PFAS rules, packaging bans, UK plans – what is changing and when

PFAS restriction and ECHA timetable

European Chemicals Agency scientific committees remain on schedule to deliver opinions on the proposed Per- and Polyfluorinated Substances (PFAS) restriction.

An ESG and Sustainability Law and Policy blog published by Squire Patton Boggs reports that the European Chemicals Agency (ECHA) confirmed on 17 December that its Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) remain on track.

December meetings enabled the adoption of provisional conclusions for the final sectors under assessment, including PFAS manufacturing.

Further meetings scheduled for March 2026 are expected to lead to the adoption of draft opinions.

Following this stage, SEAC will proceed with a 60 day public consultation under the REACH process.

Ahead of the consultation, ECHA has published guidance for respondents and a detailed mapping of PFAS uses identifying the sectors, uses and applications covered by the forthcoming SEAC draft opinion.

The committees have also continued examining horizontal issues relevant to the restriction as a whole, including concentration limits, PFAS management plans, recycling and spare parts, and questions of enforceability and monitorability.

Once both opinions are finalised, ECHA is expected to consolidate them and submit its final package to the European Commission towards the end of 2026.

PFAS packaging ban and national measures

The same blog outlines upcoming EU packaging restrictions alongside developments in France and the UK.

Under Article 5 of the Packaging and Packaging Waste Regulation (PPWR), the use of per and polyfluoroalkyl substances (PFAS) in food contact packaging above specified thresholds will be prohibited once the relevant provisions apply on 12 August 2026.

The European Commission is preparing a Commission Notice intended to support consistent implementation and interpretation of the regulation, including the PFAS restriction.

A leaked version of the Notice clarifies that the ban applies to packaging placed on the market from the date of application, covers both intentional use and non intentional presence such as contamination, and addresses the treatment of existing stocks.

The document also clarifies that no transitional period applies, meaning the prohibition applies regardless of whether PFAS are intentionally added or present as contaminants.

In France, more than 30 local authorities affected by PFAS contamination have called on the national government and Parliament for support.

A joint statement published on 16 December and coordinated by Amaris, the association representing local authorities dealing with industrial pollution and risk management, highlights limits in technical knowledge and financial resources at municipal level.

The statement calls for the establishment of a parliamentary inquiry committee to assess the extent of PFAS pollution and the challenges it creates for local authorities.

Pending such an inquiry, the proposed measures include financial support for municipalities facing restrictions on access to drinking water, full public funding of groundwater and soil remediation, expanded scientific studies, and the deployment of monitoring tools for water, air, soil and public health.

In the United Kingdom, the Environmental Improvement Plan released on 1 December 2025 includes a commitment to take action on PFAS through a new PFAS plan in 2026.

The plan is expected to set out regulatory and non regulatory interventions with specific actions and delivery milestones.

The Environment Agency (EA) is due to provide advice, guidance and tools to support the management of PFAS at contaminated sites on an ongoing basis.

A separate commitment under the plan includes publication in 2026 of a State of Contaminated Land Report.

In 2027, the Department for Environment, Food and Rural Affairs (Defra), the EA and the Health and Safety Executive (HSE) are due to decide whether to implement a UK REACH restriction on PFAS in firefighting foams.

The HSE consultation on this issue remains open until 18 February 2026.

All information for this article is from a blog authored by Thomas Delille, Gerard McElwee, Peter Sellar, Valerio Giovannini and Francesca Puttock.