PFAS in the EU: a regulatory turning point

A & O Shearman | April 1, 2026

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"This development follows the adoption by the Committee for Risk Assessment (RAC) of its final opinion on March 3, 2026,¹ on the proposed PFAS restriction concluding that PFAS pose an EU-wide risk that justifies restriction.¹

Together, these steps signal that the process has moved beyond scientific risk assessment into a phase of regulatory and policy calibration, in which stakeholders are invited to provide evidence on key issues such as the availability of alternatives, the need for derogations and appropriate transitions.²

The restriction proposal was formally received by ECHA on January 13, 2023, having been prepared and submitted by the authorities of four EU member states—Germany, the Netherlands, Denmark and Sweden—together with Norway as a contracting party to the European Economic Area.³ ECHA published the detailed restriction proposal on February 7, 2023.⁴ A six-month public consultation on the proposal ran from March 22 to September 25, 2023.⁵"