Per- and polyfluoroalkyl substances (PFAS) are often described as “forever chemicals” due to their persistence. Rising concerns over detrimental health effects and accumulation in the environment have led to tightening PFAS restrictions within the EU, culminating in a 2023 European Chemicals Agency (ECHA) proposal calling for a blanket ban on all PFAS.1
While it is uncertain when or in what form the ban will be passed, existing regulations limit the presence of selected PFAS compounds in various products and materials, including food, drinking water, packaging, cosmetics, and consumer goods. These restrictions are summarized below, along with recommendations for compliance testing.
Table of contents
PFAS restrictions under the EU POP Regulation
The use of specific, demonstrably highly toxic PFAS compounds has been restricted both globally and within the EU for over a decade. Global restrictions are specified in the Stockholm Convention on Persistent Organic Pollutants (POPs), which is implemented in the EU through the POP Regulation (EU) 2019/1021. PFAS compounds prohibited under POP legislation include the following:
Perfluorooctane sulfonic acid (PFOS) and its derivatives.
Perfluorooctanoic acid (PFOA), its salts, and related compounds.
Perfluorohexane sulfonic acid (PFHxS), its salts, and related compounds.
The upper limits for unintentional trace contamination are 10 ppm for PFOS, 1 ppm for PFOA- and PFHxS-related compounds, and 25 ppb for PFOA, PFHxS, and their salts. Temporary exemptions – many of which are about to expire in 2025 or 2026 – have been granted for specific products where these compounds are difficult to replace, such as firefighting foams and medical devices.2 Apart from the very limited array of exempted applications, PFOS, PFOA, PFHxS, and related substances should not be used in any product or material within the EU.
REACH Regulation restrictions on PFAS
Several groups of PFAS are included in the REACH Regulation Candidate List of substances of very high concern (SVHC). As a general rule, listed chemicals should not be present in products or materials in concentrations above 0.1% by weight. If higher concentrations are detected, the producer or importer has to notify ECHA and provide customers with sufficient information on the safe use of the product.
PFAS compounds on the SVHC list include the following:3
PFOA, PFHxS and its salts
Perfluoroheptanoic acid (PFHpA) and its salts
Perfluorobutane sulfonic acid (PFBS) and its salts
Nonadecafluorodecanoic acid (PFDA), also known as perfluorodecanoic acid, and its sodium and ammonium salts
Perfluorononan-1-oic-acid and its sodium and ammonium salts
Perfluamine
Ammonium pentadecafluorooctanoate (APFO), also known as perfluorooctanoic acid, ammonium salt
Pentacosafluorotridecanoic acid, also known as perfluorotridecanoic acid (PFTrDA)
Tricosafluorododecanoic acid, also known as perfluorododecanoic acid (PFDoDA)
Heptacosafluorotetradecanoic acid, also known as perfluorotetradecanoic acid (PFTDA)
Henicosafluoroundecanoic acid, also known as perfluoroundecanoic acid (PFUnDA)
2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts, and its acyl halides (HFPO-DA)
All the listed compounds are included in Measurlabs’ SVHC analysis package, which is suitable for a wide range of products and chemicals.
In addition, some PFAS compounds are restricted under Annex XVII to the REACH Regulation and must not be placed on the market on their own or as constituents in mixtures or articles. These include undecafluorohexanoic acid (PFHxA) and C9-C14 linear and/or branched perfluorocarboxylic acids (C9-C14 PFCAs), along with their salts and related substances.4
Maximum PFAS concentrations in food
Commission Regulation (EU) 2023/915 on food contaminants sets maximum concentrations for high-profile PFAS in food. The limits apply to four compounds (PFOS, PFOA, PFNA, and PFHxS) and their sum in certain high-risk food categories.5 If higher concentrations than those listed in Table 1 are discovered in laboratory tests, the product has to be removed from the market.
Table 1: Maximum levels of PFAS per food category
Foodstuff | PFOS, μg/kg | PFOA, μg/kg | PFNA, μg/kg | PFHxS, μg/kg | Sum of the 4 PFAS, μg/kg |
Eggs | 1 | 0.3 | 0.7 | 0.3 | 1.7 |
Anchovy, babel, bream, char, eel, pike-perch, perch, roach, smelt, and whitefish | 35 | 8 | 8 | 1.5 | 45 |
Baltic herring, bonito, burbot, pike, plaice, sardine, seabass, wild salmon and trout, etc.* | 7 | 1 | 2.5 | 0.2 | 8 |
Other species of fish & all fish intended for young children | 2 | 0.2 | 0.5 | 0.2 | 2 |
Crustaceans and molluscs | 3 | 0.7 | 1 | 1.5 | 5 |
Meat of bovines, pigs, and poultry | 0.3 | 0.8 | 0.2 | 0.2 | 1.3 |
Meat of sheep | 1 | 0.2 | 0.2 | 0.2 | 1.6 |
Offal of sheep, pigs, poultry, and bovine animals | 6 | 0.7 | 0.4 | 0.5 | 8 |
Meat of game animals | 5 | 3.5 | 1.5 | 0.6 | 9 |
Offal of game animals | 50 | 25 | 45 | 3 | 50 |
* In addition to these, the category covers European sprat, flounder, grey mullet, horse mackerel, pilchard, sea catfish, sea lamprey, tench, vendace, silverly lightfish, and wolf fish.
Measurlabs offers an EU compliance package for PFAS analysis of food samples. An extended analysis covering a larger set of compounds is also available.
Restrictions under the Drinking Water Directive
The revised EU Drinking Water Directive specifies two ways in which PFAS concentrations can be measured. These are:
PFAS Total, defined as "the totality of per- and polyfluoroalkyl substances". The maximum for this parameter is 0.5 μg per liter.
Sum of PFAS, calculated as the sum of 20 individual substances listed in Annex III of the Directive. The sum must not exceed 0.1 μg per liter.6
Technical guidelines for analysis methods are specified in Commission Notice C/2024/4910, which recommends following the EN 17892 standard to measure the sum of PFAS in drinking water. Other methods can be used if they meet equivalent performance criteria.7
PFAS restrictions under EU cosmetics legislation
Several PFAS compounds are listed as prohibited substances in the consolidated version of Regulation (EC) 1223/2009 on cosmetic products. If any of these substances are found, even in trace quantities, the manufacturer has to prove that their presence is technically unavoidable. Otherwise, the product may not be sold in the EU.
Prohibited substances include:8
Perfluorooctane sulfonic acid (PFOS)
Ammonium pentadecafluorooctanoate (APFO)
Perfluorooctanoic acid (PFOA)
Perfluorodecanoic acid (PFDA)
Perfluorononanoic acid (PFNA), its sodium, and its ammonium salts
Perfluoroheptanoic acid (PFHpA)
It should be noted that PFAS restrictions outlined in the POP and REACH regulations also apply to cosmetics. During a recent enforcement project, ECHA found over 150 cosmetic products that contained prohibited PFAS compounds, such as perfluorononyl dimethicone, which is a PFOA-related substance and thus restricted under both POP and REACH.9
Prohibition of PFAS in food packaging
The EU Packaging and Packaging Waste Regulation (PPWR) introduces a full ban on PFAS in food contact materials from August 12th, 2026. By that date, manufacturers will have to ensure that PFAS are not present in food packaging in concentrations exceeding the following limits:10
25 ppb for any compound measured with targeted PFAS analysis
250 ppb for the sum of PFAS measured with targeted analysis
50 ppm for total fluorine, unless it can be shown the fluorine is derived from non-PFAS sources
Testing to assess regulatory compliance
Measurlabs offers a comprehensive range of PFAS testing services to evaluate compliance with EU regulations. Standard methods are available for many of the most typical sample matrices, such as paper, plastics, firefighting foams, drinking water, and environmental samples. Other sample types can be analyzed with specialized in-house methods, and we can also provide total organic fluorine (TOF) testing to estimate the overall presence of PFAS in various materials. Do not hesitate to ask our experts for more information or a quote using the form below.
References:
1 See ECHA’s PFAS landing page for the newest updates regarding the proposed universal ban.
2 More details on the specifications of PFAS restrictions under the POP Regulation, including the expiry of derogations, can be found in Annex I to Regulation (EU) 2019/1021.
3 Candidate List of substances of very high concern for Authorisation on the ECHA website, accessed on 12/3/2025.
4 Substances restricted under Annex XVII to REACH are listed on the ECHA website, along with the detailed conditions of each restriction, including exemptions and derogations.
5 Maximum levels for certain perfluoroalkyl substances are listed in Annex I to Regulation (EU) 2023/915 (consolidated version from 1/1/2025)
6 The maximum concentrations for PFAS Total and Sum of PFAS are listed in Part B of Annex I to Directive (EU) 2020/2184.
7 Commission Notice C/2024/4910: Technical guidelines regarding methods of analysis for monitoring of per- and polyfluoroalkyl substances (PFAS) in water intended for human consumption
8 Annex II to Regulation (EC) No 1223/2009 on cosmetic products (consolidated version from 24/4/2024) lists prohibited substances. Reference numbers include 1493 for PFOS and related compounds, 1560 for APFO, 1561 for PFOA, 1604 for PFDA, 1636 for PFNA, and 1705 for PFHpA.
9 ECHA: Pilot project report on the enforcement of restrictions of PFCAs and related substances focusing on cosmetics, 25 October 2024
10 The restrictions are listed in Article 5, Paragraph 5. of Regulation (EU) 2025/40 on packaging and packaging waste.