echa-committee-assessments-on-the-eu-wide-pfas-restriction

In March 2026, the European Chemicals Agency’s (ECHA) committees published their opinions on the proposed EU-wide restriction of per- and polyfluoroalkyl substances (PFAS). These assessments follow ECHA’s restriction proposal, published in August 2025, and mark an important step in the development of one of the most significant chemicals regulatory initiatives currently under consideration in the EU.

PFAS: definition and use in cosmetic products

The Organisation for Economic Co-operation and Development (OECD) defines PFAS as fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon atom, without any hydrogen, chlorine, bromine, or iodine atom attached to it. In practical terms, subject to a few noted exceptions, any chemical containing a perfluorinated methyl group (–CF₃) or a perfluorinated methylene group (–CF₂–) is considered a PFAS.

PFAS are valued for their exceptional resistance to degradation, heat, water, and oil. This resilience is due to the strength of carbon-fluorine bonds, which are among the strongest bonds in chemistry. However, the same properties that make PFAS useful also make them highly persistent in the environment. These “forever chemicals” can accumulate in water, soil, and living organisms, and studies have associated PFAS exposure with potential adverse health effects, including endocrine disruption, immunotoxicity, and carcinogenicity.

In cosmetics, PFAS are used to enhance product performance, including long wear, water resistance, smooth application, and improved texture. They may be found in products such as waterproof mascaras and eyeliners, long-lasting foundations and concealers, lipsticks and lip glosses, powders, and primers.

RAC’s opinion on PFAS restrictions

The Committee for Risk Assessment (RAC) is responsible for assessing the risks that substances may pose to human health and the environment under REACH.

In this case, RAC assessed whether PFAS pose risks to people and the environment, and whether the proposed EU-wide REACH restriction is an appropriate measure to address those risks.

Following several years of work involving rapporteurs, RAC members, ECHA experts and a wide range of stakeholders, RAC concluded that PFAS present a growing risk and that further regulatory action is needed. The main driver for action in RAC’s assessment is the very high persistence of PFAS: once released, they remain in the environment for a very long time, accumulate, and the risk increases with continued releases over time.

RAC also noted that some PFAS have additional hazardous properties, including (eco)toxicity, mobility, bioaccumulation, long-range transport and global warming potential.

RAC’s position on substance identity

RAC supported the use of the OECD definition of PFAS for the purpose of grouping substances under the restriction. Although this definition is broad and covers a very large group of substances, the committee considered that a narrower definition could create a risk of substitution, where one PFAS is replaced by another similar PFAS with comparable persistence or hazardous properties. RAC also considered that the evidence provided was not sufficient to justify excluding certain PFAS subgroups on the basis that they are fully degradable.

RAC’s approach to thresholds and restrictions

RAC agreed with the Dossier Submitter that PFAS should be treated as non-threshold substances for the purpose of risk assessment.

From a regulatory perspective, however, it generally supported the proposed concentration limit of 25 ppb for individual PFAS in substances.

RAC explicitly noted that, given the non-threshold approach used for PFAS, there is no basis for setting a risk-based concentration limit; from a risk perspective, the limit should be set as low as possible. The 25 ppb value is therefore best understood as a practical compliance limit, not a toxicologically safe level. This limit is already used for several existing restrictions, such as PFOA and PFHxA. Nevertheless, the committee recognized that the 25 ppb limit may not currently be achievable for certain PFAS with available analytical methods.

SEAC’s draft opinion of PFAS restrictions

SEAC’s draft opinion assesses whether the proposed EU-wide PFAS restriction is proportionate from a socio-economic perspective. It takes RAC’s risk assessment as a starting point but weighs the expected health and environmental benefits of reducing PFAS emissions against the potential costs for industry, consumers, alternative providers and society.

In its draft opinion, SEAC broadly supports a wide PFAS restriction with use-specific derogations, rather than an immediate ban for all uses, because some sectors may need more time to substitute PFAS where alternatives are not yet technically or economically feasible. Its assessment is carried out use by use, considering evidence on alternatives, emissions, substitution timelines, costs, benefits and wider socio-economic impacts.

For cosmetic products, the committee concluded that no derogations are justified for the use of PFAS.

SEAC’s draft opinion is open for consultation from 26 March to 25 May 2026.

Next steps: European Commission decision making

Once SEAC publishes its final opinion, the European Commission will propose a restriction based on the assessments of both committees. The proposal will be discussed and voted on in the REACH Committee, composed of EU Member States.