RAC Adopts Opinion on Proposed REACH Restriction Proposal for PFAS, ECHA Will Publish Opinion “Soon”

The European Chemicals Agency (ECHA) announced on March 3, 2026, that its Risk Assessment Committee (RAC) has concluded its evaluation of the proposal to restrict per- and polyfluoroalkyl substances (PFAS) under the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation. ECHA notes that RAC drew on “an extensive and independent evaluation of PFAS hazards, volumes, emissions, risks and the likely effectiveness of a restriction as well as its practicality, including enforceability.” According to ECHA, RAC’s evaluation is based on the proposal submitted in January 2023 by the national authorities of the Netherlands, Germany, Denmark, Norway, and Sweden.

The RAC opinion is the first part of ECHA’s two-committee scientific evaluation of the proposal. RAC evaluates risks to human health and the environment resulting from the manufacture, placing on the market, and use of chemicals, while ECHA’s Socio-Economic Analysis Committee (SEAC) evaluates the socio-economic impacts of a restriction, taking into account the availability of alternatives. ECHA states that it will publish RAC’s opinion “soon, providing full details of the opinion content.” According to ECHA, SEAC is expected to agree its draft opinion during the week of March 9, 2026. There will be a 60-day public consultation on the draft SEAC opinion. ECHA states that SEAC is expected to adopt its final opinion by the end of 2026. ECHA will then formally submit the final RAC and SEAC opinions to the European Commission (EC). The EC will propose a restriction for discussion and vote in the REACH Committee, composed of EU member states, based on the RAC and SEAC opinions.

As reported in our December 22, 2025, blog item, ECHA published a December 2025 “Consultation on the SEAC draft opinion on restricting per- and polyfluoroalkyl substances (PFAS) — Guidance for respondents.” ECHA designed the guidance to help respondents prepare for the consultation and to understand what information is requested. The consultation will be carried out through the EUSurvey tool and consists of two types of surveys with different sets of questions: sector-specific surveys: focusing on the sector-specific evaluations in the SEAC draft opinion; and general survey: covering the sections of the SEAC draft opinion that apply to all sectors.