ECHA and the Dossier Submitters advise on the state of play and next steps of the Universal PFAS Restriction Proposal
On 15 October 2025, the Chair of the Committee for Socio-Economic Analysis (SEAC), European Chemicals Agency, joined the FPP4EU Collaboration Platform alongside representatives of BAuA and RIVM, to share latest developments and next steps in the Universal PFAS Restriction Proposal.
Current state of play
BAUA and RIVM presented insights into the final version of the extensive background document submitted in June and published by ECHA in August. Spanning over 3,300 pages, the document reflects input from over 4,400 stakeholders.
While the scope and hazard assessment remain largely unchanged from the original dossier, the new document strengthens the rationale for including fluoropolymers and introduces a new restriction option (RO3), which considers continued PFAS use under stricter emission controls. Eight additional sectors have been assessed, including military, explosives, and technical textiles.
The impact assessment has been refined with sector-specific proportionality matrices, and new proposals include derogations for second-hand articles, spare parts, and recycling streams. The document also recommends review periods for certain derogations and clarifies approaches to upstream supply chains and research exemptions.
The proposal is now progressing toward a key milestone: the finalisation of SEAC’s draft opinion, expected in March 2026. Once agreed, ECHA will launch a public consultation to gather feedback from stakeholders. This consultation will begin shortly after the draft is published and will remain open for 60 days.
Facilitating a smooth process
The SEAC chair explained that, to ensure clarity and structure, the consultation will take the form of a survey. Participants will be asked to respond to general questions about SEAC’s draft opinion and more detailed questions regarding SEAC’s evaluation of 14 sectors of use, including PFAS manufacturing. Responses must be submitted directly through the survey interface, as attachments will not be accepted. ECHA will provide written guidance to help respondents prepare and submit their input effectively.
To help stakeholders prepare for the consultation, ECHA will host a webinar on 30 October 2025. The session will explain the purpose of the consultation, the structure of the survey, the type of information being requested, and how to prepare data for submission. Participants will have the opportunity to submit questions in advance, some of which will be addressed during the webinar, with others answered in writing afterward.
A key tool for navigating the consultation will be the use mapping, intended to help respondents identify the correct use category for their input. This mapping will be published in three stages:
- Stage 1 (30 October 2025): ECHA will publish a provisional use structure covering the majority of sectors. Electronics, semiconductors, and PFAS manufacturing will be excluded at this stage, pending further discussion at SEAC in December.
- Stage 2 (Mid-December 2025): A draft use mapping will be released, along with guidance on how to submit comments. This version will include all 14 sectors plus PFAS manufacturing.
- Stage 3 (March 2026): ECHA will publish the final use mapping, incorporating any changes based on SEAC’s draft opinion.
An opportunity for shaping the future of PFAS regulation
Through its structured consultation process and phased publication of use mapping, ECHA aims at providing the tools and transparency needed for meaningful engagement. They advise members of the FPP4EU Collaboration Platform to use it as an opportunity to contribute to shaping the future of PFAS regulation by sharing sector-specific insights, clarifying use cases, and ensuring that socio-economic impacts are fully considered. The months ahead will be critical for informed participation and collective progress.
