REACH · PFAS
PFAS: what can companies prepare while the restriction is being assessed?
For PFAS, companies need to distinguish the assessment of the broad restriction proposal from measures already adopted for specific substances and uses. They can start organising composition data, supplier information and substitution options now.
Status checked on 12 November 2026.
The discussion on PFAS raises a practical question for companies: how can they prepare before the broad restriction process has been completed? The first step is to review substances and uses within their own portfolio. In doing so, companies need to distinguish planned measures from restrictions already adopted for certain groups of PFAS.
Where does the broad restriction proposal stand?
ECHA is assessing a proposal to restrict the manufacture, placing on the market and use of PFAS under REACH. In its March 2026 announcement, ECHA reported support for a restriction with targeted derogations: from RAC in its final opinion and from SEAC in its draft opinion.
In its announcement on the consultation outcome, ECHA said SEAC was expected to adopt its final opinion by the end of 2026. This is an expected next step in the scientific assessment, rather than the date when a general ban starts to apply. The relevant legislative procedure is still required before any broad restriction can apply. Follow developments on ECHA’s PFAS page.
Some restrictions have already been adopted
PFHxA, its salts and related substances are covered by a separate measure, Regulation (EU) 2024/2462. From 10 October 2026, it restricts several product groups, including cosmetics and mixtures for the general public, subject to specified concentration limits and exemptions. The Regulation also sets separate dates for other uses and a derogation for certain articles and mixtures placed on the market before that date.
A company therefore cannot wait for the broad proposal to be concluded if its product already falls within a specific adopted restriction. It needs to check the substance, use, concentration and conditions of the relevant entry in Annex XVII.
Start with the information you already have
We recommend making an inventory of purchased raw materials, formulations and articles where PFAS may be present. For each entry, record the supplier, the substance’s function and the evidence available. Distinguish confirmed presence, confirmed absence within a defined scope, and cases where information is still missing.
Ask suppliers specific questions about the substances and groups you are reviewing. A general “PFAS-free” declaration is less useful for decision-making if it does not identify the definition, product and version of the documentation it covers.
Test alternatives in practice as well
If the inventory identifies PFAS use, we recommend assessing the substance’s function in the product. Record which properties an alternative must retain and which tests will be needed. This makes it easier to compare options, the cost of a change and development time.
When assessing a possible exemption, check all the conditions in the final legal text. A proposed exemption in documents from the procedure does not guarantee that the same solution will be adopted. Keep your internal plan up to date as significant regulatory steps occur.
Support with reviewing your obligations
BiSafe helps companies understand the requirements for their substances and products. Send a description of the use and supplier information to info@bisafe.si. Explore our REACH services for further information.
