On 3rd March the European Chemicals Agency (ECHA) announced that its Risk Assessment Committee (RAC) has adopted its scientific opinion on the proposed EU-wide restriction of per- and polyfluoroalkyl substances (PFAS) under the REACH Regulation.

This marks a major milestone in the regulatory process for the PFAS restriction proposal submitted in January 2023 by authorities in Denmark, Germany, the Netherlands, Norway and Sweden.

Key points

• RAC has concluded its scientific evaluation of the restriction proposal, including assessment of PFAS hazards, volumes, emissions, risks, and the effectiveness and practicality of a restriction.
• The proposal covers all PFAS substances and all uses, making it one of the broadest chemical restriction proposals under REACH to date.
• RAC’s role is to assess risks to human health and the environment related to the manufacture, placing on the market and use of chemicals.

The second committee involved in the evaluation is ECHA’s Socio-Economic Analysis Committee (SEAC), which assesses the socio-economic impacts of the proposed restriction and the availability of alternatives.

A broad PFAS restriction could have significant implications for product design, supply chains, and materials innovation across the sporting goods and outdoor industry. While many brands have already committed to phasing out PFAS in consumer products, some applications, particularly those requiring high-performance water repellence and durability, may still rely on these substances or require additional time to transition to alternatives. Additionally, as discussed in our latest joint webinar on the new PFAS test method (EN 17681 -1:2025) all apparel and footwear products are potentially in scope. (see document below)

The ongoing SEAC evaluation will be particularly relevant, as it examines the socio-economic impacts, transition timelines, and the availability of technically feasible alternatives.

Next steps and expected timeline

• The adopted RAC opinion will be published soon, providing full details of the opinion content.
• SEAC is expected to adopt its draft opinion next week. This draft opinion will be subject to a 60-day consultation.
• SEAC is expected to adopt its final opinion by the end of 2026.
• 2027 The European Commission is expected to consider the RAC and SEAC opinions and prepare a restriction proposal for discussion and vote by EU Member States in the REACH Committee.
• If adopted, the restriction would be implemented through Annex XVII of REACH, with specific scope, exemptions and transition periods to be determined.

Next steps for FESI

• We will Monitor publication of the RAC opinion and upcoming SEAC draft opinion.
• Consider participating in the SEAC public consultation once opened.
• Continue engagement with policymakers and regulators to ensure that transition timelines and exemptions reflect technical feasibility and availability of alternatives.
• Further updates will be shared as the process progresses.

Further information

Overview of the REACH restriction process

ECHA PFAS topic page

Q&A on the restriction process