PFAS in the EU: main applications and latest ECHA proposal

Perfluoroalkylated substances, or PFASs, are a vast group of fluorinated compounds. PFASs include thousands of synthetic chemicals with wide industrial and consumer applications. Many PFASs are surfactants. Thus, they are used as stain-resistant, water-resistant, oil-resistant coatings for textile, leather, carpets, paper, cardboard, food contact materials, and many others. Other sectors of application are aerospace, defense, automotive, aviation, construction, electronics, firefighting, and medical articles. Indeed, remaining stable under intense heat is one of the great properties PFASs have.

PFAS exposure to cause serious harm to human health

PFASs contaminate soil, groundwater, and drinking water, a type of environmental pollution difficult and costly to remediate. Some PFASs persist in the environment for a long time. Consequently, humans are exposed to always higher concentrations over time, having negative consequences on health. PFASs even accumulate in people, animals, and plants. Their effect can be toxic, from toxicity to reproduction and development of foetuses, to cancer in humans, and interferences with the endocrine systems (hormones).

PFASs’ emissions into the environment come from direct and indirect sources. For example, they are released through industrial facilities but also through cosmetics, clothing, food contact materials. People come in contact with them from the environment around them, the food they eat, the water they drink.

REACH update: ECHA proposes alternatives and possible bans

On 20 August 2025, the European Chemicals Agency (ECHA) announced the publication of the updated proposal to restrict PFAS under REACH, the EU Regulation on chemicals.

ECHA sector assessment

Among others, the Proposal draft updated the list of main applications and sub-uses of PFASs. The full list includes:

• Firefighting foam, covered by a separate restriction proposal.
• TULAC (Textile, upholstery, leather, apparel, and carpets): home textiles, consumer apparel, professional apparel and PPE, leather, and other home fabric treatments (sprays).
• Food contact materials and packaging: non-stick surfaces in cookware and appliances, non-stick coatings in industrial and professional bakeware, paper and board packaging, use of polymer processing aids containing PFASs for plastics packaging production, packaging uses of F-HDPE (fluorinated high density polyethylene), and other packaging applications.
• Metal plating and manufacture of metal products: hard chrome plating, decorative chrome plating on plastics and plating with metals other than chrome, manufacture of metal products not addressed elsewhere.
• Consumer mixtures and miscellaneous consumer articles: cleaners, waxes and polishes, dishwashing products, windscreen treatments for automobiles and also windscreen wiper fluids, anti-fogging agents for spectacles and goggles, musical strings, use in pianos, fishing lines.
• Cosmetics, including peptide synthesis for cosmetic applications.
• Ski wax, assessed as a whole.
• Applications of fluorinated gases: refrigeration, air conditioning and heat pumps, foam blowing agents, propellants, cover gases, clean fire suppressants, preservation of cultural paper-based materials, insulating gas in electrical equipment.
• Medical devices: implantable medical devices (including implants and meshes), wound treatment products (non-implantable, non-invasive medical devices), tubes and catheters (non-implantable medical devices), sterilization gases, vision applications (invasive medical devices), packaging of medical devices.
• Transport: uses of fluoropolymers and perfluoropolyether in transport vehicles (with certain exceptions), reflective coatings for traffic signs, additives to hydraulic fluids in transport vehicles, devices for motion control solutions, mobile air conditioning and heat pump systems, transport refrigeration.
• Electronics and semiconductors: wires and cables, insulation material of electronics components, coating/film of electronic components, electronics components, photonics, plastic additives, heat transfer fluids, vapor phase soldering, electronic data storage, photolith ography, etching for semiconductor.
• Energy sector, assessed as a whole.
• Construction products: architectural coatings and paints, film/foil for greenhouses, window frames, bridge and building bearings, processing aids for production of construction articles, polymer additives used for fire safety purposes, surface protections, wetting/leveling agents in e.g. coatings, paints and adhesives, window film manufacturing, plumbing applications.
• Lubricants, assessed as a whole.
• Petroleum and mining: tracers, anti-foaming agents.
• Printing: toners, latex printing inks, pigment and colourants, PTFE powders, photosensitive materials, electrophotographic press units, kinetic printing components, printing plates (offset and letterpress printing), rollers, surfactant used in printing equipment.
• Sealing, assessed as a whole.
• Machinery, assessed as a whole.
• Other medical applications: fluorinated gases as propellants in pressurised metered-dose inhalers (pMDIs), semiflourinated alkanes (SFAs) as excipients in medicinal products for ophthalmic and dermatological therapies, PFAS-containing in release liners and backing film in transdermal patches, fluoropolymer-coated rubber stoppers in vials/flasks for injectable medicinal products, fluoropolymer-coated packaging of transdermal patches, fluorinated HDPE packaging, fluoropolymer-coated canisters in pressurised metered-dose inhalers, fluoropolymer-coated plungers in pre-filled syringes, PFAS in pre-filled injection pens and autoinjectors.
• Military, assessed as a whole.
• Explosive, assessed as a whole.
• Technical textiles: outdoor technical textiles, architectural membranes, other tensile fabrics and other constructions applications, filtration and separation media, removable covers for industrial process equipment, medical applications, technical textiles in transport vehicles.
• Broader industrial uses: solvents, catalysts, processing aids, ionic liquids.

In particular, ECHA proposal includes the assessment of eight sectors which were not part of the initial REACH update. More specifically, the sectors are: printing, sealing, machinery, military, and other medical applications as well as explosives, technical textiles, and broader industrial uses.

PFASs bans and alternatives

The list does not present the products and sectors subject to a ban proposal necessarily. The updated Proposal presents an assessment of whether there are suitable alternatives for the sectors identified as main PFASs’ sources. Especially, the assessment includes a cost impact and the substitution potential of the available alternatives. When there are suitable alternatives, the Proposal presents a ban.

Next steps: ECHA’s RAC and SEAC committees to analyse the proposal

The Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC) – part of the European Chemicals Agency (ECHA) – are analysing the updated Proposal. Subsequently, they will provide their opinion to the European Commission. ECHA aims to complete its evaluation by the end of 2026.

Do you have any questions on product compliance? Contact PRODlaw here or at prodlaw@obelis.net.

References:

European Commission (2025). Food Safety – PFAS. Retrieved on 01/10/2025.

ECHA. (2025). ECHA publishes updated PFAS restriction proposal. Retrieved on 01/10/2025.

ECHA. (2025). ECHA publishes updated PFAS restriction proposal. Retrieved on 02/10/2025.

ECHA. (2025). Background Document to the Opinion on the Annex XV dossier proposing restrictions on Per- and polyfluoroalkyl substances (PFASs). Retrieved on 02/10/2025.