欧盟PFAS全面限制提案进入关键阶段

background

On January 13, 2023, the five EU countries (Denmark, Germany, the Netherlands, Norway, and Sweden) submitted a proposal to ECHA to comprehensively restrict the production, release, and use of PFAS (over 10000 substances) within Europe

In March 2026, the EU's regulatory process for perfluorinated and polyfluoroalkyl substances (PFAS), also known as "permanent chemicals," will once again see significant progress

The two core committees of the European Chemicals Agency (ECHA) have successively completed key evaluations of PFAS restriction proposals, marking the final sprint of the EU's comprehensive restrictions on PFAS.

EU Regulatory Dynamic Timeline

Main content of time

In January 2023, in order to reduce the emissions of PFAS into the environment and enhance the safety of products and industrial processes for human health and ecosystems, Denmark, Germany, the Netherlands, Norway, and Sweden jointly proposed PFAS restriction proposals and submitted them to ECHA.

A six-month public consultation was conducted from March 22 to September 25, 2023, and received a large amount of feedback from the industry, research institutions, and the public.

The March 2024 conference evaluates consumer blends, cosmetics, and ski wax.

The June 2024 conference will evaluate the metal electroplating and metal product manufacturing industry, and supplement discussions on the hazard characteristics of PFAS.

The September 2024 conference evaluates the textile, interior decoration, leather, clothing, carpet, food contact materials, packaging, and petroleum and mining industries.

Latest progress on PFAS restrictions released on November 20, 2024

On August 20, 2025, ECHA announced an updated PFAS restriction proposal, officially adding 8 evaluation industries (printing, sealing, machinery, military applications, etc.) based on the first round of consultation opinions, increasing the total number of evaluation industries from 15 to 23.

On March 2, 2026, the Risk Assessment Committee (RAC) approved the final risk opinion: it is clear that the residual and migratory environmental and health risks of PFAS are sufficient to support strict restrictions

On March 11, 2026, the Socio Economic Analysis Committee (SEAC) reached consensus on its draft socio-economic opinion

We are about to launch a 60 day consultation period for the SEAC draft opinions to the public, covering all 23 industries and evaluating alternative solutions.

Expected by the end of 2026:

Based on the final opinion, ECHA has concluded the scientific evaluation phase.

Expected in 2027:

European Commission proposes draft restrictive measures

Proposal for comprehensive restrictions on PFAS updates

What does it mean for Chinese export enterprises?

Enterprises will face various risks:

Raw material risk: Fluorinated materials will face stricter restrictions

For example, fluorinated surface treatment agents, fluororubber, fluorinated lubrication systems, oil/water resistant additives, and functional materials for technical textiles.

Supply chain risk: Upstream information transparency will be forcibly amplified

The proposal requires coverage of the entire industry chain, with upstream raw material suppliers, midstream manufacturers, and downstream exporters all required to establish a PFAS traceability system. Any non-compliance in any link will result in products being unable to enter the EU market.

Product compliance risk: EU market access threshold significantly raised

PFAS content testing will become a routine requirement for market access in the European Union, and industries such as electronics and electrical, mechanical seals, textiles, food contact, and medical devices will face continuous regulation and compliance checks from the EU.