The European Chemicals Agency (ECHA) has released its updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the EU’s chemicals regulation REACH (Annex XVII of Regulation (EC) No. 1907/2006). The update represents Europe’s ongoing efforts to curb PFAS emissions and strengthen controls across a wide range of applications, including those in the packaging and food contact materials sectors.
Table of Contents
Updated Scope and Evaluation
The revised proposal was prepared jointly by authorities from Denmark, Germany, the Netherlands, Norway and Sweden, following a detailed review of more than 5,600 scientific and technical comments collected during ECHA’s 2023 public consultation.
Their revised “Background Document” now provides a broader and more detailed impact assessment across multiple industrial sectors, several of which were not explicitly covered in the initial draft.
The updated assessment includes eight additional sectors:
- Printing applications
- Sealing applications
- Machinery components
- Medical and pharmaceutical packaging uses
- Military applications
- Explosives
- Technical textiles
- Broader industrial applications such as solvents and catalysts
These additions expand the regulatory landscape and highlight how widely PFAS substances are used across manufacturing chains, including materials relevant to food packaging, coatings and barrier films.
Restriction Options Considered
The dossier submitters assessed three main restriction options (ROs) for PFAS under REACH, balancing public health protection with industrial feasibility:
- RO1: A general ban on all PFAS with an 18-month transition period and no derogations.
- RO2: A ban with time-limited derogations for specific applications, alongside the same 18-month transition period.
- RO3: Allowing continued use under strict containment and control conditions to minimize emissions throughout the life cycle of PFAS-containing products.
These options reflect the ongoing discussions about whether certain highly specialized or safety-critical uses, such as some food contact barrier materials, can remain temporarily permissible under controlled conditions.
Ongoing Scientific Review
ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-Economic Analysis (SEAC) are now evaluating the updated proposal. Their joint opinions will guide the European Commission’s final decision, expected after consultation with EU Member States.
ECHA emphasized its goal of ensuring a transparent and science-based restriction process, balancing environmental protection with the socioeconomic realities of affected the industries.
Impact on Packaging and Food Contact Applications
PFAS substances are commonly used in grease-resistant coatings, paper and board packaging, non-stick surfaces, and certain barrier films. If the updated restriction moves forward, manufacturers in the food contact and packaging supply chain may face tighter controls or complete phase-outs of fluorinated substances.
The industry is expected to intensify efforts to identify PFAS-free alternatives, particularly in fiber-based food packaging, recycled materials, and high-performance films where migration resistance and durability are critical. Early collaboration between material suppliers, converters, and brand owners will be essential to ensure continuity, compliance, and consumer safety.
Conclusion
This updated restriction proposal marks a turning point for the use of PFAS use in food contact and barrier materials. Companies should begin proactive substitution planning, invest in alternative material testing and stay closely aligned with ECHA’s forthcoming RAC and SEAC opinions to anticipate compliance deadlines.
