On August 20, 2025, Denmark, Germany, the Netherlands, Norway and Sweden submitted an update to the proposal to restrict PFAS under the European Union’s REACH regulation that they originally submitted in January 2023. The revision reflects their comprehensive evaluation of more than 5,000 scientific and technical comments submitted by stakeholders, including industry representatives, researchers and civil society organizations.
Of note in the updated proposal is the expansion of derogations from PFAS restrictions, including several for fluoropolymers. The updated proposal also introduces more regulatory pathways beyond a full ban or a phased-in ban and would allow the continued manufacture, market placement or use of PFAS under specific conditions, coupled with complementary emission-reducing measures designed to mitigate associated risks.
Additionally, the scope of sectors under consideration has widened. The original proposal identified 14 sectors, including cosmetics, fluorinated gases, transport, energy, medical devices, lubricants, electronics and semiconductors. The updated version adds eight more sectors, including critical areas like medical and military applications, for the European Chemicals Agency’s (ECHA) consideration when it finalizes the regulations. Initial indications from ECHA, however, evince an intent only to opine on the original 14 sectors, given time and capacity constraints.
ECHA’s scientific committees are already reviewing the proposal, which we will monitor in this space closely.