For those who were not able to attend the recent ECHA webinar on the upcoming public consultation on the draft opinion of the Committee for Socio-Economic Analysis (SEAC) regarding the proposed EU-wide restriction on per- and polyfluoroalkyl substances (PFAS):

• the webinar recording and the presentation material are now available on the event page
• the event page also includes a Q&A section where ECHA has responded to many of the questions raised
• the powepoint presentation slides

Key takeaways

1. ‍SEAC’s draft opinion is centred on proportionality
   SEAC will focus primarily on cost / benefit / practicability vs restriction — not on hazard science. Your evidence must therefore target proportionality arguments.‍
2. Sector level granularity is essential
   SEAC expects the most granular level possible (especially across the 14 sector categories). Submissions should not be at generic company-wide level‍
3. No attachments permitted
   All evidence must be submitted directly within the survey text / numerical fields. Internal evidence conversion and mapping must be prepared with this constraint in mind.‍
4. Consultation is planned for ~ March 2026
   Only 60 days. Companies need to pre-prepare internal harmonisation, structuring and data mapping well in advance.‍
5. Alternatives and impacts will be priority questions
   Data expected: PFAS tonnages per type, availability / feasibility of alternatives, profit loss, job loss, wider societal consequences.‍
6. Consultation structure: general survey and sector survey (TULAC for textiles)
   Both will need responses. Stakeholders can also provide data for uses not yet evaluated by SEAC.‍
7. Use mapping guidance will be published before consultation
   This will be key for alignment. First draft available here

Please review the material and familiarise yourselves with the structure and expectations of the consultation process.