Background

Per- and polyfluoroalkyl substances (PFAS) are a group of several thousand chemicals containing carbon-fluorine bonds, one of the strongest chemical bonds in organic chemistry. These bonds make PFAS resistant to degradation when used, but also in the environment, which has earned them the moniker 'forever chemicals'.

Because of their favourable physicochemical properties (e.g. oil and water repellence, high chemical, physical and temperature resistance and ability to act as surfactants), PFAS are applied in almost all industry sectors and a wide range of consumer products. Products containing or coated with PFAS include carpets, clothing and other textiles, cookware (such as non-stick pans), food packaging (such as fast-food containers and wrappers, grease-resistant paper), electronics, personal care products (e.g. shampoo, dental floss) and cosmetics, cleaning products, etc. In industrial production, PFAS are employed in machinery, filters, lubricants, seals and membranes. PFAS are used in the production of components in semiconductors and medical devices, as surfactants in fire-fighting foams, as co-formulant in plant protection products, biocides, feed additives, pharmaceuticals and paints. A 2020 study identified over 200 use categories and subcategories for more than 1 400 individual PFAS.

The same properties that make PFAS valuable for industrial applications and products pose significant environmental challenges. Most PFAS are either persistent themselves or are transformed into persistent compounds in the environment. This has resulted in their accumulation in the environment since they went into large-scale production in the 1940s. Because of their persistence and mobility, combined with decades of widespread use and resulting emissions, PFAS have been found to be ubiquitous environmental contaminants, present from the Arctic to urban rainwater. PFAS have been detected in biota, drinking water, food, air, and human serum, raising concerns due to reported toxicity impacts in both animals and humans.

Scientific research and regulatory efforts have led to a gradual phase out of some PFAS due to their inherent hazards. Action initially focused on certain long-chain compounds, particularly perfluoroalkyl carboxylic and sulfonic acids. The production and use of the most extensively manufactured (and hence most frequently detected) molecules, perfluorooctanesulfonate (PFOS) and perfluorooctanoate (PFOA), are now restricted or banned globally, and the number of PFAS subject to regulations and controls has since increased. Yet generally, regulated PFAS have been substituted with other types of PFAS. As a result, a multitude of alternative PFAS have emerged in the marketplace, of which the presence, transport, fate and effects are less understood.

Due to the sheer number of PFAS, the approach taken so far for risk management – assessing and regulating them individually, or in small groups of closely related substances – is impracticable and inadequate to effectively protect health and the environment. The very high environmental persistence, bioaccumulation, and potential toxicity of the entire PFAS class prompted PFAS scientists to call for a class approach in managing them and to ask for limits to their production and use.¹ Under its chemicals strategy for sustainability, the EU has committed to regulate PFAS as a group. The European Chemicals Agency is assessing a wide-ranging restriction proposal under REACH (often referred to as 'universal PFAS restriction') that covers some 10 000 compounds.

Health and environmental concerns

PFAS are released into the environment throughout their entire lifecycle: from PFAS production to use of PFAS in manufacturing, use of PFAS-containing products and disposal. The numerous and diverse emissions and the extensive distribution of entry routes for PFAS (both point-source and non-point-source) have led to a ubiquitous contamination of the environment.

Pollution of drinking water and agricultural soil (through the application of PFAS-contaminated sludge, atmospheric deposition, irrigation, soil additives, use of certain pesticides), is of particular concern. Food and water are the main human exposure pathways to PFAS. Human biomonitoring shows the omnipresence of PFAS in human populations, including in 100 % of young people tested, although the specific molecules and their concentrations vary. Communities in PFAS 'hotspots' have higher exposure and risk of disease. In Europe, there has been an increase in sites identified with high PFAS loads in soil and/or groundwater, often related to the use of aqueous film-forming foams (in fire-fighting training and military bases) or the presence of fluoropolymer production plants. Conservative estimates by the Forever Pollution Project in 2023 suggest nearly 23 000 sites in Europe are contaminated at levels requiring public authority attention, with over 2 300 hotspots where contamination reaches levels considered hazardous to health.

A large body of epidemiological and experimental data exists on the health effects of PFAS, but this data is available for fewer than 50 different PFAS, meaning that data are lacking to adequately assess the impacts of the thousands of other substances in use today.² PFAS are associated with liver damage, thyroid disease, kidney and testicular cancer (high certainty). In November 2023, the International Agency for Research on Cancer classified PFOA as 'carcinogenic to humans' (Group 1), and PFOS as 'possibly carcinogenic to humans' (Group 2B). Certain PFAS are toxic for reproduction and can harm the foetal development. Some PFAS are also suspected of interfering with the human endocrine (hormonal) system. There is evidence of immunosuppression, diminished vaccine efficacy, and increased risk of infections, allergies, asthma and atopic dermatitis following in utero, infant and early childhood PFAS exposure. A 2022 study linked exposure to PFAS to a dozen diseases. Research that progressed beyond the best-studied substances points out emerging PFAS can give rise to similar concerns.

A 2019 study for the Nordic Council of Ministers estimated health-related costs linked to PFAS exposure to be €52‑84 billion annually across Europe. Quantifiable annual health costs from human exposure to only four well-studied 'legacy' PFAS (the already regulated PFOA, PFOS, PFHxS and PFNA) were estimated at €39.5 billion in a new study for the European Commission.

Once in the environment, it is very costly and impractical to remove PFAS through remediation, if even possible at all. Because of the high chemical and thermal stability of PFAS and their presence as mixtures in environmental matrices, their remediation both in water and soil is extremely challenging. Many existing treatment technologies have proven inadequate, and PFAS often require new technologies or innovative combinations of existing ones. Treatment typically involves separation/concentration of PFAS to facilitate removal from the contaminated medium, followed by destruction. Immobilisation methods can be used to contain the spread of PFAS within soils and into groundwater. While remediation is needed following specific contamination events, managing environmental stocks of PFAS through treatment alone is unaffordable, with current costs to remove and destroy the total PFAS mass released annually into the environment likely exceeding the global GDP of US$106 trillion, according to recent research. A media investigation led by Le Monde estimated the costs of depolluting Europe from PFAS at between €95 billion to €2 trillion over the next 20 years, depending on the scenario considered. The 2026 Commission study expects costs to range from €330 billion to €1.7 trillion by 2050.

Given the scale of PFAS contamination, the technical challenges and high costs of remediation, focusing on pollution prevention appears to be the most effective and sustainable option.

How PFAS are regulated

'Universal' PFAS restriction proposal

Source: based on ECHA. Graphics by Samy Chahri, EPRS

The restriction proposal, prepared by authorities in Denmark, Germany, the Netherlands, Norway and Sweden, was submitted to ECHA in January 2023. The restriction process is progressing along the procedure laid down in the REACH Regulation (Figure 1), irrespective of the targeted revision of REACH announced by the Commission in the chemicals strategy and now abandoned.The restriction proposal builds on the Organisation for Economic Co-operation and Development's definition of PFAS, identifying a chemical structure common to all. It encompasses more than 10 000 PFAS and covers both non-polymers and polymers. All PFAS within scope are either very persistent themselves or degrade into very persistent PFAS in the environment. While this is not homogenous across all PFAS, many trigger additional concerns linked to mobility, eco-toxicity, bioaccumulation, long-range transport and global warming potential, and human toxicity. A group restriction based on structural similarity and equivalent hazard should prevent regrettable substitution (replacement of a hazardous chemical with another that may pose similar or even greater risks to health or the environment), hence future exposure to PFAS not currently in use.The restriction proposed by the five national authorities (the dossier submitters), following assessment of three possible options,³ would prohibit the manufacture, use and placing on the EU market of PFAS substances on their own, and as constituents in other substances, in mixtures and articles above defined concentration limits, with a general transition period of 18 months and use-specific, mostly time-limited derogations (5 or 12 years). The proposed derogations are based on the expected substitution potential (5 years for uses where alternatives are under development but not available at the entry into force of the restriction; 12 years for uses where research and development efforts have not so far identified possible alternatives or where certification processes for alternatives cannot be achieved within a five-year transition period). Specific derogations would apply to second-hand articles, spare parts and recycled materials. Continued use conditional upon emission limits is proposed for PFAS manufacturing to ensure PFAS supply for derogated uses. PFAS used as active substances in plant protection products, biocidal products and medicinal products (human and veterinary) are outside the restriction scope, as they are covered by their respective legislation.Reporting requirements are proposed for 12-year or longer derogations and for all applications of fluorinated gases, to gather data on uses and quantities and monitor any changes. This would, in case of any concerns for a sector, support the Commission in future decision-making (review of the restriction, action under sector-specific legislation). Manufacturers, importers and downstream users of fluoropolymers and perfluoropolyethers making use of any derogation would be required to prepare a site-specific management plan, with information on the identity of the substances and the products for which they are used; justification for use; and conditions of use and safe disposal. The plan should be reviewed annually and kept available for inspection.Unless a specific derogation has been formulated, all uses of PFAS⁴ are covered by the restriction proposal, regardless of whether they have been specifically assessed and/or mentioned in the dossier or not. To manage the multitude of PFAS applications, the dossier submitters organised the dossier based on sectors, i.e. groups of (economic) activities and/or industrial areas in which PFAS are used in a similar way or related purposes across supply chains. Where applications of PFAS are used in many sectors in a similar way (sealings, machinery, technical textiles, applications of fluorinated gases, etc.), these have been handled as an overarching application applicable to several sectors. Twenty-three sectors/applications, covering numerous sub-uses, have been considered (see Figure 2 below).ECHA's Committee for Risk Assessment (RAC) adopted its opinion on 3 March 2026. The Committee for Socio-Economic Analysis (SEAC) agreed on its draft opinion on 10 March 2026.Both committees support the restriction as the most appropriate regulatory measure to address the risks of PFAS. They find the proposed option is practical and proportionate. Yet, in case derogations are supported by the decision-maker, RAC recommends additional risk-management measures, including site-specific PFAS management plans (applying to all types of PFAS and to all industrial sites where manufacturing and downstream uses of PFAS and PFAS-containing mixtures are allowed to continue), with monitoring of emissions; safe use and disposal instructions; and effective supply chain communication (via labelling of products, safety datasheets/technical datasheets or product passports) to minimise PFAS emissions. SEAC supports the RAC recommendation, however without being able to conclude if the measures are proportionate.

Image source: based on the REACH restriction proposal (background document). Graphics by Samy Chahri, EPRS.

RAC considers that sectoral regulations on plant protection products, biocidal products and medicinal products do not fully address the concerns associated with persistent PFAS emissions into the environment and finds it important to include measures to minimise emissions from the use of PFAS as active substances in these products in the respective sectoral regulations in cases of a derogation. For SEAC, the dossier submitters have not justified the exclusion of these applications from the PFAS ban via a 'time-unlimited' derogation.The two-month stakeholder consultation on SEAC's draft opinion ran from 26 March to 25 May 2026. Over 3 500 contributions were received. After reviewing the consultation comments, SEAC plans to adopt its final opinion by the end of 2026. This adoption will conclude ECHA's scientific evaluation of the proposed restriction. ECHA will then send the compiled RAC and SEAC opinions to the European Commission for decision.Based on the national authorities' proposal and the RAC and SEAC opinions, the Commission will propose a restriction (a draft regulation to amend the list of restrictions in Annex XVII to REACH) for discussion and vote in the REACH Committee, composed of EU Member State representatives. A qualified majority (55 % of EU countries representing at least 65 % of the total EU population) is required for the draft measure to be approved by the committee. Once approved, the draft regulation will be submitted to Parliament and Council for scrutiny (usually for up to three months), with a possibility for them to object to the proposed act if deemed necessary. If objections are raised, the Commission must review its proposal.

European Parliament

As co-legislator, Parliament has been instrumental in securing PFAS restrictions in toys and packaging, assessment of additional quality standards for PFAS in the next review of the lists of surface water and groundwater pollutants, and assessment of a possible extension of the extended producer responsibility obligations to products generating PFAS in urban wastewater in the next review of the Urban Wastewater Treatment Directive. In recent resolutions, Parliament stressed the importance of reducing exposure to harmful substances such as PFAS for cancer prevention; and the need for updated limits on PFAS in drinking water. It called on the Commission to propose to phase out PFAS – starting with consumer goods – linked to harmful effects on human health and the environment, based on scientific evidence, allowing their use where there are no safe alternatives. It insisted that upcoming proposals do not endanger essential uses of PFAS in critical sectors (medical devices, pharmaceuticals, products necessary for the transition to a climate neutral and digital economy). When scrutinising the draft restriction, Parliament will have a key role to play in ensuring that the text lives up to the expectations on the protection of human health and the preservation of vital resources, while taking account of economic and technical challenges for businesses.