PFAS Regulation 2025–2026: EU Changes and Company Actions

MSDS-Europe – Compass to Chemical Safety – PFAS Regulation 2025–2026

 

PFAS in the EU in 2025–2026: Regulatory Directions and Company Actions

In 2025–2026, PFAS (per- and polyfluoroalkyl substances) in the EU is simultaneously a regulatory, customer, and technical issue.

The broad EU restriction process is advancing in stages: ECHA’s Risk Assessment Committee (RAC) adopted its opinion in March 2026, while the final opinion of the Socio-Economic Analysis Committee (SEAC) is expected by the end of 2026. At the same time, the already adopted restriction on PFAS-containing firefighting foam is supported by detailed transition guidance.

The purpose of this article is to provide an understandable yet technically accurate overview for economic operators (manufacturers, importers, distributors, downstream users). The focus is on company actions and technical implementation.

 

What Is PFAS, and Why Has It Become a Business Risk?

PFAS is a collective term for per- and polyfluoroalkyl substances. These substances are often used because of their high chemical stability, but many PFAS are extremely persistent in the environment. As a result, emission reduction and Substitution are becoming increasingly important across more and more sectors.

One of the main compliance challenges is that “PFAS” does not mean a single substance but a broad group of substances. Therefore, it is essential that the company and its supplier use the same PFAS definition. The OECD has issued dedicated guidance to help harmonise PFAS terminology for practical use across multiple stakeholders.

 

What Is Happening in the EU in 2025–2026?

 

1) Broad EU PFAS Restriction: Where Does the Process Stand?

According to the latest regulatory timetable, the broad PFAS restriction process is moving forward in stages. RAC has already adopted its opinion, while SEAC is expected to conclude the scientific evaluation by the end of 2026.

This means that 2025–2026 is primarily a period for preparation, data collection, and planning alternatives and transition pathways.

The key message for companies is clear: it is not enough to prepare for one single “big date”. It is better to establish an internal programme that can handle gradual and sector-specific requirements. The logic of restrictions and the related obligations can be followed through the Regulatory Change Observer and the REACH knowledge base.

 

2) Firefighting Foam: Specific Restriction and Practical Transition Guidance

In 2025, the European Commission adopted a REACH restriction on PFAS-containing firefighting foam. The regulation applies transitional periods depending on the field of use.

The restriction starts to apply from October 2026, and the implementation is phased, including earlier ban elements for portable fire extinguishers.

From an implementation perspective, the transition is not only about product replacement. It also involves cleaning systems, reducing liquid use, storage, waste management, and disposal.

 

3) Drinking Water: 2026 Compliance Deadline and Measurement Methodology

Directive (EU) 2020/2184 requires Member States to ensure compliance with the PFAS parametric values for water intended for human consumption by 12 January 2026.

In practical compliance work, not only the limit value but also the measurement approach is a key issue.

The European Commission has published technical guidance on methods suitable for monitoring PFAS Total and Sum of PFAS, following consultation with the Member States.

 

How Can Compliance Differ Between Member States?

The central part of EU legislation is the same, but implementation may differ from one Member State to another. These differences usually appear not in the objective, but in the way the rules are enforced.

 

Transposition of Directives and Possible Stricter National Rules

For directives such as the Drinking Water Directive, Member States transpose the requirements into national law. They may also introduce stricter values or additional parameters.

 

Official Controls and Sanctions

The frequency of inspections, the scope of documents that may be requested, and enforcement practice may vary between Member States. Therefore, good practice is to establish an internal registry system covering documentation, measurements, and change management, rather than trying to meet only the minimum requirement.

 

Waste Management and Disposal

In the transition away from firefighting foam, the EU-level technical steps are relatively clear, but practical waste management and disposal routes may differ by Member State.

This is particularly important for legacy stocks, rinse water, and contaminated material streams generated during system cleaning.

 

Analytical Methods, Accreditation, and Expected Detection Limits

The Commission’s methodological guidance identifies analytical methods and approaches, but laboratory capacity, accreditation practice, and regulatory expectations may differ between Member States.

For this reason, it is important to define the objective of testing in advance: demonstrating compliance, checking the effectiveness of transition measures, or identifying a release pathway.

 

Who Is Affected? Typical Roles Concerned in the Economy

PFAS is not only a “chemical manufacturer” issue. It often appears where product performance is critical, for example in coatings, seals, or surface treatment, or where inventories and systems are in place, such as fire protection.

The following actors may be affected, for example:

  • Manufacturer and mixture formulator.
  • Importer and distributor, especially in complex supply chains.
  • Downstream user in industrial processes.
  • Facility operator holding firefighting foam stock or operating foam-based extinguishing systems.

 

Company Actions in 2025–2026: Audit-Ready Preparation Step by Step

The purpose of the approach below is to support both legal compliance and business continuity. The sequence is intentionally structured as a practical project workflow.

 

1) PFAS Inventory: What Is Used, Where, and Why?

Start by mapping PFAS relevance across the organisation:

  • substances and mixtures (raw materials, auxiliaries),
  • finished and semi-finished products,
  • on-site inventories, especially firefighting foam.

A practical filter is to search by function as well, for example non-stick performance, water repellency, or chemical resistance. This helps identify hidden PFAS uses.

 

2) The Limits of the Safety Data Sheet (SDS): What Else Should Be Requested?

The safety data sheet is a core document, but it is not always sufficient to demonstrate PFAS relevance clearly. In some cases, the SDS does not provide enough detail on the presence of PFAS as a substance family, or the information is limited due to confidential business information.

The practical solution is a targeted supplier data request based on a consistent definition. OECD terminology recommendations can serve as a useful reference point for that consistency.

 

3) Supplier Questionnaire: What Should You Ask So the Reply Is Usable?

Recommended topic blocks:

  • presence of PFAS according to the defined scope,
  • type of supporting evidence available (testing, method description, quality assurance),
  • change management: notification in the event of composition changes and updated documentation,
  • alternatives and Substitution status, including any replacement plan.

 

4) Risk Ranking: Where Should Action Start First?

Ranking criteria may include:

  • regulatory focus areas, for example firefighting foam,
  • customer compliance pressure (audit, tender, export),
  • potential release pathways (site water, cleaning processes).

For firefighting foam, it is advisable to launch a dedicated transition project, because the technical steps and documentation requirements are complex.

 

5) Measurement Strategy: Less, but More Targeted

One of the most common mistakes is the “measure everything” approach. Instead, define a clear objective:

  • confirming or excluding PFAS presence within a product family,
  • checking transition performance before and after replacement,
  • identifying a release pathway.

For drinking water and monitoring, the Commission’s methodological guidance can help ensure that the selected measurement approach is also interpretable from a regulatory perspective.

 

6) Substitution: Planned Replacement with Validation

PFAS is often performance-critical. A Substitution project is stable only if it includes:

  • a test plan (laboratory and plant trial),
  • quality assurance approval,
  • customer communication,
  • documented change management.

 

7) Documentation and Communication: What Can a Company Claim Safely?

A “PFAS-free” claim is defensible only if it is supported by:

  • supplier declarations,
  • test results where justified,
  • traceable change management.

Without this evidence, the claim may create risk during a customer complaint, tender review, or audit.

 

8) Firefighting Foam Transition: Practical Minimum Package

Typical tasks in a transition project include:

  • inventory survey (foam type, quantity, use),
  • selection of a fluorine-free alternative,
  • cleaning of infrastructure to minimise PFAS residues,
  • organisation of waste management and disposal routes,
  • verification sampling and documentation.

 

FAQ – PFAS 2025–2026

When can the major turning point in the broad EU PFAS restriction be expected?

According to ECHA, RAC has already adopted its opinion, while the final SEAC opinion is expected by the end of 2026. Legislative steps will follow that process, so companies should prepare for gradual transition periods rather than a single cut-off date.

Why is one single PFAS list not enough for supplier declarations?

Because PFAS terminology and scope can easily diverge. OECD guidance was issued precisely to support consistent interpretation of what is covered by PFAS.

Is the safety data sheet (SDS) enough to determine PFAS relevance?

Often it is not. The SDS is primarily a hazard communication document. To assess PFAS relevance, a targeted supplier data request and, where justified, analytical testing may also be necessary.

Which organisations should urgently start phasing out PFAS-containing firefighting foam?

Any organisation that stores firefighting foam or operates foam-based extinguishing systems, because the restriction starts to apply in autumn 2026 and the technical transition may take significant time.

Why can there be differences between Member States if the rule is based on EU law?

For regulations, the substantive rule is the same, but enforcement and practical implementation may differ. For directives, Member States may transpose the requirements more strictly and may introduce additional parameters.

What are the first three steps when a customer asks for a PFAS declaration?

(1) Prepare a PFAS inventory covering products and auxiliaries. (2) Use a consistent supplier questionnaire and definition. (3) Decide where testing is needed and where documentation plus change management is sufficient.

 

Summary: 2025–2026 Is the Period of Preparation – and It Can Also Be a Competitive Advantage

The PFAS regulation landscape in the EU is evolving quickly. The safest company strategy is demonstrable transparency: inventory, supplier data, targeted testing, planned Substitution, and, where relevant, a dedicated firefighting foam transition project.

 

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