Restrictions on the use of PFAS substances: past, present, future

PFAS, known as "forever chemicals," are facing increasing regulation in Europe. Learn about the main usage restrictions already in force or coming soon.

Thomas Forest
Consultant HSE
Publication : 
17.12.2024
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Please note: This article concerns French legislation. The requirements described may not apply in other countries.

Which products / mixtures are affected? When? Under what conditions?
Use of this substance prohibited on its own or in substances, mixtures or articles Since 4 July 2020 Concentration:

> 0.025 mg/kg (0.0000025% by weight) for PFOA and its salts

> 1 mg/kg (0.0001% by weight) for related compounds and any combination thereof
Use of this substance, its salts and related compounds for:
· Medical devices other than implantable devices
· Latex printing inks
· Plasma nano-coatings
Since 3 December 2020
Use of firefighting foams containing or liable to contain PFOA, its salts and related compounds at sites where it is not possible to contain all discharges Since 1 January 2023
Water- or oil-repellent textiles for personal protective equipment Since 4 July 2023
Use of this substance, its salts and related compounds for:
· Photolithography or etching processes in semiconductor manufacturing
· Photographic coatings applied to films
· Invasive and implantable medical devices
· Firefighting foam against liquid fuel vapours and liquid fuel fires (Class B fires) already contained in systems, whether mobile or fixed (but banned for training and testing where not all discharges are contained)
From 4 July 2025
Use of PFOA-related compounds in a substance intended to be used as a transported isolated intermediate Since 4 July 2020 Concentration > 20 mg/kg (0.002% by weight)
Use of this substance, its salts and related compounds in medical devices other than invasive and implantable devices Since 4 July 2020 Concentration > 2 mg/kg (0.0002% by weight)
Use of PFOA and its salts present in PTFE micropowders transported or treated to bring the concentration below the 0.025 mg/kg limit Since 18 August 2023 Concentration > 1 mg/kg (0.001% by weight)

For several years now, per- and polyfluoroalkyl substances (commonly known as PFAS substances) are progressively being subjected to usage restrictions.

These substances, used in many areas (industrial and everyday life), are particularly persistent in the environment (for this reason, they are also known as "forever chemicals").

Examples of use include: textiles (waterproofing, fire resistance), food packaging, firefighting foams, non-stick coatings, cosmetics, plant protection products…

Given that their impact on the environment and human health is a cause for concern and that these PFAS substances are found in all environments (air, water, and soil), European regulations have specifically introduced progressive usage restrictions; we summarize the main ones below.

PFOA Restriction since July 2020 (1)

(1) Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants, Annex I, Part A

Which products / mixtures are affected? When? Under what conditions?
Use of firefighting foams containing or liable to contain C9-C14 PFCAs, their salts and related substances at sites where it is not possible to contain all discharges Since 1 January 2023 Combined concentration:

≥ 25 ppb for PFCA and its salts

≥ 260 ppb for related substances

[ppb: parts per billion]
Use of this substance prohibited on its own or in substances, mixtures or articles Since 25 February 2023
Water- or oil-repellent textiles for personal protective equipment Since 4 July 2023
Use in semiconductors as such or incorporated into semi-finished and finished electronic equipment Since 31 December 2023
Use as a coating on pressurised metered-dose inhaler canisters Since 25 August 2024
Use of this substance, its salts and related substances for:
· Photolithography or etching in semiconductor manufacturing
· Photographic coatings applied to films
· Invasive and implantable medical devices
· Firefighting foam against liquid fuel vapours and liquid fuel fires (Class B fires) already contained in systems, whether mobile or fixed (but banned for training and testing where not all discharges are contained)
From 4 July 2025
Use of semiconductors used in spare or replacement parts for finished electronic equipment From 31 December 2030
Use in fluoropolymer resins and fluoroelastomers containing perfluoroalkoxy groups Since 25 February 2023 Combined C9-C14 PFCA concentration ≥ 2,000 ppb
Since 26 August 2024 Combined C9-C14 PFCA concentration ≥ 100 ppb
Use of PFCA, its salts and related substances, where present in a substance intended to be used as a transported isolated intermediate Since 25 February 2023 Combined C9-C14 PFCA concentration ≥ 10 ppm
[ppm: parts per million]
PTFE micropowders produced by ionisation or thermal degradation

Mixtures and articles containing PTFE micropowders intended for industrial and professional uses
Since 25 February 2023 Combined C9-C14 PFCA concentration ≥ 1,000 ppb

Exemptions to these usage restrictions are possible for:

  • the use of perfluorooctyl bromide containing perfluorooctyl iodide for the manufacture of pharmaceutical products (a review and evaluation by the Commission is foreseen by 31 December 2026 at the latest);
  • the use of articles already in use in the Union before 4 July 2020 and containing PFOA, its salts and/or PFOA-related compounds.

C9-C14 PFCA Restriction since January 2023 (2)

(2) Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), entry 68 of Annex XVII

Which products / mixtures are affected? When? Under what conditions?
Use of this substance prohibited on its own or in substances, mixtures or articles Since 28 August 2023 PFHxS or its salts at a concentration ≥ 0.025 mg/kg (0.0000025% by weight)

Sum of the concentrations of all PFHxS-related compounds ≥ 1 mg/kg (0.0001% by weight)

Concentrations of PFHxS, its salts and PFHxS-related compounds ≥ 0.1 mg/kg (0.00001% by weight) where present in concentrated firefighting foam mixtures intended for use, or used, in the production of other firefighting foam mixtures

PFHxS Restriction since August 2023 (3)

(3) Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants, Annex I, Part A

Which products / mixtures are affected? When? Under what conditions?
Use of this substance banned, whether on its own or in substances, mixtures, or articles Since August 28, 2023 PFHxS or its salts at a concentration ≥ 0.025 mg/kg (0.0000025% by mass)

Sum of the concentrations of all PFHxS-related compounds ≥ 1 mg/kg (0.0001% by mass)

Concentrations of PFHxS, its salts, and PFHxS-related compounds ≥ 0.1 mg/kg (0.00001% by mass) when present in concentrated firefighting foam mixtures intended for use, or used, in the production of other firefighting foam mixtures

Restrictions on the use of PFHxA from 2026, 2027, and 2029 (4)

(4) Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), entry 79 of Annex XVII

Which products / mixtures are affected?* When? Under what conditions?
Firefighting foams and foam concentrates for training and testing (excluding functional testing, and where all emissions are contained)

Firefighting foams and foam concentrates for public fire services (excluding industrial fires)
From 10 April 2026 Concentration measured in a homogeneous material:

≥ 25 ppb for the sum of PFHxA and its salts

≥ 1,000 ppb for the sum of PFHxA-related substances

[ppb: parts per billion]
Textiles, leather, fur and skins in clothing and related accessories intended for the general public

Footwear intended for the general public

Paper and board used as food contact materials

Mixtures intended for the general public

Cosmetic products
From 10 October 2026
Textiles, leather, fur and skins for the general public, other than those in clothing and related accessories From 10 October 2027
Firefighting foams and foam concentrates for civil aviation (including at civil airports) From 10 October 2029

*These restrictions do not apply to substances where the C6F13- perfluoroalkyl group is directly attached to a sulfur atom, which are already prohibited under Annex I of Regulation (EU) 2019/1021 on persistent organic pollutants.

Exemptions from these restrictions and prohibitions of use are possible for:

  • certain personal protective equipment (protection against substances and mixtures hazardous to health, harmful biological agents, ionizing radiation, hot environments (≥ 100 °C) and cold environments (≤ -50 °C), electric shocks and live working, and injuries from bullets or knife stabs);
  • medical devices present in healthcare and diagnostic facilities in vitro;
  • textiles used as construction textiles (insulation, waterproofing, roofing, foundations, cladding, etc.).