EU PFAS Restriction: Current Status, Scope, Timeline and Derogations

The EU PFAS restriction is a proposed restriction under the EU REACH framework covering the manufacture, placing on the market and use of per- and polyfluoroalkyl substances (PFAS). The proposal is being assessed through the European Chemicals Agency (ECHA) restriction process, with the final scope, conditions, derogations and transition periods determined through the regulatory process.

For manufacturers, the practical challenge is not simply determining whether a substance is a PFAS. Companies need to identify where PFAS may occur across materials, components and products, determine which uses could be affected, collect supporting supplier information, and maintain evidence as the regulatory position develops.

Current status: The EU PFAS restriction remains subject to the REACH regulatory process. Manufacturers should distinguish between provisions proposed during the restriction process and requirements that become legally applicable after the final regulatory decision.

What is the EU PFAS restriction?

The European PFAS restriction is being developed under REACH to address the risks associated with the broad group of per- and polyfluoroalkyl substances.

Unlike a restriction targeting one individual substance, the proposal takes a group-based approach to PFAS. This is significant for manufacturers because PFAS can occur across different materials, components, applications and supply chains.

The restriction process considers:

• PFAS substances and groups within scope
• uses and applications
• concentration or threshold conditions
• derogations and transition periods
• technical feasibility of alternatives
• socioeconomic considerations
• sector-specific uses

The final legal requirements should therefore be assessed against the final restriction text and applicable implementation dates, rather than treating the original proposal as the final obligation.

For background on the wider regulatory relationship, see PFAS and REACH compliance.

What is the current status of the EU PFAS restriction?

The restriction proposal is progressing through the REACH restriction process.

ECHA's scientific committees evaluate the proposal and associated evidence before the European Commission considers the regulatory decision. The process includes scientific assessment, socioeconomic considerations and examination of the proposed restriction conditions.

Manufacturers should therefore monitor:

• ECHA committee opinions and regulatory updates
• changes to the proposed restriction conditions
• substance and use scope
• proposed concentration limits
• derogations and transition periods
• sector-specific provisions
• the final EU regulatory decision

The status of the proposal can change as the scientific and regulatory assessment progresses. Compliance teams should therefore avoid treating an early proposal, committee opinion or draft provision as an already applicable legal requirement.

EU PFAS restriction timeline

The EU PFAS restriction has progressed through several stages of the REACH restriction process.

The important distinction for compliance teams is between proposed requirements and final legally applicable requirements.

For ongoing regulatory developments, see the latest ECHA PFAS restriction developments.

What does the EU PFAS restriction cover?

The proposed restriction is designed around PFAS as a broad substance group rather than a single chemical.

For manufacturers, scope assessment should therefore go beyond checking a finished product against a single substance list.

A practical assessment should consider:

Substance → material → component → product → use → jurisdiction → applicable restriction

This is particularly important where PFAS may be present in specialised materials or applications and where supplier information is incomplete.

Companies should also distinguish between:

• PFAS intentionally used in a material or component
• PFAS present as part of a formulation
• PFAS associated with a manufacturing process
• PFAS present in articles or finished products
• applications potentially subject to specific conditions or derogations

For electronics manufacturers, see PFAS in electronics.

What are PFAS derogations and exemptions?

Derogations are an important part of the EU PFAS restriction because some applications may require additional time or specific conditions where technically or economically viable alternatives are not yet available.

However, a proposed derogation should not automatically be treated as a permanent exemption.

Manufacturers should assess:

• the specific use covered
• the applicable conditions
• any concentration or threshold requirements
• the duration of the derogation
• whether reporting or documentation is required
• whether an alternative is technically available
• whether the provision applies to the company's specific product or use

This makes derogation management an ongoing compliance activity rather than a one-time determination.

What does the EU PFAS restriction mean for manufacturers?

The impact depends on where PFAS occur in the company's products and supply chain.

A manufacturer should establish a traceable PFAS assessment covering:

1. Identify potentially affected materials and components

Review bills of materials, material declarations, specifications and supplier information to identify components or materials that may contain PFAS.

2. Collect supplier information

Request relevant substance and material information from suppliers, particularly where internal product data does not identify PFAS composition.

Where supplier information is incomplete, document the information gap rather than treating an unknown response as confirmation of compliance.

For supplier-data processes, see PFAS supplier chemical transparency.

3. Map PFAS to products

Connect supplier and material information to the affected component, BOM and finished product.

A useful traceability chain is:

Supplier → material → component → BOM → product

4. Determine regulatory applicability

Assess the identified PFAS against:

• substance scope
• use
• concentration or threshold
• applicable restriction condition
• derogation or transition provision
• relevant jurisdiction

5. Maintain evidence

Compliance teams should retain the information supporting their assessment, including:

• supplier declarations
• material information
• laboratory evidence where applicable
• product/BOM assessments
• regulatory assessments
• decisions regarding derogations
• historical records

6. Monitor regulatory changes

Because the restriction is evolving, the assessment should be revisited when relevant regulatory provisions change.

Which industries may be affected by PFAS restrictions?

PFAS are used across a wide range of industrial applications, so the regulatory impact depends on the specific material, component, use and availability of alternatives.

Regilient's existing content covers PFAS considerations for sectors including:

• Electronics
• Electrical and electronic equipment
• Automotive
• Medical devices
• Industrial equipment
• Healthcare applications

For medical-device considerations, see PFAS compliance in healthcare and medical devices.

For electronics, see PFAS in electronics.

EU PFAS restriction and REACH: what is the difference?

The proposed PFAS restriction is being developed under REACH, but PFAS compliance and general REACH compliance are not interchangeable concepts.

REACH compliance covers the wider framework of substance registration, restrictions, authorisation, SVHC obligations and other applicable requirements.

PFAS compliance focuses specifically on PFAS-related substances, uses, restrictions, reporting and associated requirements.

A manufacturer may therefore need to assess both the general REACH requirements applicable to its products and the PFAS-specific requirements relevant to particular substances or uses.

See REACH, RoHS and PFAS compliance data alignment for the relationship between these regulatory data requirements.

What should manufacturers do now?

Manufacturers do not need to wait for the final restriction to begin preparing their data.

A practical preparation process is:

1. Build a PFAS inventory

Identify products, components and materials that could contain PFAS.

2. Close supplier-data gaps

Request relevant declarations and supporting information from suppliers.

3. Screen the BOM

Map material and substance information to affected components and products.

4. Assess applicability

Check the relevant substance, use, threshold, restriction condition and derogation.

5. Document the decision

Maintain evidence supporting the compliance assessment.

6. Monitor regulatory changes

Update the assessment when ECHA, the European Commission or the final restriction requirements change.

For broader PFAS compliance requirements, see PFAS compliance for manufacturers.

EU PFAS restriction vs other PFAS requirements

The EU restriction is only one part of the global PFAS regulatory landscape.

Manufacturers selling products internationally may also need to assess requirements in other jurisdictions.

For example:

• United States: TSCA reporting and recordkeeping requirements
• Japan: PFAS controls under the Chemical Substances Control Law
• Canada: PFAS reporting requirements
• Individual US states: additional product restrictions and reporting requirements

See the relevant Regilient resources for TSCA PFAS reporting and recordkeeping, Japan PFAS requirements, and Canada PFAS reporting requirements.