With the publication of the final report evaluating 5,642 submissions on August 25, 2025, the European Chemicals Agency (ECHA) has reached an important first milestone in the PFAS regulatory process.
The comments received during the consultation provided extensive detailed information. These had a significant influence on the committees’ revised assessments, particularly with regard to possible alternatives and environmental and economic impacts.
In addition to the two regulatory options originally planned –
Option 1: Ban and
Option 2: Ban with time-limited exemptions –
the report proposes to consider a third regulatory option:
Option 3: Conditions that must be met to allow the continued manufacture, placing on the market, or use of PFAS instead of a ban.
This third option is intended to apply to certain applications for which no suitable alternatives are currently available and which have been assessed by the Committees for Risk Assessment (RAC) and Socioeconomic Analysis (SEAC). These include, among others:
batteries
fuel cells
electrolysers
medical devices
semiconductors
Fluoropolymers during manufacture, during service life and at the end of service life
With the introduction of this third regulatory option, ECHA is laying the foundation for differentiated consideration of individual applications and entire substance groups within the framework of PFAS regulation for the first time. Fluoropolymers also fall into this category when considering their entire life cycle, as there are currently no suitable alternatives available for them. This represents an important success in the joint efforts to counteract a blanket ban on PFAS and highlight the special significance of fluoropolymers.