PMT/vPvM Regulation
On December 19, 2022, the European Commission published a proposal for the revision of Regulation (EC) No 1272/2008 on classification, labeling and packaging of chemicals and mixtures (CLP). This revision aims to define scientific and technical criteria to classify substances and mixtures which would present PMT and vPvM properties.
Following the examination of the proposed revision text by the European Parliament and Council, these classifications could come into force in 2023, with a transition period of between 2 and 5 years depending on whether the substance is new, a mixture or already on the market.
The European ZeroPM project, a H2020 project like the Promisces project, provides a regulatory watch indicating the upcoming deadlines for PMT regulations.
PFAS Regulation
United Nations Stockholm Convention
Perfluorooctanoic acid (PFOA), perfluorohexane sulfonic acid (PFHxS), perfluorooctane sulfonic acid (PFOS), their salts and derivatives belong to the list of substances targeted by the Stockholm International Convention on Persistent Organic Pollutants.
Members to this convention are required to:
- prohibit the production, use, import and export of PFOA, PFHxS, their salts and derivatives ;
- limit the production and use of PFOS, its salts and derivatives and PFOSF.
This legislation is implemented in the European Union by the POP Regulation.
In May 2025, it was decided to include the group of long-chain perfluorocarboxylic acids (C9–C21) and related compounds in Annex A of the Stockholm Convention (with specific exemptions), thereby prohibiting their production, use, and import (decision SC-12/12).
European Union POP Regulation
PFOA, PFHxS, and PFOS, as well as their salts and related compounds, are listed in Annex I of the EU POP Regulation. Consequently, their concentration must not exceed certain thresholds:
- 10 mg/kg (0.001% by weight) for PFOS in substances or mixtures;
- 0.025 mg/kg for PFOA or its salts and 1 mg/kg for its related compounds¹ in substances, mixtures, or articles;
- 0.025 mg/kg for PFHxS and its salts and 1 mg/kg for its related compounds in substances, mixtures, or articles.
Regulation (EU) 2022/2400 of the European Parliament and of the Council of 23 November 2022 makes the following amendments to POP Regulation in waste management:
- Concentration limit in waste of 1 mg/kg for PFOA and its salts and 40 mg/kg for the sum of PFOA-related compounds
- Concentration limit in waste of 1 mg/kg for PFHxS and its salts and 40 mg/kg for the sum of PFHxS-related compounds
This Regulation will apply on 10 June 2023, however, the Commission shall review that concentration limit and shall, where appropriate, adopt a legislative proposal to lower that value, where such lowering is feasible in accordance with scientific and technical progress, no later than 30 December 2027.
¹ Different thresholds apply to certain firefighting foams.
European Union REACH Regulation
Restriction procedures
As stricter restrictions are foreseen in the POP Regulation for PFOA, PFOS and their related substances (including its salts and polymers), these replace the restrictions originally defined for these substances in REACH in Annex XVII.
The manufacture and placing on the market of C9-C14 PFCAs, their salts and related substances as substances are prohibited. Their use or placing on the market is also prohibited when they are present in another substance (as a constituent), in a mixture, or in an article (textiles, high‑performance filter membranes, sealing products, etc.), unless the total concentration of C9-C14 PFCA and their salts is below 25 ppm, or the total concentration of C9-C14 PFCA‑related substances is below 260 ppm.
On 19 September 2024, the European Commission adopted a restriction on the use of undecafluorohexanoic acid (PFHxA), its salts and related substances for the production of textile articles, leather, fur, footwear and accessories, paper or cardboard food packaging, various mixtures (such as waterproofing sprays), cosmetics and firefighting foams (including foams used for training and testing, for public services and for civil aviation). This restriction will apply after transitional periods ranging from 18 months to 5 years, depending on the use.
As of 23 October 2030, firefighting foams with a total PFAS concentration greater than 1 mg/L may no longer be placed on the market or used (specific transitional periods are defined for each use). This restriction specifically targets PFAS other than PFOS, PFOA, PFHxS, PFHxA, and C9-C14 PFCA, as these substances are already regulated. However, when determining the concentration of the sum of all PFAS, these substances are included in the calculation.
On 7 February 2023, ECHA published a restriction proposal targeting the manufacture, placing on the market and use of PFAS. This restriction proposal was submitted on 13 January 2023 by the authorities of Denmark, Germany, the Netherlands, Norway and Sweden. It concerns any substance containing at least one fully fluorinated methyl (CF₃–) or methylene (–CF₂–) carbon atom (with no hydrogen, chlorine, bromine or iodine atoms attached to the group).
Authorisation procedures
Several per‑ and polyfluoroalkyl substances have been identified by the Member State Committee as SVHC (Substances of Very High Concern, candidates for inclusion on the authorisation list). A non‑exhaustive list includes: perfluorohexane‑1‑sulfonic acid (PFHxS), its salts and related substances; perfluorobutane sulfonic acid and its salts (PFBS); nonadecafluorodecanoic acid and its ammonium and sodium salts (PFDA); perfluorononan‑1‑oic acid and its ammonium and sodium salts (PFNA); PFOA; ammonium pentadecafluorooctanoate (APFO); tricosafluorododecanoic acid (PFDoDA); pentacosafluorotridecanoic acid (PFTrDA); heptacosafluorotetradecanoic acid (PFTDA); henicosafluoroundecanoic acid (PFUnDA); perfluoroheptanoic acid and its salts; and the reaction mass of octafluoro‑4‑(1,1,1,2,3,3,3‑heptafluoropropan‑2‑yl)morpholine and octafluoro‑4‑(heptafluoropropyl)morpholine.
As a reminder, SVHC are included on a list managed by ECHA, also known as the "Candidate List", because they are candidates for in-depth examination, with a view to their possible inclusion on the list of substances whose use will be subject to authorisation (Annex XIV) in order to market them in the European Union (for the uses covered by the REACH regulation).
OSPAR Convention
PFOS is on the OSPAR Convention's list of chemicals for priority action. The OSPAR Convention is the mechanism by which sixteen governments2 and the European Union cooperate to protect the marine environment of the North-East Atlantic.
OSPAR is conducting a comprehensive review of all substances on this list to identify substances to which the obligations of the Hazardous Substances Strategy should apply, but which are not adequately covered by the EU framework or another international forum.
2 Belgium, Denmark, Finland, France, Germany, Iceland, Ireland, the Netherlands, Norway, Portugal, Spain, Sweden, the United Kingdom, Northern Ireland, Luxembourg and Switzerland.
Water Framework Directive
Priority hazardous substances
PFOS and its derivatives belong to the list of priority hazardous substances in Annex X of the Water Framework Directive for which discharges, emissions and losses must be phased out.
Water monitoring in France
In France, the monitoring of PFAS in surface water and groundwater is governed by national regulations. This monitoring is based on the amended decree of 25 January 2010 (in French) defining the French programme for monitoring the chemical status of surface water and groundwater, with measures specific to France.
This text includes the PFOS for surface water monitoring and a list of 20 PFAS for regular groundwater monitoring.
In addition, the regulation defines a list of relevant substances to be monitored specifically in French surface waters, including several PFAS, to improve knowledge of environmental contamination.
The French system also distinguishes between different levels of analysis (regular, intermediate and photographic) for groundwater, with a dedicated list of PFAS monitored as part of the photographic analysis.
Finally, diflufenicanil is recognised in France as a specific pollutant of ecological status and is used as such for the assessment of the ecological quality of surface water.
Drinking water
Member States must take the necessary measures to ensure that water intended for human consumption complies with the following thresholds established for PFAS by the European Directive 2020/2184:
- 0.5 µg/l for the parameter "Total PFAS "3
- 0.1 µg/l for the parameter "Sum of 20 PFAS "4
In accordance with Decision No. 2025-1287, as of 1 January 2027, two additional PFAS will be included in the list of 20 PFAS: 6:2 fluorotelomer sulfonic acid (6:2 FTSA) and trifluoroacetic acid (TFA). It should be noted that from 1 January 2023, any exceedance of this new quality limit must already be considered.
3 "Total PFAS": Total per- and polyfluorinated alkyl substances
4 ‘Sum of 20 PFAS’: sum of the 20 PFAS monitored regularly in groundwater, namely PFBA, PFPeA, PFHxA, PFHpA, PFOA, PFNA, PFDA, PFUnDA, PFDoDA, PFBS, PFHxS, PFOS, PFNS, PFDS, PFHpS, PFPeS, PFTrDA, PFTrDS, PFDoDS, PFUnDS
European Sector Directives
Plant protection products
Nearly fifty substances belonging to the PFAS family due to their chemical structure are identified as active substances under Regulation (EC) No 1107/2009 concerning the placing of plant protection products on the market.
Some PFAS may also be used as co-formulants in plant protection products. PFAS are not currently included in the list of co-formulants that are prohibited from being used in plant protection products.
Biocides
In France, as in all other Member States of the European Union, the use of active substances and biocidal products is subject to Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products. Seven substances belonging to the PFAS family approved under this regulation have been identified: hexaflumuron, chlorfenapyr, bifenthrin, fipronil, flocoumafen, lambda-cyhalothrin, and tralopyril.
National sectoral regulations
Cosmetics, clothing textiles, and ski waxes
In 2025, France enacted a law prohibiting (in French), as of 1 January 2026, the manufacture, import, export, and placing on the market of the following products containing PFAS:
- cosmetics;
- ski waxes (ski base coatings);
- clothing, footwear, and their waterproofing treatments (except for protective clothing and footwear, such as those used by the military or firefighters).
As of 2030, all textiles (for example, furnishing textiles) containing PFAS will be prohibited in France (with exceptions, such as technical textiles for industrial use, which will be listed by decree).