Regulatory Overview: Forever chemicals in consumer products across Europe
This article is provided by BRC Associate Member, UL Solutions.
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The EU establishes regulations to limit the use of PFAS in consumer products under REACH, POP legislation and the SVHC list. Larger proposals are being developed to cover a greater number of substances.[ES1]
In the European Union (EU) and the United Kingdom (U.K.), several actions are being taken to regulate per- and polyfluoroalkyl substances (PFAS) in consumer products. These substances are also known as forever chemicals due to their high persistence and tendency to accumulate in the environment.
PFAS comprise a group of about 10,000 mainly manufactured substances used in numerous applications. These include textiles, food packaging materials, lubricants, refrigerants, electronics, construction materials and many more (European Parliament and Council of the European Union, 2019).
In the EU, some PFAS groups are already regulated under:
- Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation (European Chemicals Agency, n.d.)
- Persistent organic pollutants (POP) legislation (see Table 1) (European Parliament and Council of the European Union, 2019)
- The substances of very high concern (SVHC) list
Whereas other PFAS groups are under consideration for future restrictions (see Table 2).
Table 1 – PFAS currently restricted in the EU
| Substance group | Limits in articles | Applicable from |
|
Perfluorooctanoic acid (PFOA) and PFOA-related substances (various Chemical Abstracts Service Registry Numbers®, commonly known as CAS numbers) |
25 parts per billion (ppb) and 1,000 ppb for PFOA-related substances |
July 4, 2020 (European Commission, 2020) |
|
Perfluorooctanesulfonic acid (PFOS), its salts and PFOS-related compounds (various CAS numbers) |
25 parts per billion (ppb) and 1,000 ppb for PFOS-related substances |
Dec. 3, 2025 (European Commission, 2025) |
| Perfluoroalkyl carboxylic acids (PFCA) and PFCA-related substances (various CAS numbers) |
25 ppb for the sum of C9-C14 PFCAs and their salts or 260 ppb for the sum of C9-C14 PFCA-related substances |
Feb. 25, 2023 (European Commission, 2021) |
| Perfluorohexanesulfonic acid (PFHxS), its salts and related substances |
25 ppb for the sum of PFHxS and its salts or 1,000 ppb for the sum of PFHxS-related substances |
Aug. 28, 2023 (European Commission, 2023) |
| Undecafluorohexanoic acid (PFHxA), its salts and related substances |
Sum of PFHxA and its salts: <25 ppb Sum of PFHxA related substances: <1,000 ppb |
Apr. 10, 2026: Firefighting foams for training, testing and public fire services Oct. 10, 2026: Textiles, leather, furs and hides in clothing and related accessories for the general public; footwear for the general public; paper and cardboard used as food contact materials within the scope of Regulation (EC) No 1935/2004; mixtures for the general public; cosmetic products as defined in Regulation (EC) No 1223/2009 Oct. 10, 2027: Textiles, leather, furs and hides in products other than clothing and related accessories for the general public Oct. 10, 2029: Firefighting foams for civil aviation (European Commission, 2024) |
The current larger proposals for restrictions (see Table 2) will cover a greater number of substances with specific exemptions and different dates of entry into force (EiF) for specific uses.
PFAS is defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom without any hydrogen, chlorine, bromine or iodine attached to it (European Chemicals Agency, n.d.).
Table 2 – Larger proposals for PFAS restriction
| Restriction proposals | Limits in articles | Applicable from |
| Option 1 | Full ban |
Still under proposal and there will be a transition period of 18 months without derogations (European Chemicals Agency, 2025a) |
| Option 2 |
>25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification) >250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, optionally with prior degradation of precursors >50 parts per million (ppm) total PFAS (polymeric PFAS included). If total fluorine exceeds 50 mg F/kg then manufacturer, importer or downstream user shall provide information to the enforcement authorities on the fluorine measured as content of either PFAS or non-PFAS (European Chemicals Agency, 2025a). |
Still under proposal and there will be a transition period of 18 months with derogation for some use cases (European Chemicals Agency, 2025a) |
| Option 3 |
Allowing continued use under strict conditions that minimize emissions over the full life cycle |
Various from the end of 2030 onwards (European Chemicals Agency, 2025a) |
Current Status
The last updated draft proposal of universal restriction for PFAS, published in August 2025, requires three Restriction Options (RO) (European Chemicals Agency, 2025a):
- A full ban with a transition period of 18 months (RO1)
- A ban with use-specific, mostly time-limited derogations (RO2)
- Allowing continued use under strict conditions that minimize emissions over the full life cycle, i.e., regulatory options potentially allowing for adequate control of risks through means other than a ban (RO3)
All restriction options, RO1, RO2 and RO3, are considered sufficiently enforceable. RO1 is likely not implementable, and therefore also not manageable, while RO2 and RO3 are evaluated as implementable and manageable by the Dossier Submitter. Hence, RO2 and RO3 are concluded to be practical with regard to implementability, enforceability and manageability.
The restriction proposal is tailored to address the manufacturing, placing on the market and use of PFAS, as well as their use as constituents in other substances, in mixtures and in articles above a certain concentration. The restriction will apply 18 months from EiF.
Exemptions to Proposals
By way of derogation, the restriction shall not apply to some products, such as (European Chemicals Agency, 2025a):
- Active substances in biocidal products within the scope of Regulation (EU) 528/2012
- Articles placed on the market before the date in paragraph 3 (including second-hand articles)
- PFAS used as transported isolated intermediates within the meaning of Article 3(15) of Regulation (EC) 1907/2006, provided that they are used for the service life of the article
- Uses under product and process-oriented research and development [PPORD; art. 67(1) of EU-REACH]
- Paper and board articles containing recovered material, with the exception of food-contact material and packaging
- Textile articles containing recovered material, with the exception of toys as defined in Directive 2009/48/EC, until 13.5 years after EiF
- Plastic articles containing recovered material, with the exception of food-contact material and food contact packaging and toys as defined in Directive 2009/48/EC, until 23.5 years after EiF
- Production of PFAS with or without the use of fluorinated polymerization aids in the production of polymeric PFAS under controlled conditions with average emission factors (= Annual emission of PFAS / total annual amount of PFAS manufactured on site) not exceeding:
- 0.0090% to air, 0.0010% to water and 0% to soil for emissions of non-polymeric PFAS residues from polymerization aid technology in fluoropolymer manufacturing until end of 2030
- 0.0030% to air, 0.0006% to water and 0% to soil for emissions of non-polymeric PFAS residues from polymerization aid technology in fluoropolymer manufacturing from end of 2030 onwards
- 0.01% to all compartments for all PFAS emissions not mentioned above from sites manufacturing polymeric and non-polymeric PFAS 6.5 years after EiF
EU Next Steps
On Aug. 27, 2025, the European Chemicals Agency (ECHA) announced updated progress on the PFAS restriction process, including its intention to deliver the final opinions of the Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC) to the Commission in 2026. Following its March 2026 meeting, ECHA also launched a consultation on SEAC’s draft opinion on the proposed EU-wide restriction of PFAS (European Chemicals Agency, 2025b).
The consultation uses a structured survey format, inviting participants to respond to questions about the potential impacts of restricting PFAS use across various sectors. Participants are also asked to provide specific information about the availability and feasibility of alternatives to these widely used chemicals. Any information marked as confidential will be treated appropriately. Information on the risks associated with PFAS will not be considered, as these are evaluated in a separate opinion by the RAC.
The consultation is open to all interested parties, including industry representatives, non-governmental organizations, researchers and members of the public. After reviewing the consultation feedback, SEAC is expected to adopt its final opinion by the end of 2026.
The European Commission will also consider the updated proposal submitted by the Member States. The European Parliament and the Council will usually have two months to formally object to the Commission’s proposal. If no objections are raised by the co-legislators during the objection period — which can be extended (usually by an additional two months) — the PFAS restriction is formally adopted and published in the Official Journal of the EU.
There is also another proposal on long-chain perfluorocarboxylic acids to align the EU’s obligations under the Stockholm Convention on POPs published by the European Commission (Table 3) (European Commission, n.d.).
| Substance group | Limits in articles | Applicable from |
|
Long chain perfluorocarboxylic acids (C9-21 PFCAs), their salts and related compounds refer to the following:
Not included as compounds related to C9-21 PFCAs:
|
25 parts per billion (ppb) and 260 ppb for PFCA-related substances (European Commission, n.d.) The proposal sets specific derogations and different limits for certain usage and polymers. |
Still under proposal Commission adoption planned for the first quarter of 2026. When the Regulation is published, it will EiF on the twentieth day following its publication in the Official Journal of the European Union (European Commission, n.d.). |
National Initiatives in Denmark and France
In the meantime, several EU Member States have pursued national initiatives to limit PFAS ahead of the EU-wide restriction under the REACH framework. Legislation introduced at the national level, including in Denmark and France, is expected to enter into force in 2026.
The Danish government has introduced a national ban on PFAS in clothing, footwear and waterproofing agents. The ban does not apply to PFAS used in professional clothing or safety clothing (Miljø- og Ligestillingsministeriet, 2025).
France has also advanced national legislation addressing PFAS in consumer products. Under the French PFAS law, which applies from Jan. 1, 2026, the manufacture, import, export and marketing of certain PFAS-containing products are prohibited (République française, 2025).
From Jan. 1, 2026, the French law bans PFAS in:
- Cosmetic products
- Wax products
- Textile clothing products, footwear and waterproofing agents intended for consumers
Textile clothing and footwear designed for the protection and safety of persons — particularly for national defense or civil security missions — are excluded, with the specific list defined by decree.
Products manufactured before Jan. 1, 2026, may continue to be placed on the market or exported for a maximum period of 12 months following that date (République française, 2025).
From Jan. 1, 2030, the French law further prohibits the manufacture, import, export and placing on the market, whether for consideration or free of charge, of any textile product containing PFAS substances. Exceptions are permitted for textile products required for essential uses, those contributing to national security where no alternative solution exists, and technical textiles for industrial use (République française, 2025).
The proposed thresholds under the French framework are subject to three cumulative conditions (République française, n.d.):
- 25 parts per billion (ppb) for any PFAS measured by targeted analysis (excluding polymers)
- 250 ppb for the sum of PFAS measured by targeted analysis, with prior degradation of precursors where applicable (excluding polymers)
- 50 parts per million (ppm) for PFAS, including polymers
PFAS in the UK
Finally, the U.K. has also announced its PFAS Plan: Building a Safer Future Together, which focuses on monitoring and reducing forever chemicals through improved environmental testing, research into potential health impacts and potential limits on PFAS in drinking water (Department for Environment, Food & Rural Affairs, 2026).
UL Solutions can help
For more details and to know more on how UL Solutions can support your business, please contact katie.ellen.moore@ul.com
Sources:
Department for Environment, Food & Rural Affairs. (2026, February 3). PFAS plan: Building a safer future together. GOV.UK. https://www.gov.uk/government/publications/pfas-plan/pfas-plan-building-a-safer-future-together
European Chemicals Agency. (n.d.). ANNEX XVII to REACH – Conditions of restriction (Entry 82: Per- and polyfluoroalkyl substances (PFAS)). https://www.echa.europa.eu/documents/10162/e8c76d1e-5204-4e99-ea16-3dffb8f1ca8b
European Chemicals Agency. (2025a, August 20). ECHA publishes updated PFAS restriction proposal. https://www.echa.europa.eu/-/echa-publishes-updated-pfas-restriction-proposal
European Chemicals Agency. (2025b, August 27). ECHA update on the per- and polyfluoroalkyl substances (PFAS) restriction process. [PDF]. https://www.echa.europa.eu/documents/10162/111425157/echa_update_pfas_en.pdf/6775e241-204e-af0a-a2d0-4c16ba2c138d
European Chemicals Agency. (2026, March 25). ECHA to launch consultation on draft SEAC PFAS opinion. https://www.echa.europa.eu/-/echa-to-launch-consultation-on-draft-seac-pfas-opinion
European Commission. (2020, June 15). Commission Delegated Regulation (EU) 2020/784 of 8 April 2020 amending Annex I to Regulation (EU) 2019/1021 of the European Parliament and of the Council as regards the listing of perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds. EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32020R0784
European Commission. (2021, August 5). Commission Regulation (EU) 2021/1297 of 4 August 2021 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards perfluorocarboxylic acids containing 9 to 14 carbon atoms in the chain (C9-C14 PFCAs), their salts and C9-C14 PFCA-related substances. EUR-Lex. https://eur-lex.europa.eu/eli/reg/2021/1297/oj/eng/pdf
European Commission. (2023, August 8). Commission Delegated Regulation (EU) 2023/1608 of 30 May 2023 amending Annex I to Regulation (EU) 2019/1021 of the European Parliament and of the Council as regards the listing of perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds. EUR-Lex. https://eur-lex.europa.eu/eli/reg_del/2023/1608/oj
European Commission. (2024, September 20). Commission Regulation (EU) 2024/2462 of 19 September 2024 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances. EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024R2462
European Commission. (2025, June 27). Commission Delegated Regulation (EU) 2025/718 of 14 April 2025 amending Regulation (EU) 2019/1021 of the European Parliament and of the Council as regards perfluorooctane sulfonic acid and its derivatives. EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32025R0718
European Commission. (n.d.). Persistent organic pollutants – Long-chain perfluorocarboxylic acids, their salts and related compounds (Initiative 14834). Retrieved May 4, 2026, from https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14834-persistent-organic-pollutants-long-chain-perfluorocarboxylic-acids-their-salts-and-related-compounds_en
Miljø- og Ligestillingsministeriet. (2025, May 14). Bekendtgørelse om forbud mod import og salg til forbrugere af beklædning, fodtøj og visse imprægneringsmidler, der indeholder PFAS (BEK nr 464 af 02/05/2025). Retsinformation. https://www.retsinformation.dk/eli/lta/2025/464
European Parliament & Council of the European Union. (2019, June 25). Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants (recast). EUR-Lex. https://eur-lex.europa.eu/eli/reg/2019/1021/oj/eng
République française. (2025, December 30). Décret n° 2025-1376 du 28 décembre 2025 relatif à la prévention des risques résultant de l’exposition aux substances perfluoroalkylées et polyfluoroalkylées. Légifrance. https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053201526
République française. (n.d.). Projet de décret relatif aux modalités de mise en œuvre de la trajectoire nationale de réduction progressive des rejets aqueux de substances perfluoroalkylées et polyfluoroalkylées des installations industrielles. [Consultation publique]. Retrieved May 4, 2026.
