PFAS restrictions in the EU. When the bans apply and what producers need to do

PFAS restrictions in the European Union are no longer a distant prospect. Some bans already apply, further ones take effect in 2026, and hanging over all of this is the broadest restriction in the history of the REACH Regulation, covering more than 10,000 substances. If your company manufactures, imports or uses articles containing PFAS, the time to prepare is now. Below we explain what already applies, what takes effect in the coming months and where to start.

What PFAS are and why regulators have turned their attention to them

PFAS, or per- and polyfluoroalkyl substances, are a group of over ten thousand chemical compounds valued for their resistance to water, grease and high temperatures. They are found in textiles, packaging, coatings, cosmetics, electronics, firefighting foams and many industrial processes. The problem is that PFAS barely degrade in the environment and accumulate in living organisms. Hence their popular name: forever chemicals. The European Union is responding with a series of restrictions that reach further with every passing year.

What already applies

Several groups of PFAS are already banned or restricted. PFOS and PFOA are subject to bans under the Regulation on persistent organic pollutants (POPs). C9-C14 perfluorocarboxylic acids, their salts and related substances have been restricted under Annex XVII to REACH since February 2023. A number of PFAS are also on the Candidate List of substances of very high concern (SVHC), which in itself triggers information duties in the supply chain, including notifications to the SCIP database.

What takes effect in 2026

The year 2026 brings two important deadlines.

The first concerns PFHxA. Commission Regulation (EU) 2024/2462 restricted the use of perfluorohexanoic acid, its salts and related substances. The first bans start to apply in April 2026, with transitional periods for individual uses ranging from 18 months to 5 years. The restriction covers, among other things, consumer textiles, footwear, food contact paper and board, cosmetics and firefighting foams used for training purposes. Critical uses for which no safe alternatives currently exist, such as semiconductors and lithium-ion batteries, remain outside its scope.

The second deadline concerns firefighting foams. Commission Regulation (EU) 2025/1988, published in October 2025, sets a timetable for phasing PFAS out of firefighting foams. The first obligations, including a ban on portable fire extinguishers and requirements for the continued use of PFAS-containing foams, start to apply in October 2026. The final ban on placing on the market and using foams containing PFAS at a concentration of 1 mg/l or more will take effect in October 2030. Businesses that continue to use such foams must meet additional requirements during the transitional period, including labelling and wastewater management.

The universal restriction: the biggest project in the history of REACH

In parallel, a procedure is under way that will decide the future of the entire PFAS group. In January 2023, Denmark, Germany, the Netherlands, Norway and Sweden submitted a proposal to restrict the manufacture, placing on the market and use of PFAS as an entire class of substances. The proposal relies on a structural definition: it covers any substance containing at least one fully fluorinated carbon atom. This means that what determines whether a substance is caught is its chemical structure, not its trade name or how it has been classified to date.

In March 2026 the procedure entered its decisive phase. ECHA’s Committee for Risk Assessment (RAC) adopted its final opinion supporting the restriction, and the Committee for Socio-Economic Analysis (SEAC) published a draft opinion along the same lines. The public consultation on the draft SEAC opinion closed in May 2026. The final SEAC opinion is expected by the end of 2026. The European Commission will then prepare a draft amendment to Annex XVII to REACH, and adoption of the restriction is realistically possible in 2027. Only the final regulation will settle the scope of the bans, the transitional periods and the derogations for individual sectors.

For businesses, one conclusion follows. The question is no longer whether PFAS will be restricted, but when and on what terms this will affect a given product.

Where to start: five steps for producers and importers

1)   Map the PFAS in your products. Review formulations, specifications and safety data sheets. Ask your suppliers directly about the presence of fluorinated substances, including in components and coatings. The structural definition means the issue may extend to substances no one has ever called PFAS before.

2)   Check whether the restrictions already adopted apply to you. The deadlines for PFHxA and firefighting foams run regardless of the fate of the universal restriction.

3)   Put your information duties in order. The presence of an SVHC in an article above 0.1% already triggers a duty to inform customers and to notify the SCIP database.

4)   Assess the availability of alternatives and start talking to your suppliers. The transitional periods under the universal restriction will depend on the availbility of substitutes. Companies that begin substitution early will gain an advantage when their competitors find themselves against the wall.

5)   Document your analysis. If your use qualifies for a derogation, the evidence needs to be gathered now, not after the rules take effect.

Legal status as at July 2026.

How we can help

We track the work on the PFAS restriction as it happens and advise companies at every stage of their preparations: from auditing the product portfolio, through supplier communication and verifying information duties, to building a strategy for derogation applications. If you would like to check how the upcoming restrictions will affect your products, please get in touch.