ECHA Releases Updated PFAS Restriction Dossier

On 20 August 2025 the European Chemicals Agency (ECHA) released the updated version of the Universal PFAS (UPFAS) Restriction dossier. The dossier alongside its associated annexes and appendices have been revised by the Dossier Submitters to reflect the unprecedented amount of information shared in the public consultation.

For stakeholders who contributed their data to the UPFAS Restriction, the revision represents a first look at how the Restriction has been influenced by their input.

Key changes to look out for in the revised document(s) are:

• inclusion of new use sectors (military applications, technical textiles, machinery applications, etc);
• a new restriction option (RO3) is considered where risks from PFAS are adequately controlled under other legislation;
• proportionality assessments of the restriction options for each end use (see Annex E); and
• updated derogations for each end use sector based on the strength of data submitted on alternatives.

For manufacturers, importers or users of PFAS (or PFAS based products), RPA recommends checking that your end use is accurately described, evidenced and concluded upon in the background document. A further public consultation will be announced after the SEAC opinion (which we estimate for Q1/2 of 2026) allowing for corrections and final amendments to be shared before the Commission decision.

Contact us to find out more about how you can prepare for the SEAC consultation or for clarity on the updated Restriction.