First Published – 17/02/2023.
Last Updated – 2/11/2025.
ECHA Publishes PFAS Restriction Proposal
On 13th January 2023, the submission of a PFAS restriction proposal was made to the European Chemicals Agency (ECHA) by five European authorities: Denmark, Germany, the Netherlands, Norway, and Sweden.
The authorities collaborated on this PFAS proposal to limit the use of Per- and polyfluoroalkyl substances (PFAS) in the European Union after a comprehensive study spanning three years. This study examined PFAS usage, their environmental and health risks, and industry data. The evaluation involved consultation of scientific literature, stakeholder engagement, and requests for information from businesses, public authorities, and organisations.
On 7th February 2023, ECHA published this restriction proposal, which seeks to ban both the use and production of PFAS to mitigate their harmful effects on humans and the environment.
PFAS refers to a class of more than 10,000 synthetic chemicals identified as one of the main factors of their long-lasting presence in nature and are suspected of causing various health hazards, e.g., the disruption of the endocrine system, liver toxicity, and cancer. The phrase “forever chemicals” mainly refers to these compounds that have an extremely slow degradation rate.
Due to their water and dirt-resistant properties, PFAS have been found in almost every aspect of your daily life, such as textiles, food packaging, non-stick cookware, ski waxes, electronic devices, and paints. On the industrial side, PFAS are used in chrome plating, foam suppression, and a few types of speciality plastics. The presence of PFAS in both consumer and industrial products is leading to issues with regulations and compliance, which is causing trouble for businesses located anywhere in the world.
Proposed EU PFAS Restriction Process
The EU restriction process will follow several structured steps:
- Scientific Committee Review: ECHA’s Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) will first examine whether the restriction proposal meets REACH legal requirements. This step is crucial for scientific validation and compliance assessment.
- Public Consultation: A six-month consultation will allow stakeholders, including manufacturers, NGOs, and researchers, to provide information or opinions on the proposal. Public input ensures transparency and considers industry realities.
- Committee Opinions: RAC and SEAC will present scientific and socio-economic opinions on the proposal, expected to take up to 12 months.
- European Commission Decision: Based on committee opinions, the European Commission will draft a final proposal for member state voting. The restriction is expected to enter into force by 2025.
The scientific rigour as well as the socio-economic feasibility of the ban are ensured by this organised method, which balances the environmental and health advantages with the possible effects that companies dependent on PFAS may face.
Key dates in the EU PFAS restriction process
| Year | PFAS proposal process |
| 2020 | January: First meeting | May-July: Call for evidence |
| 2021 | July-October: 2nd stakeholder consultation | October: Start of drafting of proposal |
| 2023 | 13th January 2023: Submission of the dossier with the new proposal |
| 7th February 2023: The new proposal is published by ECHA. | |
| 22nd March: Open consultations for 6 months (until 22nd September 2023) | |
| 5th April: online information session by ECHA | |
| 2024 | Opinion of Committees |
| 2025 | COM decision Entry into force |
| 2026 / 2027 | Restriction becomes effective |
Every milestone in the timeline opens up possibilities for stakeholders to adjust their activities, carry out PFAS lab testing, and confirm that they are in line with future regulations. Enterprises are taking advantage of this interval to assess the cost of PFAS analysis, streamline their testing approach, and initiate their process changes to reduce the PFAS content in their products.
Summary of the PFAS Proposal
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).”
Conditions of Restriction
1.Shall not be manufactured, used, or placed on the market as substances on their own.
2.Shall not be placed on the market in:
a. Another substance, as a constituent
b. A mixture
c. An article
In a concentration of or above:
- 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded).
- 250 ppb for the sum of PFAS measured as a sum of targeted PFAS analysis.
- 50 ppm for PFAS (polymeric PFAS included). Total fluorine exceeding 50 mg F/kg requires documentation proving fluorine content from either PFAS or non-PFAS.
Manufacturers are always looking for ways to use PFAS laboratory services in order to ensure that they conform to these limits of concentration. Certified PFAS test laboratories offer not only selective PFAS analysis but also a measurement of total organic fluorine (PFAS TOF), which is very important in the implementation of the new restriction.
Global Regulatory Landscape
Europe is implementing its single biggest ban on PFAS that will have a global impact, and other regions are adopting similar measures. The European Chemicals Agency (ECHA) has proposed this historic restriction to limit the use of per- and polyfluoroalkyl substances (PFAS) across a wide range of products. This move significantly increases the demand for reliable PFAS analysis and total organic fluorine testing, highlighting the role of accredited PFAS testing labs and specialised PFAS testing services.
Similarly, the California PFAS ban and associated California PFAS regulations, along with the Colorado PFAS regulations, are driving manufacturers to adopt standardised testing procedures to ensure compliance in multiple markets.
There are strict California PFAS regulations and a California PFAS ban in the US, which require extensive PFAS testing in consumer products, especially in food contact materials and textiles. The state of Colorado has also given a go-ahead to the ban of toxic chemicals in products, such as PFAS, for the purpose of safeguarding human health and the environment. To comply with these laws, PFAS analysis is usually required by certified PFAS testing labs that are capable of producing accurate and reproducible results.
Worldwide alignment of PFAS regulations is the main factor that is causing the need for standardised PFAS testing services to be so high. Companies that export to more than one jurisdiction have to rely on laboratory data to fulfil the regulatory requirements of both the EU and the U.S. The implementation of the high-resolution mass spectrometry technique (LCMSMS/GCMS) enhances the capability of measuring both individual PFAS compounds and total organic fluorine (TOF PFAS), thereby achieving complete compliance.
The Role of PFAS Testing in Compliance
PFAS testing that adheres to regulatory standards has major significance in the decision process of cooperating with a specialised PFAS labs. By such a partnership, manufacturers can trace the presence of PFAS in consumer products. Reliable PFAS lab testing can generate data that is suitable for internal audits, regulatory reporting, and risk management activities.
In an optimisation of a company’s compliance structure/operating decisions, businesses often weigh PFAS testing cost and PFAS analysis cost. The costs vary depending on the matrix to be tested, the number of PFAS analytes, and whether total organic fluorine measurements will be necessary. However, the companies that invest in testing greatly reduce their legal and reputational risks and become a way to the implementation of sustainable manufacturing practices.
Furthermore, businesses are utilising PFAS testing in product development to ensure that new materials and their formulations comply with the recently European- and U.S.-based regulations. Early testing can get rid of the assumption of expensive recalls, fines, and supply chain disruptions.
Eurofins Sustainability Services PFAS Testing
Eurofins Sustainability Services offers a comprehensive portfolio of PFAS testing solutions designed to meet diverse regulatory and industry requirement. The services cover consumer products. The services offered include targeted PFAS analysis, PFAS TOF/TF measurement, as well as instruction for the global regulatory compliance sector. Providing precise and timely results can help companies to fulfill the requirements for PFAS labs in the EU, US, Asia, and other international markets.
Meeting PFAS regulations is essential for businesses in today’s global market. Eurofins Sustainability Services leverages technical expertise and advanced PFAS testing services to provide reliable results that ensure compliance with the US nation-wide, state-level regulations (California PFAS regulations, Colorado PFAS regulations), Canada, Asia, and emerging EU restrictions, helping companies maintain product safety and consumer trust.
Conclusion
PFAS are persistent chemicals with widespread applications, posing significant environmental and health risks. The proposed EU PFAS restriction represents the largest ban on these substances, reflecting a global trend toward stricter chemical regulation.
In order to thoroughly oversee the adherence to rules and regulations, companies can perform diligent PFAS testing, collaborating with specialised PFAS laboratory testing for measuring individual compounds, total organic fluorine, and confirming compliance with new regulations.
For more information, visit the ECHA website.
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