The evolving European PFAS Restriction Proposal: where we stand in 2025

16 Oct 2025

Per- and polyfluoroalkyl substances (PFAS) are widely used synthetic chemicals valued for their resistance to heat, water and oil. At the same time, they are extremely persistent in the environment, mobile and capable of accumulating in wildlife and humans. Scientific studies have linked some PFAS to adverse effects on human health and ecosystems. The societal cost of exposure is significant: the Nordic Council estimated annual European health costs from PFAS exposure at €52–84 billion, while a more recent analysis suggested that cleaning up PFAS contamination in Europe and the UK could cost more than £1.6 trillion over 20 years.

Against this backdrop, five national authorities – Denmark, Germany, the Netherlands, Sweden, and Norway – jointly submitted an Annex XV restriction proposal under REACH in January 2023, calling for a comprehensive restriction on PFAS across the EU.

The proposed restriction

The proposal uses the OECD/UNEP definition of PFAS, published in 2021, which encompasses more than 10,000 substances. While some fully degradable subgroups are excluded, the scope remains broad to avoid regrettable substitution. Authorities estimate that without action, about 4.4 million tonnes of PFAS will enter the environment in the next 30 years.

The initial PFAS restriction proposal focused on a broad range of sectors where PFAS is widely used, including manufacturing, transport, electronics and semiconductors, energy, food contact materials and packaging, metal plating, consumer products (such as mixtures and cosmetics), construction materials, lubricants, medical devices, ski wax and textiles. However, in August 2025, ECHA published an updated version of the restriction proposal following review of over 5,600 consultation comments. This revision expands the scope to include eight additional sectors: printing, sealing, machinery, technical textiles, explosives, military and certain medical applications such as packaging and excipients. Importantly, the updated proposal also explores alternative regulatory options, such as conditional allowances for PFAS in areas where complete substitution is not yet feasible, including semiconductors, energy and transport.

Under the current proposal, PFAS may not be manufactured, used, or placed on the EU market above specific concentration thresholds. Exemptions are foreseen where alternatives are not technically or economically viable, with transition periods ranging from five to 12 years. Essential uses in medicines, plant protection and biocidal products remain exempt.

In April 2025, EU Member States formally adopted a sector-specific restriction banning PFAS in firefighting foams, the most advanced PFAS restriction so far. National measures are also emerging, with France adopting legislation that bans PFAS in cosmetics, textiles and ski wax from 2026 and extends the ban to all textiles by 2030.

Economical impact of the restriction

Failing to act on PFAS carries enormous risks and costs, many of which land squarely on private companies. Litigants are already holding manufacturers, users and downstream entities liable for liability, cleanup and reputational damage. For example, in the United States, 3M recently agreed to pay up to $450 million to New Jersey to resolve PFAS contamination claims. More dramatically, Chemours, DuPont and Corteva agreed to an $875 million settlement in 2025 over environmental PFAS claims in New Jersey. Meanwhile, courts have ordered Chemours to immediately curb unlawful PFAS discharges to the Ohio River, following allegations of permit violations.

On the broader scale, remediation of PFAS-contaminated soil and water in Europe is estimated to cost over €2 trillion, with water treatment alone projected at €238 billion if emissions are unabated. For a private company, delaying PFAS restrictions can mean exposure to cascading financial liabilities, costly retrofits, litigation risk and loss of market credibility – all far exceeding the immediate costs of compliance.

At the same time, the economic implications of a universal PFAS restriction for industry are substantial. Ricardo plc supported several industry associations in assessing these impacts, including a comprehensive study for Cefic submitted to ECHA during the public consultation (Part 76, #7993). This analysis mapped PFAS uses across more than 15 industrial sectors, representing an estimated annual turnover of over €15 trillion and a direct Gross Value Added (GVA) contribution of more than €2 trillion to the European economy.

Survey data from 173 companies indicated that approximately 60% of their business activities (by turnover) depend directly or indirectly on PFAS, with significant variation by sector. Moreover, 85% of respondents reported no viable alternatives that could fully replicate PFAS functionality today. Where substitution is possible, companies estimate an average six-year lead time to develop and commercialize alternatives, with wide variability across applications.

Even under optimistic assumptions, companies expect to replace or reformulate only 35–65% of PFAS-dependent products in the medium term. This leaves a substantial share of industrial activity at risk if no exemptions or derogations are introduced, potentially leading to product withdrawals and market disruptions.

Ricardo’s modelling suggests that a universal PFAS restriction could result in:

Loss of PFAS production in Europe (13 facilities), equivalent to around €4 billion in annual turnover, €1.5 billion in direct GVA (and approximately €5 billion including indirect and induced impacts), and 15,000 jobs.
Reduction in PFAS-using sectors’ activity by 20–40%, translating into billions of euros in lost turnover and GVA, and thousands of jobs across the EU.

Additional sector-specific studies by Ricardo (e.g., on household appliances and cookware, Parts 118 and 39 of ECHA’s published comments) confirm that the economic consequences of PFAS restrictions will vary widely by sector but could be severe without targeted exemptions and realistic transition timelines.

Timeline and next steps

ECHA’s Committee for Risk Assessment (RAC) and the Committee for Socio-Economic Analysis (SEAC) are evaluating the updated proposal. During the September meeting RAC set its provisional conclusions for electronics and semiconductors while SEAC started discussing those sectors and reached provisional conclusions for energy and lubricants sectors.

On 27 August 2025, ECHA confirmed it will consult on a draft SEAC opinion in spring 2026, with final opinions expected by the end of 2026 (ECHA, 2025c). After that, the European Commission and Member States will decide on the restriction.

Should the PFAS restriction be adopted, the rules will not apply uniformly overnight: the proposal foresees sector dependant transition periods based on the availability of alternatives. The phased-in deadlines are designed to give industry time to substitute PFAS in complex applications such as semiconductors, energy technologies or transport systems, while still driving a gradual elimination of non-essential uses.

Meanwhile, the EU has tightened PFAS regulation through complementary measures. In late 2024, a restriction on undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances was adopted under REACH (EU Regulation 2024/2462). On 23 September 2025, the Council and Parliament reached a provisional deal to revise EU water legislation, adding PFAS (including trifluoroacetic acid, TFA, a breakdown product of several PFAS) to the list of priority pollutants in surface and groundwater. Member States will face stricter monitoring and compliance obligations with deadlines stretching into the 2030s (Council of the EU, 2025).

The European Commission’s 2025 Chemicals Industry Action Plan further reinforced the “essential use” principle: PFAS should only remain in applications where their use is indispensable for health, safety, or the functioning of society and no alternatives are available. The plan also commits to establishing an EU-wide PFAS monitoring framework by 2026.

What should industry be doing?

The direction of travel is clear: PFAS use in Europe will be heavily restricted with only limited and temporary exemptions. Industry should already be:

Assessing portfolios and supply chains for PFAS content;
Engaging in substitution research and reformulation, particularly in sectors like textiles, cosmetics, food packaging and semiconductors where regulatory and litigation risks are growing;
Monitoring national initiatives, as Member States may move faster than the EU in implementing bans;
Participating in the process via consultations or member state representatives: providing evidence supporting derogations or highlighting transition challenges. This can be done in some of the following steps:
- SEAC launches a second public consultation on its draft socio-economic opinion (first half of 2026)
- After RAC and SEAC opinions are adopted, ECHA forwards them to the European Commission, which then takes the proposal to the REACH Committee (composed of Member State representatives) for a vote.
- Promote dialogue with policymakers if the issue escalates politically or with technical committees within the EU Council, providing technical documents to support their position.
- It will be crucial to also engage in the Commission’s decision-making process and subsequent discussions in the REACH Committee where Member States vote on the restriction.

Conclusion

The EU’s approach to PFAS is evolving into one of the most ambitious global regulatory efforts against persistent chemicals. With complementary action at EU and national levels, industries using PFAS face increasing pressure to transition toward safer alternatives. Businesses that act now by engaging with regulators, participating in consultation stages, investing in innovation, and planning for substitution will be better placed to adapt to the coming restrictions and respond to growing societal and environmental expectations.

How can Ricardo support?

Through our Policy Strategy and Economics team we provide a full suite of research, regulatory and advisory services to support stakeholders navigating the rapidly evolving PFAS policy landscape in Europe. This includes:

scientific and techno-economic research on substitution, exposure, ecotoxicology and environmental fate;
regulatory advisory services such as horizon scanning, risk identification, and tailored support for responding to ECHA’s consultations on the proposed PFAS restriction;
business impact analyses to help companies and trade associations understand how the restriction and national measures will affect operations and supply chains; and,
impact assessments and evaluations aligned with the European Commission’s Better Regulation Guidelines to support policy development.

We also deliver socio-economic analyses consistent with methodologies from ECHA and other international bodies, ensuring robust evidence on costs and benefits of regulatory options. Finally, we provide targeted advisory services, such as Regulatory Management Option Analyses, to inform strategic decisions in this critical transition away from PFAS.

Ricardo has elaborated a Regulatory Management Option Analysis of eight F-gases in scope of the wider blanket restriction of PFAS in the EEA. Ricardo also assessed the economic impacts of the Chemical Strategy for Sustainability (CSS) (including the PFAS ban) to the EU chemicals industry as a result of the selected action modules, in an effort to estimate the combined economic impact. The assessment included a national level assessment.

The environmental chemistry and toxicology (ECT) experts at Ricardo have extensive experience of dealing with the identification and management of hazardous substances. We can support you to understand the impact of PFAS on your business operations and within your portfolio and implement processes and policies to help you transition away from PFAS. The team is currently in several scientific projects related to PFAS and its degradation products.

Our trusted experts provide PFAS training and consultancy services to support you to:

Identify PFAS use in your supply chain and product portfolio;
Understand the implications of the changing regulatory landscape and environmental policy;
Transition away from PFAS in your portfolio;
Communicate your use of non-PFAS substances with customers, shareholders, and other stakeholders.

Additionally, we have experts that can support clients within the food, airport, agriculture and water industries.

Together, we understand the environmental risk and public heath challenges that PFAS pose across the value chain and can offer bespoke guidance across industries to help you manage your risks from PFAS and move towards a more sustainable future.

Advancing environmental chemistry and toxicology for a safer, sustainable future

The Environmental Chemistry and Toxicology team at Ricardo is at the forefront of understanding how chemicals interact with the environment and assessing their toxic effects on organisms and ecosystems using traditional and innovative approaches. By combining our knowledge of environmental chemistry, fate, and (eco)toxicology, our highly motivated team investigates the intricate composition and behaviour of substances in the environment. To this end, we deliver insights that drive impactful solutions and develop strategies to mitigate risks.