SubstancesSubstance class; firefighting foam restriction and C9-C21 PFCA POP listing adopted, wider restriction under assessment

PFAS: Per- and Polyfluoroalkyl Substances

Note: general educational information, not legal advice. Check the official source before relying on it.

A class of thousands of extremely persistent synthetic chemicals, nicknamed the 'forever chemicals'. The first class-wide EU restriction is already law for one sector, firefighting foams, the long-chain PFCAs are being prohibited outright as POPs, and a broader restriction proposal is still under assessment.

Updated
2026-09-15

Overview#

PFAS are a large family of human-made chemicals that do not break down in the environment, which is why they picked up the nickname "forever chemicals". They are prized for being water-, grease- and heat-resistant, and they are now a top regulatory target.

Key point

PFAS aren't a single substance. The family runs to thousands of related chemicals. Because of that scale, regulators are shifting away from banning them one at a time toward restricting the whole class at once.

Why they matter#

What they are
Synthetic chemicals with very stable carbon-fluorine bonds
The problem
Extremely persistent, mobile, and widespread in people and environment
Where they're used
Coatings, textiles, electronics, seals, lubricants, packaging
The direction
Broad restriction, not case-by-case

The regulatory picture#

Existing
POP Regulation
PFOS, PFOA and PFHxS are already restricted as persistent organic pollutants. See the EU POP Regulation.
Existing
REACH restrictions
Specific PFAS uses are restricted, and several are SVHCs
2023
Universal PFAS proposal
Five countries (incl. Germany) submitted a REACH restriction dossier targeting the entire PFAS class
Oct 2025
Firefighting foams restricted
Regulation (EU) 2025/1988 added entry 82 to REACH Annex XVII, the first restriction to take the whole PFAS class as its scope in one sector
Sep 2026
C9-C21 PFCAs become POPs
The Commission adopted a delegated act listing long-chain perfluorocarboxylic acids in Annex I to the POP Regulation, prohibited from 16 December 2026
Ongoing
Assessment
ECHA committees are assessing scope, derogations and timelines for the wider proposal

These controls sit across POP and REACH, and internationally under the Stockholm Convention.

Firefighting foams: REACH Annex XVII entry 82#

This one is adopted law, not a proposal. Commission Regulation (EU) 2025/1988 added entry 82 to Annex XVII of REACH. It entered into force on 23 October 2025, and its first compliance dates fall in October 2026.

Key point

Entry 82 does not name individual PFAS. It restricts 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 OECD definition, written into the entry itself. That is a structural test rather than a list, so a PFAS that nobody has named yet is in scope the day it is formulated into a foam.

The two limits#

PFAS in firefighting foam, sum of all PFAS1 mg/L Fluorine-free foam from cleaned equipment50 mg/L

The 1 mg/L figure is the restriction limit itself, expressed for the sum of all PFAS. The 50 mg/L figure is a narrow allowance in paragraph 4 for the residue that stays behind in equipment: where the equipment has been cleaned in accordance with best available techniques, fluorine-free foam newly in that equipment may carry up to 50 mg/L. It does not apply to portable fire extinguishers, and the Commission must review it no later than 23 October 2030.

The exclusions still count toward the sum#

Paragraph 2 takes three groups out of the prohibition, because other law already covers them: PFOS, PFOA and PFHxS and their related compounds under Annex I to the POP Regulation; the C9-C14 PFCAs restricted under Annex XVII entry 68; and PFHxA and its related substances for the uses restricted under entry 79.

Paragraph 3 then closes the obvious loophole: when you determine the concentration of the sum of all PFAS, those excluded substances are included in the determination. The exclusion is from the ban, not from the measurement.

Dates, by what they stop#

23 Oct 2025
In force
Entry 82 applies. Nothing is prohibited yet, but the clock starts.
23 Oct 2026
Portable extinguishers off the market
Placing PFAS-containing foam on the market in portable fire extinguishers ends. On the same date the conditions of use and the labelling duty below begin to apply.
23 Apr 2027
Training, public fire services, alcohol-resistant extinguishers
Use for training and testing ends, except functional testing of firefighting systems where all releases are contained. Use by public fire services ends, except when they intervene at industrial fires at Seveso establishments. Alcohol-resistant foam in portable extinguishers may no longer be placed on the market.
23 Oct 2030
The general ban
Placing on the market and use of PFAS in firefighting foams at or above 1 mg/L is prohibited, for everything not covered by a longer derogation.
31 Dec 2030
Use in portable extinguishers
Existing PFAS-containing portable fire extinguishers may no longer be used.
23 Oct 2035
The long derogations
The last uses end: establishments covered by the Seveso Directive (2012/18/EU) but not civilian aviation or civilian airports, offshore oil and gas installations, military vessels, and civilian ships with foam placed on board before 23 October 2025.
The general date is not your date

Paragraph 1 sets 23 October 2030, but paragraphs 5 and 6 give individual sectors their own end dates, and some of those fall earlier than 2030 rather than later. Portable fire extinguishers come off the market four years before the general date. Work from the derogation that names your sector.

What a user has to do from 23 October 2026#

Where use is still allowed, it is allowed on conditions. From 23 October 2026 the user must keep to class B fires (flammable liquids) only, reduce emissions and human exposure as far as is technically and practically possible, collect unused foam and PFAS-containing waste including wastewater separately for treatment that destroys or irreversibly transforms the PFAS, and hold a site-specific PFAS-containing firefighting foams management plan.

1Use conditions and volumes
What is on site, in what quantity, and how the emission-reduction duty is being met.
2Collection and treatment
How unused foam and PFAS-containing waste, wastewater included, are collected and adequately treated.
3Cleaning and maintenance
The type and methods used on the equipment.
4Spill plans
What happens on accidental leakage or spillage, with follow-up documented where relevant.
5Substitution strategy
The plan for moving to fluorine-free foams.

The plan is reviewed annually and kept available for inspection for at least 15 years.

From the same date, foam placed on the market at or above 1 mg/L (portable fire extinguishers excepted) and stocks of unused foam and PFAS-containing waste must be labelled with the wording the entry prescribes: "WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS", marked visibly, legibly and indelibly.

The September 2026 corrigendum

The corrigendum to entry 82 was published in the Official Journal on 8 September 2026 as OJ L, 2026/90757. It corrects two typographic errors in paragraph 2: the PFOS-related compounds formula reads C8F17SO2X, not C8F17SO3X, and a subscript in the C9-C14 PFCA formula was fixed. Neither changes the scope, the limits or any date.

The other track: C9-C21 PFCAs are becoming POPs#

Entry 82 is REACH. The longer perfluorocarboxylic acids are being dealt with under the POP Regulation instead, and that track moved in September 2026.

A Commission delegated regulation adopted on 7 September 2026 adds long-chain perfluorocarboxylic acids (C9-C21 PFCAs), their salts and related compounds to Part A of Annex I to Regulation (EU) 2019/1021, implementing Stockholm Convention decision SC-12/12. Annex I means prohibition, not restriction: manufacturing, placing on the market and use all stop, subject to the derogations in the entry. It applies from 16 December 2026.

Two consequences for reading entry 82

Paragraph 2 of entry 82 excludes the C9-C14 PFCAs from its prohibition on the ground that entry 68 of Annex XVII already restricts them. The Commission has said it will start the procedure to remove entry 68 now that the POP listing is adopted, so that cross reference is expected to change. Separately, the new POP entry sets its own trace limits for firefighting foam already installed in systems, which run to 3 August 2028 and sit alongside, not instead of, the entry 82 duties.

The scope definition, the trace contaminant limits and the semiconductor and article-in-use exemptions are set out on the POP Regulation page.

How this fits the rest of REACH#

Entry 82 is a restriction, so it applies to everyone in scope automatically. There is no application to file and no permission to obtain, unlike authorisation.

Caution

PFAS scope and timelines are moving fast. Treat this entry as orientation and track the official ECHA restriction process before making design or sourcing decisions.

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PFAS: Per- and Polyfluoroalkyl SubstancesPFASREACH: Registration, Evaluation, Authorisation and Restriction of ChemicalsREACHSVHC: Substance of Very High ConcernSVHCPOP: Persistent Organic Pollutants RegulationPOPRestriction (REACH)RestrictionF-Gas Regulation (EU) 2024/573F-Gas RegulationStockholm Convention on Persistent Organic PollutantsStockholm ConventionTSCA: Toxic Substances Control ActTSCAECHA: European Chemicals AgencyECHAPlacing on the MarketPlacing on the Market
PFASpersistentREACH restrictionPOPfirefighting foam