PFAS – The current situation regarding the ‘general ban’ on PFAS
Background:
PFAS are highly persistent chemicals that do not break down in the environment and can travel long distances via water and air. Once released into the environment, they often contaminate groundwater and drinking water, and remediating this contamination is complex and costly. Certain PFAS accumulate in humans, animals and plants and can cause toxic effects, including cancer and damage to reproductive health.
The proposal to restrict PFAS in the EU/EEA was drawn up by the authorities in Denmark, Germany, the Netherlands, Norway and Sweden and submitted to ECHA on 13 January 2023. The aim is to reduce PFAS emissions into the environment and make products and processes safer for the public. The six-month consultation period ran from 22 March to 25 September 2023. More than 5,000 submissions were received.
The Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC) of the European Chemicals Agency (ECHA) completed their assessments of the proposal for a universal restriction on all per- and polyfluoroalkyl substances (PFAS) in mid-March. The drafts will shortly be published on the ECHA website for a 60-day consultation.
The RAC assesses the risks to human health and the environment arising from the manufacture, placing on the market and use of chemicals, whilst the Committee for Socio-economic Analysis (SEAC) assesses the socio-economic impacts of a restriction, taking into account the availability of alternatives.
Next Steps:
The draft SEAC opinion and the final RAC opinion will be published shortly and will contain full details of the opinions’ content. The draft SEAC opinion will be subject to a 60-day consultation. The Committee is expected to adopt its final opinion by the end of 2026, taking into account any new information received during the consultation. Once adopted, the scientific evaluation of the proposed restriction by the ECHA Committees will be complete, and the opinions will be formally submitted to the Commission.
Auf Grundlage der beiden endgültigen Stellungnahmen wird die Europäische Kommission dem REACH-Ausschuss, der sich aus EU-Mitgliedstaaten zusammensetzt, eine Beschränkung zur Diskussion und Abstimmung vorschlagen.zeitig auf fundierte Analysen und ganzheitliche Bewertungsmethoden setzen, verschaffen sich nicht nur ökologische, sondern auch wirtschaftliche Vorteile.
Source: ECHA
POP VO entries planned for: MCCP + long-chain PFAS
The EU is implementing the new listings agreed under the Stockholm Convention by adopting Commission delegated regulations that amend Annex I to the POPs Regulation (EU) 2019/1021. This follows the decisions taken at COP-12 (April–May 2025) to include chemicals/groups in Annex A (elimination).
MCCPs – Medium-chain chlorinated paraffins: The EU delegated act on the inclusion of MCCPs in Annex I of Regulation 2019/1021, in accordance with the COP-12 list (Annex A) and any narrowly defined exemptions. This update highlights the phased phase-out of MCCPs from various articles and materials. MCCPs have historically been used as plasticisers or flame retardants in PVC trims and films, imitation leather, rubber (e.g. soles), printing inks, paints, adhesives and surface coatings. They may be present as legacy contaminants and also occur as impurities in some leather chemicals.
LC-PFCAs – Long-chain perfluorocarboxylic acids (C9–C20), their salts and related compounds. An EU delegated act on the inclusion of LC-PFCAs (and related compounds) in Annex I implements the decision of COP-12 Annex A, subject to specific exemptions. LC-PFCAs were frequently used for impregnation. Even if they are no longer intentionally used, they may occur as residues/contaminants or as degradation products of older equipment. The EU already restricts C9–C14 PFCAs under REACH Annex XVII (25 ppb for the acids/salts; 260 ppb for related substances in substances, mixtures and articles). The POPs list may become more comprehensive (up to and including C20 and including precursor substances) and again contains very low limit values for ‘unintended trace contaminants’ – hence the requirements will become stricter.
Source: POPs
Standardisation – Test methods
There is also renewed activity in the field of national and international standardisation. The international committee on footwear, ISO TC 216, is working on a method for PFAS determination, which primarily focuses on plastic, paper and cardboard matrices, in order to close the gap in PFAS standardisation for consumer goods such as footwear. However, other harmful substances are not being neglected either. The draft standard for the determination of bisphenols in shoes and shoe components is almost complete and will be published in the coming months.
The international leather standards committee, ISO TC 289, is currently working on a revision of the outdated DIN EN ISO 17070 standard, which dates from 2015 and covers the determination of chlorinated phenols.
But the issue of PFAS is also ever-present in the leather sector, and another exciting project involves developing a method for determining total fluor in leather.
Do you have any questions?
Your Contact Person:

Dr. Ines Anderie
Chemical and Microbiological Analysis
Sign up for our newsletter to stay up to date.
Did you enjoy our blog article? Then sign up for our newsletter today! Published quarterly, it provides exciting insights into all things PFI. Stay informed about the latest topics in research, development, and testing—always up to date!

