ECHA Consults Over SEAC’s Draft Opinion on PFAS Restrictions under REACH

SG 050/26

European Chemicals Agency (ECHA) has launched consultation on the draft opinion of the Committee for Socio-Economic Analysis (SEAC) regarding per- and polyfluoroalkyl substances (PFAS) restrictions under REACH.

In March 2026, ECHA announced a two-month consultation on SEAC’s draft opinion on the proposed restriction of PFAS under Regulation (EC) No. 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)’.

The final opinion of the Risk Assessment Committee (RAC) and the draft opinion of SEAC support an EU-wide restriction, subject to specific (time-limited) exemptions, on the manufacture, placing on the market and use of PFAS. These two scientific committees further advise that any restriction should be complemented by effective measures to minimize emissions.

According to the proposal submitted by the dossier submitter (DS: Denmark, Germany, the Netherlands, Norway and Sweden), PFAS means substances that contain at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, without any H/Cl/Br/I attached to it. Substances containing only the following structural elements are excluded from the scope of the restriction.

• 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’’’; and where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-) (SafeGuardS 128/25 and references therein)

Additionally, ECHA announced a detailed Q&A document on the same day, addressing the restriction process under REACH, and summarizing the key points from RAC’s final opinion and SEAC’s draft opinion on the proposal to restrict PFAS in the EU/EEA

What elements are included in SEAC’s draft opinion?

Key highlights include:

• Aligning with RAC’s opinion that a group restriction based on structural similarity and equivalent hazard will prevent regrettable substitution and future exposure to PFAS not currently in use
• Agreeing with the final opinion of RAC in supporting an EU-wide restriction subject to specific (time-limited) exemptions, on the manufacture, placing on the market and use of PFAS
• Supporting RAC’s conclusion that the evidence provided is insufficient to justify excluding substances containing the specified structural elements from the scope of the restriction, as detailed above in the definitions
• Prohibiting PFAS as substances on their own (see Table 1 below)
• Restricting PFAS when present in other substances, mixtures and articles (see Table 1 below)
• Concurring with the two points mentioned above in the proposal that the prohibition/restriction would apply 18 months from entry into force (EIF) of the restriction
• Detailing an overview of the committee’s conclusions regarding all derogations (Table 9 to section 3.4.3.2.5.8) provided by the DS as well as additional points for consideration
• Adding two derogations for consideration on the use of PFAS in:
  • Polyvinylidene fluoride (PVDF) strings for professional musical instruments until 13.5 years after EIF
  • Radiofrequency equipment, waveguides and capacitors, with a derogation lasting up to 13.5 years after EIF

Who is impacted?

This draft opinion would affect stakeholders across multiple industries and supply chains operating in the EU/EEA, including manufacturers, users and importers of PFAS, as well as mixtures and articles that contain them.

When does it apply?

The prohibition/restriction of PFAS would apply 18 months from the date of EIF.

Highlights of the proposal submitted by DS and SEAC’s proposed restrictions are summarized in Table 1.

Table 1

Comments will be accepted until May 25, 2026.

It is important to note that this DS proposal does not address PFAS in firefighting foams (FFF) as these are regulated under Commission Regulation (EU) 2025/1988 (SafeGuardS 152/25).

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