PFOA and related compounds restricted under REACH Annex XVII (Entry 68) and designated as Persistent Organic Pollutants under Regulation (EU) 2019/1021.
PFAS
PFAS Compliance under REACH
By end of 2026, ECHA's SEAC is expected to adopt its final opinion on the universal class-based PFAS restriction covering more than 10,000 substances. Once adopted, the opinion will be transmitted to the European Commission as the basis for amending REACH Annex XVII. For food contact packaging, the PFAS ban under PPWR Art. 5 enters into force on August 12, 2026.
Any company placing PFAS-containing products on the EU market is faced with the existing REACH restrictions today. A universal restriction covering more than 10,000 PFAS substances is advancing toward adoption.
Next deadline
12 August 2026: PFAS limits in food contact packaging enters force under PPWR Art. 5 (Regulation EU 2025/40).
For companies placing packaged food on the EU market, this is the immediate hard deadline: food contact packaging containing PFAS above permitted thresholds cannot legally be placed on the EU market from that date. Under REACH, the next major regulatory milestone is the end of 2026, when ECHA's Committee for Socio-Economic Analysis (SEAC) is expected to adopt its final opinion on the universal class-based PFAS restriction covering more than 10,000 substances. That opinion, combined with the RAC final opinion published in March 2026, will be transmitted to the European Commission as the basis for amending REACH Annex XVII. Companies in affected sectors should treat 2026 as the last window to complete substance inventories and assess substitution options before binding restriction timelines are confirmed.
Regulation timeline
What the regulation requires
PFAS (per- and polyfluoroalkyl substances) is a class of more than 10,000 synthetic chemicals characterized by their persistence in the environment and human tissue. Several specific PFAS are already restricted under REACH Annex XVII. Any company placing products on the EU market that contain PFAS classified as substances of very high concern (SVHCs) above 0.1% weight by weight must notify the ECHA SCIP database under REACH Article 33. There are currently more than 40 PFAS substances on the SVHC Candidate List. A universal restriction covering PFAS as a class is advancing through ECHA's committee process with both RAC and SEAC opinions expected by end of 2026.
Operational challenges of PFAS compliance
Substance-level PFAS data can rarely be obtained from existing supplier records
PFAS is a class of more than 10,000 substances, not a single chemical. Existing supplier records rarely specify which PFAS are present at what concentrations. Substance-level data collection across a multi-tier supply chain requires a structured supplier engagement process that standard ERP and product information systems are not built to support.
SCIP notification obligations expand twice a year as the SVHC Candidate List is updated
REACH Article 33 requires a SCIP database notification for every article containing an SVHC above 0.1% by weight. Each notification requires article identification, substance identity, concentration range, and safe use information. The SVHC Candidate List is updated twice a year, therefore a product catalog that is fully notified today can require new submissions within months without any change to the products themselves.
Reformulation and material qualification take longer than most restriction transition periods allow
Both ECHA committees have issued opinions in favor of a broad PFAS prohibition. The Annex XVII amendment is not expected before 2027, but derogation timelines for specific sectors are still being shaped through the ongoing regulatory process and have not yet been confirmed. Starting substance mapping and substitution assessments before timelines are confirmed is the only way to have options when they are.
osapiens HUB for Product Compliance
PFAS substance data collection, SCIP notifications, and REACH compliance on one platform
The osapiens HUB manages PFAS substance data collection, SCIP notifications, and REACH compliance alongside RoHS, POPs, and PPWR obligations from a single supplier data layer and product catalog.
Collect and automatically evaluate supplier substance declarations against REACH restrictions.
Structured questionnaires are sent through the supplier portal, available in 29 languages at no license cost to suppliers. Every response is automatically evaluated against applicable REACH restrictions and SVHC concentration thresholds, returning a conformant, non-conformant, or not-applicable status per substance per article.
Generate and submit SCIP notifications to ECHA for every article where an SVHC threshold is exceeded.
Once substance data has been collected and evaluated, the osapiens HUB generates, validates, and submits SCIP Simplified Notifications for every article where an SVHC threshold is exceeded. Each notification includes substance identity, concentration range, and safe use information according to ECHA requirements. The same workflow handles new obligations as the Candidate List expands twice a year.
Manage REACH, RoHS, POPs, and PPWR substance obligations from one supplier data layer.
Supplier substance data collected for REACH SVHC reporting significantly reduces the data collection effort for RoHS restriction checks and POPs compliance assessments. When PPWR substance obligations require parallel data collection for food contact packaging, the same supplier profile is used across both workflows.
PFAS RESOURCES AND GUIDES
Frequently asked questions (FAQs)
Several specific PFAS are already subject to binding restrictions under REACH Annex XVII. PFOS and its salts are restricted under Entry 53. PFOA and related compounds are restricted under Entry 68 and the EU POPs Regulation. PFAS in firefighting foams are subject to a restriction adopted in April 2025, with the prohibition on use taking effect in 2030. The universal restriction covering PFAS as a class is advancing through ECHA's committee process but has not yet been adopted.
REACH Article 33 requires any supplier of an article containing an SVHC above 0.1% weight by weight to notify the ECHA SCIP database. More than 40 PFAS substances are currently on the SVHC Candidate List, which is updated twice a year. The notification obligation applies per article, and each submission must include article identification, substance identity, concentration range, location, and safe use information.
No binding compliance date has been confirmed. SEAC is expected to finalize its opinion by the end of 2026. The European Commission will then draft an amendment to REACH Annex XVII, a process unlikely to produce a final restriction before 2027 at the earliest. For most sectors, use-specific derogations and transition periods are expected; longer timelines have been indicated for electronics, medical devices, and semiconductors.
Yes. A REACH Annex XVII restriction applies to the manufacture, use, and placing on the EU market, which covers imports. Companies based outside the EU that export PFAS-containing products to the EU market are subject to the restriction through their EU importers or authorized representatives.
Penalties are set by individual EU Member States. In Germany, non-compliance with REACH obligations, including failure to submit SCIP notifications, can result in administrative fines, criminal prosecution, and, in serious cases, imprisonment. The applicable penalties depend on the nature and severity of the violation.
No. The ban on PFAS in food contact packaging from August 12, 2026 arises under PPWR Art. 5 (Regulation EU 2025/40), which is packaging-specific legislation separate from REACH. The two regimes have different scopes, thresholds, and compliance mechanics. See the PPWR regulation page for packaging-specific requirements.
