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  • Regulatory Update

EU Sets PFAS Restrictions in Consumer Products

EU establishes regulations to limit the use of PFAS in consumer products under REACH, POP legislation and the SVHC list. Larger proposals are being developed to cover a greater number of substances.

Scientists working in Laboratory having discussion on testing data together.

May 11, 2023

By Roberta Canciello, senior technical specialist, Retail Consumer Products team, UL Solutions

Several regulatory actions are being taken to regulate per- and polyfluoroalkyl substances (PFAS) in consumer products in the EU. 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 both humans and the environment.

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

In the EU, some PFAS are already regulated under REACH and POP legislation (see Table 1) and the SVHC list, while other groups are being proposed for restrictions (see Table 2).

Table 1

  PFAS currently restricted in the EU  
Substance group Limits in articles Applicable from
PFOA and PFOA related substances (various cas numbers) 25 ppb as total content and 1000 ppb for PFOA-related substances July 4, 2020
PFOS (various CAS numbers) 1 microg/m2 for treated articles and 0.1% by weight as total content Aug. 25, 2010
PFCA and PFCA related substances (various CAS numbers) 25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA-related substances Feb. 25, 2023

Table 2

  PFAS groups under proposal for restrictions in the EU  
Substance group Limits in articles Applicable from
PFHxS 25 ppb for the sum of PFHxS and their salts or 1,000 ppb for the sum of PFHxS -related substances Still under proposal
PFHxA 25 ppb for the sum of PFHxA and their salts or 1,000 ppb for the sum of PFHxA -related substances Still under proposal

The current larger proposals for restriction (see Table 3) will cover a greater number of substances with specific exemptions and different dates of entry into force for specific uses.

PFAS are defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom without any H/Cl/Br/I attached to it.

A substance that only contains the following structural elements is excluded from the scope of the proposed restriction: -CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (-CH2-), an aromatic group, a carbonyl group (-C(O)-), -OR’’, -SR’’ or –NR’’R’’’, and where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-).

Table 3

  Larger proposals for PFAS restriction  
Restriction proposals Limits in articles Applicable from
Option 1 Full ban Still under proposal and there will be a transition period of 18 months without derogations.
Option 2
  • 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification)  
  • 250 ppb for the sum of PFAS measured as sum of targeted PFAS analysis, optionally with prior degradation of precursors (polymeric PFAS excluded from quantification)
  • 50 ppm for PFASs (polymeric PFASs included)
If total fluorine exceeds 50 mg F/kg, the manufacturer, importer or downstream user shall provide proof of the fluorine measured as content of either PFAS or non-PFAS to the enforcement authorities upon request.
Still under proposal and there will be a transition period of 18 months with derogation for some uses.

To ensure compliance with regulatory requirements, relevant enterprises should familiarize themselves with these requirements as early as possible and adapt their protocols and manuals to investigate the presence of PFAS in their products.

UL Solutions can assist customers in finding the best strategies for complying with PFAS regulations in terms of both testing and communication along the supply chain. Additionally, we can provide support and training to help customers prepare for regulatory changes and upcoming restrictions on PFAS.


Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants (recast) (Text with EEA relevance)Text with EEA relevance

COMMISSION REGULATION (EU) 2021/1297 of 4 August 2021 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards perfluorocarboxylic acids containing 9 to 14 carbon atoms in the chain (C9-C14 PFCAs), their salts and C9-C14 PFCA-related substances

Persistent organic pollutants – perfluorohexane sulfonic acid (PFHxS)

Registry of restriction intentions until outcome

Submitted restrictions under consideration