SG 113/26
Sweden has proposed limits on per- and polyfluoroalkyl substances (PFAS) in certain consumer products.
In July 2026, Sweden’s Ministry of Climate and Enterprise (Klimat- och näringsdepartementet) issued a memorandum, proposing to regulate PFAS in certain products. The legislative proposal would amend the nation’s Ordinance (1998:944) on prohibitions, etc., in certain cases in connection with the handling, import and export of chemical products.
According to the proposal, the term ‘PFAS’ has the same definition as in Article 5(5) of Regulation (EU) 2025/40 on packaging and packaging waste (Packaging and Packaging Waste Regulation, PPWR):
- Any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CH2-) carbon atom (without any H/Cl/Br/I attached to it), except substances that only contain the following structural elements:
- CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (-CH2), an aromatic group, a carbonyl group (-C(O))-), OR’’, -SR’’ or -NR’’R’’’
- Where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3-), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-)
What does this draft regulation require and when does it apply?
Key provisions in the draft ordinance are summarized in Table 1.
| Substance | Scope¹ | Requirement | Proposed date of entry into force |
|---|---|---|---|
| PFAS |
| < 25 µg/kg (ppb) for individual non-polymeric PFAS³ < 250 µg/kg (ppb) for the sum of non-polymeric PFAS, including those from degradation of precursors³ < 50 mg/kg (ppm) for the sum of all PFAS³, ⁴ | January 1, 2028 |
| ¹Exempts a) clothing containing at least 20% recycled materials, b) personal protective equipment (PPE) under Annex I of Regulation (EU) 2016/425), c) impregnating agents for re-impregnation of PPEs listed in point b and d) products that have been in use and are suitable for continued use, including those that have been repaired ²Applies only to food contact part(s) of the product ³Applies only if there is no equivalent prohibition in Regulation (EC) No 1907/2006 (REACH, current consolidated version to May 2026 for reference) or Regulation (EU) 2019/1021 on persistent organic pollutants (POPs, current consolidated version to January 2026 for reference) ⁴Fluorine is presumed to come from PFAS when total fluorine (TF) exceeds 50 mg/kg, unless proven that the fluorine comes from a non-PFAS source | |||
Table 1
The proposal is intended as an interim national measure while the broader EU-wide PFAS restriction under REACH remains under development. Sweden has indicated that the national restriction would be repealed once equivalent EU legislation enters into force.
Who is impacted?
The proposal would affect stakeholders throughout the supply chain for the specified consumer products, including manufacturers, importers, retailers and other intermediaries operating in Sweden.
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