POSITION | CHEMICAL POLICY | RESTRICTION
PFAS-Restriction Evaluation of the restriction proposal
24 April 2023 Background On 13 January 2023, the competent authorities from Germany, the Netherlands, Denmark, Sweden and Norway submitted a restriction dossier to restrict all PFAS (per- and polyfluoroalkyl substances). This was published in advance on 07.02.2023. On 22.03.2023, the conformity of the restriction proposal was confirmed by the ECHA Committees, and a public consultation was launched. The dossier is very comprehensive and consists of an Annex XV report with 7 annexes and 4 appendices. Scope of the restriction The restriction is intended to ban the production, placing on the market and use of all PFAS as such or in mixtures and articles (above certain concentration limits, see below). The scope of the restriction proposal refers to the OECD definition of PFAS. It includes all substances containing at least one fully fluorinated methyl group (-CF3) or methylene group (-CF2-) without further H, Cl, Br or I atoms (more than 10,000 substances in total). This also includes fluoropolymers and polymers with fluorinated side chains. Two restriction options are assessed in the restriction dossier: I.
Full ban on all PFAS with a transition period of 18 months (no derogations)
II.
Full ban on all PFAS with use-specific and time-limited derogations (6.5 years or 13.5 years after entry into force) and otherwise a transitional period of 18 months
The restriction dossier assesses Option II as the preferred option. For mixtures and articles, the following concentration limits are proposed for the full ban of all PFAS: -
≥ 25 ppb for each PFAS determined by targeted analysis (polymeric PFAS are excluded from quantification).
-
≥ 250 ppb for the sum of PFAS measured as sum of targeted PFAS analysis, optionally with prior degradation of precursors (polymeric PFAS excluded from quantification)