Per- and polyfluoroalkyl substances (PFAS) are recognized as ‘forever chemicals’ and are now a major concern in many countries. Several jurisdictions have introduced, or plan to introduce, restrictions on their use in consumer goods.
In Europe, Denmark, Germany, the Netherlands, Norway and Sweden have prepared a restriction proposal. In the US, while there is currently no federal legislation, several states have individually banned PFAS or have indicated their intention to do the same.
European Union
On February 7, 2023, the European Chemicals Agency (ECHA) published a REACH Annex XV Restriction Report on PFAS.
The proposal defines PFAS as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (- CF2-) carbon atom (without any H/Cl/Br/I attached to it). The proposed restriction contains one exclusion, introduced for a substance only containing the following structural elements:
CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH3), methylene (-CH2-), an aromatic group, a carbonyl group (-C(O)-), -OR’’, -SR’’ or –NR’’R’’’; and where R/R’/R’’/R’’’ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-)
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