PFAS regulations in the EU: overview of restrictions and compliance testing

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 regulations within the EU, culminating in a 2023 proposal by the national chemicals authorities of the Netherlands, Germany, Denmark, Norway, and Sweden calling for a blanket ban on virtually all PFAS.

In March 2026, the European Chemicals Agency (ECHA) declared its support for the broad PFAS restriction. However, the agency proposes numerous targeted derogations to ensure that companies have time to develop alternatives to PFAS in industries where they are still widely used.¹ If the restriction moves forward as expected, it will eventually be incorporated into Annex XVII of the REACH Regulation.

While the timing and final form of the broad PFAS ban remain uncertain, existing regulations limit the presence of certain 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.

PFAS restrictions under the EU POP Regulation

The use of certain, 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: 

• Perfluorooctane sulfonic acid (PFOS), its salts, and related compounds. 

• 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 0.025 mg/kg (25 ppb) for PFOS, PFOA, PFHxS, and any of their salts, and 1 mg/kg (1 ppm) for related compounds. Derogations were previously granted to several product groups, such as firefighting foams and medical devices, in which replacing these compounds was technically difficult. Most of the derogations have now expired, which means that PFOS, PFOA, PFHxS, and related substances must not be used to manufacture any products or materials for the EU market, apart from the very limited array of remaining derogations.²

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. While SVHC presence in excess of this threshold does not make the product illegal, it does trigger notification and information requirements that most manufacturers would rather avoid. Absence of SVHCs is also commonly expected by downstream customers and ecolabeling organizations.

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:⁴

• C9-C14 linear and/or branched perfluorocarboxylic acids (C9-C14 PFCAs) must not be placed on the market on their own or as constituents in mixtures or articles. The ban took effect in 2023, and derogations granted to firefighting foams and certain coatings and medical devices expired in July 2025. Compliance testing limits are 25 ppb for the sum of C9-C14 PFCAs and their salts, and 260 ppb for the sum of related substances.

• Undecafluorohexanoic acid (PFHxA), its salts and related substances are banned from October 10, 2026, in several product groups, including clothing, footwear, cosmetics, and paper and cardboard used as food contact materials. The restriction also applies to firefighting foams, with the effective date depending on the context where the product is used. Maximum limits are 25 ppb for PFHxA and its salts, and 1,000 ppb for the sum of related substances.

• PFAS will be banned in firefighting foams from 23 October 2030. For the purpose of this restriction, the sum of all PFAS must not reach or exceed 1 mg/L.

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 must not be placed on the market.

Measurlabs offers an EU compliance package for PFAS analysis of food samples. An extended analysis covering a larger set of compounds is also available.

Prohibition of PFAS in food packaging

The EU Packaging and Packaging Waste Regulation (PPWR) prohibits PFAS in food contact packaging from August 12, 2026. Manufacturers have to ensure that PFAS are not present in concentrations at or above the following limits:⁶

• 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 that the fluorine originates from non-PFAS sources

According to a Commission guidance document on the application of the PPWR, the following stepwise approach can be applied to compliance testing:⁷

1. First, a total fluorine (TF) analysis is conducted. If TF content does not exceed 50 ppm, the material can be considered compliant, and further testing is not needed.

2. If the fluorine content is higher, inorganic and organic fluorine are differentiated with a method such as py-GC/MS. If the total organic fluorine (TOF) content is less than 50 ppm, the material can be considered compliant, and further testing is not required.

3. If PFAS presence is not ruled out after these two steps, a direct total oxidizable precursor (TOP) analysis is recommended for checking compliance with the 25 ppb and 250 ppb limits for individual PFAS and the sum of PFAS, respectively.

Restriction under the Drinking Water Directive

The revised EU Drinking Water Directive requires Member States to monitor PFAS concentrations from January 2026 and ensure the set limit values are not exceeded. Monitoring can focus on one or both of the following parameters:

• 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 to the Directive. The sum must not exceed 0.1 µg per liter.⁸

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.⁹

Monitoring obligation under the Urban Wastewater Treatment Directive

The Urban Wastewater Treatment Directive (EU) 2024/3019 requires competent authorities to monitor PFAS levels at the inlets and outlets of large treatment plants that discharge water into drinking water catchment areas. The parameters to be monitored are the same as those for drinking water, i.e., PFAS Total and/or Sum of PFAS, but no limits are currently set for wastewater. Official analysis methods tailored to wastewater samples are set to be established through implementing acts by January 2, 2027.¹⁰

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 and that the product remains safe. Otherwise, the product may not be sold in the EU.¹¹

Prohibited substances include:

• Perfluorooctane sulfonic acid (PFOS)

• Ammonium pentadecafluorooctanoate (APFO)

• Perfluorooctanoic acid (PFOA)

• Perfluorodecanoic acid (PFDA) and its sodium and ammonium salts

• Perfluorononanoic acid (PFNA) and its sodium and ammonium salts

• Perfluoroheptanoic acid (PFHpA)

It should be noted that PFAS restrictions specified in the POP and REACH regulations also apply to cosmetics. In a 2023–2024 EU enforcement project, authorities found over 150 cosmetic products that contained prohibited PFAS compounds. The most common finding was perfluorononyl dimethicone, which is a PFOA-related substance and thus restricted under both POP and REACH.¹²

French ban on PFAS in selected products

While the universal EU-level PFAS restriction is still being evaluated by ECHA's scientific committees, France recently adopted one of the most extensive national bans within the union. Law No. 2025-188 bans PFAS-containing products in the following product groups from January 2026:¹³

• Clothing and footwear

• Ski wax

• Cosmetics

• Waterproofing agents

There are certain exemptions, including technical textiles for industrial use, personal protective equipment (PPE), and clothing and footwear that contain at least 20% of recycled material.

The compliance criteria, set in Decree No. 2025-1376, largely mirror those outlined in the PPWR: 25 ppb for individual compounds, 250 ppb for the sum of target PFAS, and 50 ppm for total fluorine from PFAS sources.

Testing to assess regulatory compliance

Measurlabs offers a comprehensive selection of PFAS testing services to evaluate compliance with EU and national regulations. Standard methods are available for 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 also provide total fluorine (TF) and 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.