Comments submitted to PFAS restriction proposalComments submitted to PFAS restriction proposal

PFAS restriction proposal received more than 5,600 comments from organisations, companies and individuals from around the globe, reports Elaine Campling from ESMA HSEP Committee and Chemical Compliance Advisory Services.

The European Chemicals Agency (ECHA) received more than 5,600 comments on the proposal to restrict per- and polyfluoroalkyl substances (PFAS) in the European Economic Area under REACH, the Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation. PFAS represent a large class of thousands of synthetic chemicals that are used in a number of sectors including surface coatings, printing inks, varnishes, lubricants, and coatings on textiles, upholstery, leather, apparel and carpets (TULAC).

However, PFAS contain carbon-fluorine bonds, which are one of the strongest chemical bonds in organic chemistry. Consequently, PFAS are known as ‘forever chemicals’ because of their resilience and persistence in the environment. 

They are associated with contamination of groundwater, surface water and soil. Most are readily transported in the environment and are found at remote sites long distances from the source of their release. Some PFAS are also associated with impacts to human health.

The restriction proposal that was prepared by the authorities in Denmark, Germany, the Netherlands, Norway and Sweden, was submitted to ECHA in January of this year. It is being called ‘PFAS Universal’ to distinguish it from a separate restriction that has been concluded relating to the restriction of PFAS in firefighting foams.

This ‘PFAS Universal’ restriction proposal was subject to a six-month public consultation that was opened in March of this year and closed in September. Comments and information were submitted by more than 4,400 organisations, companies and individuals from around the globe (see table). ECHA notes that a large number of comments were received from Sweden, following a national campaign. 

The comments will now be evaluated by ECHA’s scientific committees for Risk Assessment (RAC) and Socio-Economic Analysis (SEAC). The five countries who prepared the initial proposal will also review the consultation input and may update their initial proposal based on it. The final opinions will be submitted to the European Commission, for decision on the outcome of the restriction proposal alongside EU Member States. 


PFAS regulation remains a necessary focus for attention at the ESMA HSEP Committee meetings. Please join us there for discussions on this and other important topics:

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