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The PFAS Regulatory Landscape – are you ready?

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In the first part of our series (Shaping a Future without PFAS), we explored the urgent need to address the widespread use of PFAS (per- and polyfluoroalkyl substances) in various industries, highlighting the significant environmental and health risks posed by these persistent chemicals. As we investigated the challenges and advancements in developing PFAS-free alternatives, it became clear that a collaborative effort is essential to phase out these harmful substances. Building on this foundation, our second article shifts focus to the upcoming regulatory changes aimed at controlling and eventually eliminating the use of PFAS. We’ll examine the implications of these changes, their impact on industries, and how businesses can adapt to a future where PFAS is no longer a hidden threat in our environment and products.

The PFAS Regulatory Landscape

At the beginning of 2023, two new pieces of EU legislation came into force which limit human exposure to harmful quantities of PFAS. The concentrations of PFAS compounds in food are now regulated by Commission Regulation (EU) 2022/2388, while Directive (EU) 2020/2184 places limits on the presence of PFAS in drinking water.

In parallel to these EU regulations, the U.S. Environmental Protection Agency (EPA) has introduced a range of strategies and programmes to limit human and environmental exposure to PFAS, including removal of an exemption permitting organisations to avoid reporting the release of small quantities of PFAS to the environment [1]. The EPA has also proposed a rule that would prevent commencement or resumption of the manufacture, processing, or use of three hundred or more dormant PFAS chemicals that have not been made or used for many years, without a complete review and risk assessment by the EPA. [2] [3]


Fluoropolymer foams find application in aerospace interiors and seating due to their low flammability and low smoke release. Fluoropolymers are used throughout the aerospace industry and could be heavily impacted by the upcoming regualtions.

Restriction of PFAS in end-use products

Another significant date on the regulatory horizon is 2025, when The European Chemicals Agency (ECHA)’s recommendations on the restriction of PFAS chemicals will pass into law and become part of REACH regulations. This will result in a total ban on the use of many PFAS above a threshold quantity at the end of a limited 18-month transition period.

The nonwoven industry will need to wait for the decision from the ECHA on how fluorinated polymers may be restricted, but due to uncertainties around their disposal at end of life it seems unlikely that they will escape EU regulation entirely.

Certain derogations to the law will be permitted based on socio-economic considerations and the availability of alternatives, although these will gradually cease over the next 5 and 12 years. In addition, some time-unlimited derogations are proposed, such as for example, PFAS used as active substances in plant protection products, biocidal products, and human and veterinary medicinal products. [4]

PFAS vs Fluoropolymer

Many players within the chemical industry and industrial sector are seeking to differentiate fluoropolymers from PFAS chemicals. Whilst a key chemical manufacturer has announced its exit from food contact and cosmetic use of PFAS, as well as a transition away from the use of fluorinated surfactants in the synthesis of fluorinated polymers, they are strongly against the banning or restriction of fluorinated polymers themselves. [5] This position is mirrored by other major players in fluoropolymer manufacture. [6]



International/Stockholm Convention

Stockholm Convention of persistent organic pollutants updated to include Perfluorooctane sulfonic acid (PFOS). Effectively controlling production and distribution to specific applications.


International/Stockholm Convention

Stockholm Convention of persistent organic pollutants updated to include Perfluorooctanoic acid (PFOA) to control production and distribution to specific applications.

June 2022

International/Stockholm Convention

Stockholm Convention on persistent organic pollutants updated to ban the production and distribution of Per-fluorohexane sulfonic acid (PFHxS) entirely

January 2023

Denmark, Germany, Netherlands, Norway and Sweden

A proposal to introduce a class chemical ban affecting the production and distribution of >10,000 substances (based on elements of their structure) is submitted to EU member states for consultation.

February 2023


C9-C14 perfluorinated carboxylic acids (PFCAs) entered the REACH candidate list of substances of very high concern (SVHC).

March 2023


Start of ECHA Consultation Period.

September 2023


ECHA Committees’ evaluation began.



Proposed Legislation enters law and EU member states adopt the ECHA recommendations. An 18-month transition period begins.



Proposed 18 Month transition period ends.



Proposed 5 Year derogation for food contact products ceases.



Proposed 12 Year derogation for medical devices ceases.

As we reach the conclusion of our exploration into the evolving regulatory landscape surrounding PFAS (per- and polyfluoroalkyl substances), it’s clear that the nonwoven industry stands at a pivotal crossroads. Our journey when developing NIRI’s comprehensive whitepaper has illuminated the challenges and opportunities that lie ahead in replacing PFAS.

In the next chapter of our PFAS series, we will focus specifically on how the nonwoven industry can proactively respond to these changes. We’ll explore practical steps, innovative approaches, and the collaborative efforts needed to successfully navigate this transition to PFAS-free products, ensuring a safer and more sustainable future. Stay tuned for an in-depth look at the proactive strategies and solutions that will shape the nonwoven industry’s journey towards a PFAS-free era.

Discover more in the full whitepaper or contact the team at NIRI today to explore how we can support your business with its PFAS related hurdles.


[1] https://www.epa.gov/toxics-release-inventory-tri-program/changes-tri-reporting-requirements-and-polyfluoroalkyl

[2] PFAS Strategic Roadmap: EPA’s Commitments to Action 2021–2024, Document Number EPA-100-K-21-002, United States Environmental Protection Agency (EPA) [internet] c2021 Oct [cited 2023 Oct 27]. Available from: https://www.epa.gov/system/files/documents/2021-10/pfas-roadmap_final-508.pdf

[3] https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-management-and-polyfluoroalkyl-substances-pfas

[4] https://echa.europa.eu/documents/10162/aea5537d-b698-3b75-4b67-0cadd0fd11d3

[5] https://www.solvay.com/en/pfas-eu-regulation

[6] https://cen.acs.org/policy/chemical-regulation/battle-over-PFAS-Europe/101/i31