The EU plans to ban PFAS in my products under REACH – how do I build an advocacy strategy and secure an exemption or transition period?

Case study Product law 23 April 2026

Client

Global manufacturer in the technology and industrial sector

The situation

The pan-European REACH restriction proposal on PFAS covering all non-essential uses represents one of the most significant regulatory risks for manufacturers whose products or processes depend on these substances. A negative outcome of the restriction proceedings would mean product reformulation, challenged business models and enormous adaptation costs. A global manufacturer in the technology and industrial sector, whose products contain PFAS, needed a comprehensive regulatory strategy at European level.

Our role

We were helping the client build a regulatory and advocacy strategy before EU institutions, ECHA and the European Commission and the governments of member states, with a primary focus on the Netherlands, Germany, Belgium, Norway, Denmark, Finland and Poland. Our goal was to build a common stakeholder approach to the restriction and, in time, secure an exemption or adaptation period for essential uses. We acted as coordinators of a multi-jurisdictional strategy, combining the Polish perspective with the European one.

The result

This is one of the most complex and strategically significant projects in EU chemical regulation on which we advise. It demonstrates that an effective response to a pan-European regulation requires three things simultaneously: in-depth knowledge of REACH, the ability to build stakeholder coalitions, and experience in conducting advocacy before EU institutions.

Is your company affected by the REACH PFAS restriction proposal? We can help build an effective strategy at EU level.

Product law

In this area, reacting when a problem arises is not enough. You need to act earlier. We advise clients on managing regulatory risk related to products, from composition and labelling, through packaging and environmental obligations, to strategies for entering the EU market and maintaining a secure position within it.

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