulation mandates reductions in packaging waste, sets ambitious recycling targets and includes a ban on PFAS in food contact materials to contribute to a more sustainable use of resources. The restrictions set limits of 25 parts per billion (ppb) for a targeted PFAS, 250ppb for the sum of the targeted PFAS measured, and 50 parts per million (ppm) for all PFAS, including polymeric PFAS. These thresholds align with the broader proposed universal restriction on PFAS.

The PPWR was formally adopted on 16 December 2024 and entered into force on 11 February 2025. The regulation will be applied 18 months after the date of entry into force, so 11 August 2026. To avoid overlap with existing regulations, the PPWR mandates a review by the European Commission within five and a half years, where  the need for amendments or repeal will be assessed.

PFHxA Restriction

In September 2024, the European Commission adopted a restriction on perfluorohexanoic acid (PFHxA), a subgroup of PFAS. This targets its use in textiles, cosmetics, food packaging, and certain firefighting foams. The restriction will ban the sale and use of PFHxA in consumer textiles, such as rain jackets; food packaging, like pizza boxes; consumer mixtures such as waterproofing sprays; cosmetics; and in some firefighting foam applications.

These restrictions will start to apply from 10 October 2026 with transitional periods of 18 months to five years to facilitate the development of safer alternatives. It does not affect other applications of PFHxA, for example in semiconductors, batteries or fuel cells for green hydrogen.

Updates to drinking water standards

The European Environment Agency has reported that the widespread presence of PFAS in European waters is undermining the objectives of the EU’s Water Framework Directive. This has prompted reforms to the EU Drinking Water Directive, where stricter limits on PFAS concentrations have been introduced.

The agency highlights the need to expand the list of PFAS substances monitored in surface and groundwater, with an ongoing proposal for this expansion since 2022, despite resistance from some EU member states. From 2026, the revised directive will enforce a maximum of 0.1 µg/L for the sum of 20 specific PFAS and 0.5 µg/L for the total concentration in drinking water. This significant step aims to improve public health by ensuring safer drinking water across all member states.

New law bans PFAS in consumer products in France

On 27 February 2025 a new law in France for the protection of the public against risks associated with PFAS entered into force. The law bans the fabrication, the import, the export and the marketing of cosmetics, ski waxes, clothing, footwear and their waterproofing agents that contain PFAS. Starting 2030, all textiles containing PFAS – with a few essential exceptions – will be banned in France. Other products were taken out of the regulation since they have been included in the PPWR.