Dear Members, please see below update on the current stage of the EU proposed PFAS restriction
We are writing to share with you the ECHA PFAS mapping of which uses fall under which sector (at the link here) which was just made available by ECHA.
Background:
In the recent September ECHA PFAS plenary and in the 30 October ECHA webinar on how to prepare for the SEAC 60-day consultation, ECHA announced that it will publish a mapping of which PFAS uses fall under which sector, in order to help stakeholders understand which sector they need to comment on during the SEAC consultation in March/April 2026.
This is one of the two mappings that ECHA is making available; the next mapping that will be prepared by the end of 2026 and will be published together with the final ECHA Opinion, is the mapping of which uses are covered under which exemptions. This assessment can only be done by ECHA once they have the full overview of which exemptions will be proposed and this will only be possible at the end of the ECHA process (final Opinion adoption expected December 2026).
Assessment of the sector-uses mapping:
As Secretariat, we have reviewed the mapping of uses falling under the 15 sectors, and our initial reading is that, whilst it does give some indications of uses under sectors, the mapping is at this stage not complete, e.g.:
- The medical device sector mapping does not contain the full detailed list of sub-uses, to give one example, we are aware that surgical equipment for ophthalmological applications is covered under –> 1) Invasive devices –> 2) vision applications; however, this level of detail is not present in the mapping.
- The PFAS manufacturing and electronics sector uses are not added yet, as ECHA will first need to finalize its discussions on these sectors in the December 2025 plenary –> this is relevant for us, as we are awaiting for a written confirmation that our medical electronic technologies are covered under the electronics sector.
- Other sectors do not always have detailed uses – e.g. the lubricants sector lists three uses: industrial, professional, and consumer; however, it does not list the sub-uses, which were however, discussed in the September plenary of the lubricant sector. In that discussion in September, medical device uses of lubricants were acknowledged as a sub-use under professional lubricants.
The ECHA document does state that this mapping can still undergo changes and a final version will be published when the consultation begins.
Therefore, whilst this mapping is a step in the right direction towards providing more clarity (publicly) ahead of the SEAC consultation, there are still some gaps, which we will continue to help members navigate, based on the information we receive from the ECHA plenaries, with the next one taking place in December and we will be participating in as well.
