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29 December 2025

ECHA's Committees Continue To Evaluate PFAS Uses; ECHA Publishes Guidance For Upcoming Consultation On SEAC's Draft Opinion

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The European Chemicals Agency's (ECHA) Committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) met in December 2025.
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The European Chemicals Agency's (ECHA) Committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC) met in December 2025. According to ECHA's December 17, 2025, press release, RAC and SEAC progressed their evaluation of the updated proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the European Union's (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) regulation. According to ECHA, both committees reached provisional conclusions on PFAS manufacturing, while SEAC also concluded on electronics and semiconductors. ECHA states that both committees also continued examining the horizontal issues relevant to the entire restriction, including concentration limits above which PFAS could be restricted; PFAS management plans; recycling; spare parts; practicality — including enforceability — and monitorability, and whether the proposed restriction is the most appropriate EU-wide measure to address the risks from PFAS.

According to ECHA, the tentative plan for the committees' March 2026 meetings includes:

  • Final discussion and adoption of RAC's opinion; and
  • Discussion and agreement on SEAC's draft opinion.

ECHA states that RAC "is expected to adopt its opinion in March 2026 while SEAC will agree its draft opinion for further consultation." ECHA expects the 60-day stakeholder consultation on SEAC's draft opinion to begin soon after the draft opinion has been agreed at the Committee's March 2026 meeting.

ECHA has published a December 2025 "Consultation on the SEAC draft opinion on restricting per- and polyfluoroalkyl substances (PFAS) — Guidance for respondents." ECHA designed the guidance to help respondents prepare for the consultation and to understand what information is requested. The guidance notes that while SEAC's opinion making is still ongoing at the time of publication, ECHA may make minor revisions to the survey questions or approach. The guidance notes that "the scope and purpose of the surveys will remain broadly as outlined in this document." ECHA held a webinar in October 2025 on the consultation format and has posted a recording of the webinar and questions and answers from stakeholders.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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