On November 20, 2024, the European Chemicals Agency (ECHA) and the authorities from Denmark, Germany, the Netherlands, Norway, and Sweden released a progress update on the process to restrict per- and polyfluoroalkyl substances (PFAS) in Europe. According to ECHA’s press release, the five authorities (Dossier Submitters) and ECHA’s scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) continue to consider more than 5,600 scientific and technical comments received from third parties during the 2023 consultation. The Dossier Submitters are using the comments “to progressively update and improve the information on PFAS.” ECHA notes that the comments also helped identify uses that were not specifically named in the initial proposal, and these are being incorporated into existing sector assessments or grouped into new sectors as needed. ECHA states that examples include sealing applications, technical textiles, printing applications, and other medical applications, such as packaging and excipients for pharmaceuticals.

According to ECHA, alternative restriction options, besides a full ban or a ban with time-limited derogations, are also being considered. ECHA states that “[a]n alternative option could, for example, involve conditions allowing the continued manufacture, placing on the market or use of PFAS instead of a ban.” ECHA notes that this option is particularly relevant for uses and sectors where evidence suggests that a ban could lead to disproportionate socio-economic impacts. These alternative options are being considered for uses including, but not limited to:

• Batteries;
• Fuel cells; and
• Electrolyzers.

ECHA states that the proportionality of each alternative option will be evaluated and compared to the initial two restriction options of a full ban or a ban with time-limited derogations. According to ECHA, this updated information is feeding into RAC and SEAC’s ongoing evaluations of the proposal. Further details about the ongoing work can be found in the progress update document