PFAS Restriction: Public Consultation Launched on the SEAC Draft Opinion

Dear Clients,

We would like to inform you that on 26 March 2026, ECHA launched the public consultation on the SEAC draft opinion (Committee for Socio-Economic Analysis) concerning the proposed restriction on PFAS. The consultation will remain open until 25 May 2026.

This is an important stage in the REACH process. Following the publication of the PFAS restriction dossier in March 2023 and the first public consultation, which closed in September 2023, ECHA’s two scientific committees continued their evaluation of the proposal. The RAC (Committee for Risk Assessment) adopted its final opinion on 2 March 2026, while SEAC agreed on its draft opinion on 10 March 2026, which has now been submitted for public consultation. At the end of this phase, SEAC will assess the contributions received and is expected to adopt its final opinion by the end of 2026. Subsequently, the RAC and SEAC opinions will be transmitted to the European Commission, which will prepare the legislative proposal to be discussed and voted on by the REACH Committee.

It is important to emphasize that we are no longer in the phase of general discussion on the restriction, but rather in a much more targeted phase. The current consultation concerns exclusively the SEAC draft opinion and therefore focuses on socio-economic aspects, the availability of alternatives, and their technical and economic feasibility. Comments relating to hazards, emissions and risks will not be considered in this consultation, as these aspects are already covered by the adopted RAC opinion.

The consultation includes several sector-specific questions, dedicated to the sectors specifically assessed by SEAC. For stakeholders who have detailed data on one of the sectors assessed, ECHA expressly recommends using the relevant survey, as this allows the Committee to verify or update its conclusions in a targeted manner.

For companies, this consultation is therefore particularly relevant: it is the appropriate time to provide ECHA with concrete data on required performance, the absence or inadequacy of alternatives, industrial qualification timelines, conversion costs, customer impacts, and specific technical challenges.

Focus on the chrome plating and metal plating sector
For the metal plating and manufacture of metal products sector, SEAC distinguishes between hard chrome plating (functional hard chrome plating), decorative chrome plating, and other applications. In the official mapping of the consultation, chrome plating falls within sector 04 and includes the use of PFAS as wetting agents and mist/fume suppressants in electroplating baths.

For hard/functional chrome plating, SEAC considers that there is sufficiently strong evidence of a low substitution potential at the entry into force of the restriction, as many PFAS-free alternatives are still under development or have not yet been adequately tested and proven suitable for use by downstream users. For this reason, SEAC concludes that an immediate ban would not be proportionate and considers a 5-year derogation, following the general 18-month transitional period, to be necessary.

For decorative chrome plating, by contrast, SEAC considers that alternatives are widely available and feasible, with a high substitution potential, and therefore concludes that a specific derogation is not justified.

From a risk perspective, RAC confirms that in the electroplating sector PFAS are used mainly to reduce surface tension and as mist suppressants to limit the formation of Cr(VI) aerosols in chrome plating baths. RAC also notes that the available literature supports the presence of significant PFAS emissions from the chrome plating sector and concludes that the operational conditions, risk management measures, and the existing regulatory framework are not sufficient to adequately control emissions in this sector.

Given the significance of the PFAS dossier and its potential impact on numerous industrial sectors, we recommend that affected companies carefully assess their position and, where appropriate, prepare a well-supported technical contribution within the established deadlines.

We remain available to support you:

• in analysing your position with respect to the proposed restriction;
• in identifying the most appropriate survey;
• in preparing technical and socio-economic comments to be submitted as part of the consultation.