EU Sets PFAS Restrictions in Consumer Products

By Roberta Canciello, Technical Manager, Retail and Consumer Products team, UL Solutions

In the European Union (EU), several actions are being taken to regulate per- and polyfluoroalkyl substances (PFAS) in consumer products. These toxic substances are also known as “forever chemicals” due to their high persistence. Without the ability to degrade, their concentration in the environment will continue to increase. Exposure to these substances can have negative effects on humans and the environment.

PFAS comprise a group of about 10,000 mainly man-made substances used in numerous applications in the EU. These applications include textiles, food packaging materials, lubricants, refrigerants, electronics, construction materials and many more.

In the EU, some PFAS groups are already regulated under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation and persistent organic pollutants (POP) legislation (see Table 1) and the substances of very high concern (SVHC) list, whereas other groups are being proposed for restrictions (see Table 2).

Table 1 – PFAS currently restricted in the EU

The current larger proposals for restrictions (see Table 2) will cover a greater number of substances with specific exemptions and different dates of entry into force for specific uses.

PFAS is defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom without any hydrogen, chlorine, bromine, or iodine attached to it.

Table 2 – Larger proposals for PFAS restriction

The last updated draft proposal of universal restriction for PFAS published in August 2025 requires three Restriction Options (RO):

• a full ban with a transition period of 18 months (RO1)
• a ban with use-specific, mostly time-limited derogations (RO2)
• allowing continued use under strict conditions that minimize emissions over the full life cycle, i.e., regulatory options potentially allowing for adequate control of risks through means other than a ban (RO3).

All restriction options, RO1, RO2 and RO3, are considered sufficiently enforceable. RO1 is likely not implementable, and therefore also not manageable, while RO2 and RO3 are evaluated as implementable and manageable by the Dossier Submitter. Hence, RO2 and RO3 are concluded to be practical with regards to implementability, enforceability and manageability.

The restriction proposal is tailored to address the manufacturing, placing on the market, as well as the use of PFAS as such and as constituents in other substances, in mixtures and in articles above a certain concentration.

The restriction will apply 18 months from entry into force.

By way of derogation, the restriction shall not apply to some products, such as:

• active substances in biocidal products within the scope of Regulation (EU) 528/2012
• articles placed on the market before the date in paragraph 3 (including second-hand articles)
• PFAS used as transported isolated intermediates within the meaning of Article 3(15) of Regulation (EC) 1907/2006, provided that they are used for the service life of the article
• uses under product and process-orientated research and development [PPORD; art. 67(1) of EU-REACH]
• paper and board articles containing recovered material, with the exception of food-contact material and packaging
• textile articles containing recovered material, with the exception of toys as defined in Directive 2009/48/EC, until 13.5 years after EiF
• plastic articles containing recovered material, with the exception of food-contact material and food contact packaging and toys as defined in Directive 2009/48/EC, until 23.5 years after EiF
• production of PFAS with or without the use of fluorinated polymerisation aids in the production of polymeric PFAS under controlled conditions with average emission factors (= Annual emission of PFAS / total annual amount of PFAS manufactured on site) not exceeding
   
  1. 0.0090% to air, 0.0010% to water and 0% to soil for emissions of non-polymeric PFAS residues from polymerization aid technology in fluoropolymer manufacturing until end of 2030;
  2. 0.0030% to air, 0.0006% to water and 0% to soil for emissions of non-polymeric PFAS residues from polymerization aid technology in fluoropolymer manufacturing from end of 2030 onwards;
  3. 0.01% to all compartments for all PFAS emissions not mentioned above from sites manufacturing polymeric and non-polymeric PFAS 6.5 years after EiF.

On August 27, 2025, ECHA confirmed its “firm objective” to deliver the final Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) opinions to the Commission in 2026. Once these are received, the Commission will publish a draft amendment to Annex XVII of the EU REACH Regulation, which will detail the specific substance restrictions. The Commission will also consider the updated proposal submitted by the Member States, particularly as it relates to the eight newly covered sectors. The Commission must draft its own restrictions considering all available evidence and input (including the Member State proposals). Thus, even at this stage, further adjustments are possible. Political deliberations, trade considerations, and enforcement realities may all impact the final text. Businesses should remain vigilant for updates and prepare for multiple scenarios. The Commission’s draft will be submitted to the World Trade Organisation (WTO) to ensure international trade compliance.

The European Parliament and Council will usually have 2 months to formally object to the Commission proposal (the “objection period”), which can be extended (usually by an additional two months). If no objections are raised by the co-legislators during the objection period, the restriction proposal is formally adopted and published in the Official Journal of the EU.

For the application of specific derogations, it will be necessary to provide by May 31 of each calendar year a report to the Agency containing:

1. the derogation that the intended use belongs to;
2. the identity and quantity of the substances placed on the market in the previous year.

The Agency shall make the information available to the Commission and Member States by August 31 every year;

Manufacturers, importers and downstream users of fluoropolymers and perfluoropolyethers making use of any of the derogations  shall establish a site-specific management plan which shall include:

1. information on the identity of the substances and the products they are used in
2. a justification for the use;
3. details on the conditions of use and safe disposal.

In the main time, there were some EU Initiatives at the state level (Denmark and France) to introduce a legislation to limit PFAS that will enter into force in 2026, before the actual proposal under REACH for PFAS.

The Danish government has introduced a national ban on PFAS in clothing, shoes, and waterproofing agents. PFAS in professional clothing and safety clothing will not be part of the ban.

Elsewhere in the EU, France's National Assembly has published legislation to restrict the manufacture and sale of nonessential products containing PFAS, the first step in the legislative process.

As of January 1, 2026, the law bans the manufacture, import, export and marketing of the following PFAS-containing products:

• Any cosmetic product containing perfluoroalkylated and polyfluoroalkylated substances.
• Any wax product containing perfluoroalkylated and polyfluoroalkylated substances.
• Any textile clothing product, footwear and waterproofing agents for textile clothing products and footwear intended for consumers containing perfluoroalkylated and polyfluoroalkylated substances, except for textile clothing and footwear designed for the protection and safety of persons, particularly in the performance of national defense or civil security missions, and whose list is specified by decree.

From January 1, 2030, the manufacture, import, export and placing on the market, for a consideration or free of charge, of any textile product containing perfluoroalkylated and polyfluoroalkylated substances are prohibited. Exceptions are permitted for textile products required for essential uses, those contributing to the exercise of national security and for which no alternative solution exists, and technical textiles for industrial use.

The proposed thresholds are subject to these three cumulative conditions:

• For any PFAS measured by targeted analysis (excluding polymers): 25 ppb
• For the sum of PFAS measured as the sum of targeted analysis (with prior degradation of precursors where applicable, but excluding polymers): 250 ppb
• For PFAS, including polymers: 50 ppm

Sources: 

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02019R1021-20210315  

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202500718  

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32021R1297&rid=3  

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1608  

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202402462  

Projet de décret relatif aux modalités de mise en œuvre de la trajectoire nationale de réduction progressive des rejets aqueux de substances perfluoroalkylées et polyfluoroalkylées des installations industrielles | Consultations publiques  

https://www.retsinformation.dk/eli/lta/2025/464