Background
On August 20, 2025, the European Chemicals Agency (ECHA) published the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the EU’s chemicals regulation REACH. The updated proposal follows a public consultation that ran from March 22 to September 25, 2023 (FPF reported). The restriction proposal was jointly prepared by authorities in Denmark, Germany, the Netherlands, Norway, and Sweden, and initially submitted to ECHA on 13 January 2023 (FPF reported).
Regarding food contact materials
The updated proposal does not include general exceptions or derogations regarding food contact materials (FCMs) compared to the initial text. The rationale is that existing FCM regulations primarily address food safety but not environmental health impacts. Therefore, the restriction is considered necessary to cover these broader concerns.
During the consultation, stakeholders provided evidence that substitution away from PFAS is not currently possible for only two applications (FPF reported):
- Polymer processing aids used in flexible plastic film extrusion (for both food and non-food applications).
- PFAS used in non-stick surfaces in industrial bakeware.
As a result, the current proposal foresees derogations for these two applications. For all other FCM uses, including paper packaging, HDPE containers, and consumer non-stick cookware, substitutes are available, and PFAS would be restricted. The proposed framework would establish an 18-month transition period, followed by a five-year derogation for flexible plastic film extrusion and industrial bakeware. After this period, the ban would apply to these applications as well.
Plan forward
In a communication note from August 27, 2025, ECHA announced that it aims to complete its scientific evaluation of the proposed PFAS restriction by the end of 2026. Although eight additional sectors have since been added to the proposal, the agency has indicated that these will not be considered separately. Instead, the agency’s scientific committees, RAC (Risk Assessment Committee) and SEAC (Socio-Economic Analysis Committee), plan to finalize their discussions on the 14 sectors originally covered, along with PFAS manufacturing and horizontal issues, by the end of 2025. This schedule would allow ECHA to issue the RAC opinion, the SEAC draft opinion, and to conduct a public consultation on the latter during the first half of 2026. According to ECHA, this approach will ensure that more than 90% of PFAS volumes and emissions are addressed in the opinions to be sent to the European Commission.
The Commission is expected to receive the final RAC and SEAC opinions, together with the Background Document, in 2027. These will provide the basis for regulatory decisions on “how to best address the different use sectors (14 sectors plus the additional eight sectors), PFAS manufacturing and horizontal issues.”
References
ECHA (August 20, 2025). “Updated PFAS restriction proposal.”
ECHA (August 27, 2025). “ECHA update on the per- and polyfluoroalkyl substances (PFAS) restriction process.”
Read more
Luke Buxton (August 28, 2025). “EU PFAS restriction update prompts call for full fluoropolymer exemption.” Chemical Watch News & Insight.
