On 11 May 2023 the European Union established regulations restricting the use of PFAS in consumer products under REACH, POP legislation and the SVHC list. A larger proposal covering more substances is being prepared.

The European Union is taking a number of regulatory actions to control per- and polyfluoroalkyl substances (PFAS) in consumer products. Because of their high persistence these toxic substances are also called forever chemicals. Without any degradation capability their concentration in the environment keeps increasing. Exposure to these substances has negative effects on people and the environment.

PFAS are defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom with no H, Cl, Br or I attached. PFAS are a group of about 10,000 mainly man-made substances used in many applications in the European Union, including textiles, food packaging, lubricants, refrigerants, electronics and construction.

In the European Union some PFAS are already regulated under REACH and the POPs legislation (see Table 1) and the SVHC list, while restrictions are being proposed for other groups (see Table 2).

Table 1  PFAS restricted in the European Union

Substance group	Restriction in articles	Applicable from
PFOA and PFOA-related substances (various CAS numbers)	25 ppb in total, and 1000 ppb for PFOA-related substances	4 July 2020
PFOS (various CAS numbers)	1 microg/m2 for treated articles, 0.1% by weight in total	25 August 2010
PFCAs and PFCA-related substances (various CAS numbers)	25 ppb in total for C9-C14 PFCAs and their salts, or 260 ppb in total for C9-C14 PFCA-related substances	25 February 2023

Table 2  PFAS groups proposed for restriction in the European Union

Substance group	Restriction in articles	Applicable
Perfluorohexane sulfonic acid	PFHxS and its salts 25 ppb in total, or PFHxS-related substances 1,000 ppb in total	Still under proposal
Perfluorohexanoic acid	PFHxA and its salts 25 ppb in total, or PFHxA-related substances 1,000 ppb in total	Still under proposal

The current broader restriction proposal (see Table 3) would cover more substances with specific derogations and different entry into force dates for specific uses.

Substances containing only the following structural elements are excluded from the scope of the proposed restriction: -CF3-X or X-CF2-X, where X = -OR or -NRR and X = methyl (-CH3), methylene (-CH2-), an aromatic group, carbonyl (-C(O)-), -OR, -SR or -NRR, where R, R and R are hydrogen (-H), methyl (-CH3), methylene (-CH2-), aryl or carbonyl (-C(O)-).

Table 3  Broader PFAS restriction proposal

Restriction option	Restriction in articles	Applicable
Option 1	Total ban	Still under proposal, with an 18-month transition period and no derogations.
Option 2	25 ppb for any PFAS measured by targeted PFAS analysis (polymeric PFAS are not included in the quantification)   250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, with optional pre-degradation of precursors (polymeric PFAS are not included in the quantification) 50 ppm for PFAS (including polymeric PFAS) If total fluorine exceeds 50 mg F/kg, the manufacturer, importer or downstream user must provide, on request, proof of the fluorine measured as PFAS or non-PFAS content to the enforcement authority.	Still under proposal, with an 18-month transition period and derogations for certain uses.