Public Consultation on the EU's Universal PFAS Restriction to Open Shortly - Preparation Strongly Recommended

The European Chemicals Agency’s (ECHA) Committee for Socio-Economic Analysis (SEAC) is expected to agree on its draft opinion on restricting per- and polyfluoroalkyl substances (PFAS) in the first half of March 2026. The draft opinion will be published shortly afterward, marking the start of the public consultation as well. The consultation will run for 60 calendar days, until approximately mid-May 2026. This consultation will represent the final opportunity for stakeholders to submit comments before the ECHA forwards its restriction proposal to the European Commission, currently planned for late 2026.

The consultation will be conducted via EUSurvey, the Commission’s official survey platform, accessible through the ECHA website using an EU Login account. Two surveys will be available:

• a sector-specific survey, with both single, multiple choice and free text responses, addressing SEAC’s evaluations of particular sectors and touching upon, for example,the specific use cases of PFAS in products, statistical data on the use of PFAS, the availability of alternatives and the magnitude of potential negative impacts of a ban to society; and
• a general survey, allowing free text comments on any aspect of the draft opinion or any PFAS uses, even if not specifically evaluated by the SEAC.

In December 2025, the ECHA published a brief guidance document, as well as draft consultation questions in the form of two tables.

Given the limited 60-day time frame and the substantial effort required to collect data and prepare concise responses to complex questions, stakeholders (e.g., companies, industry associations) are advised to prepare in advance.

Companies active in multiple sectors may need to complete several sector-specific questionnaires, increasing the administrative burden of staff working on different fields. Stakeholders should therefore consult the ECHA’s mapping of PFAS uses to identify the relevant evaluation levels and begin compiling supporting data.

Trade Associations and consortia also can respond to the survey, which means that they will need to consolidate input from their members first.

As the structure of the consultation questions is already known and the SEAC’s approach can be inferred from previous PFAS restriction opinions, meaningful preparatory work can be undertaken.

How Can We Help?  

Mayer Brown’s EU Regulatory practice has extensive experience advising a broad range of companies and trade associations in connection with the universal PFAS restriction process, REACH and other chemicals legislation and products legislation. We help our clients prepare for legislative changes, ensuring that they keep up to date with regulatory developments and meet the challenges posed by an ever-shifting regulatory environment.

Our team stand ready to assist companies, consortia and trade associations preparing their comments on the SEAC opinion, using our legal and regulatory expertise and also by collecting confidential input from consortium and association members and aggregating such input on a no name basis. .