In Europe, PFAS are shifting from “performance tool” to “regulatory liability.” Therefore, if you sell in the EU—or export into EU distribution—you need an EU-specific plan: map PFAS entry points in your BOM, lock supplier declarations with change-control, and build a defensible evidence file for audits, retailers, and B2B customers.
Important: Keep your general PFAS overview (what PFAS are, broad alternatives, and full screening logic) on your PFAS pillar page. This post is EU-only: legal tracks, EU deadlines, and EU documentation strategy.
EU PFAS controls: the four tracks that matter
PFAS action in the EU is not one single “ban date.” Instead, it comes through multiple legal tracks that can hit portfolios at different times. Consequently, your compliance plan must follow the earliest binding rule for your market mix.
Track 1 — EU-wide PFAS class restriction (REACH / ECHA process)
ECHA is evaluating a broad PFAS restriction proposal under REACH. In practice, this is the track that pushes a class-based approach where “swap PFAS A for PFAS B” is not sustainable. The scientific evaluation continues through 2026, including consultation on draft opinions and the committees’ final opinion work through the end of 2026.
Track 2 — Existing REACH Annex XVII restrictions (already in force for certain PFAS groups)
Even before the full class restriction lands, some PFAS families are already restricted under REACH Annex XVII. Therefore, EU portfolio reviews should check whether legacy raw materials intersect with existing restriction entries (and whether your suppliers have updated statements accordingly).
Track 3 — POPs Regulation controls (PFOS/PFOA and related entries)
The EU also controls certain PFAS via the Persistent Organic Pollutants (POPs) framework. Moreover, the EU has tightened contaminant thresholds over time, which matters when you are assessing impurities, trace contamination risk, and documentation standards for “PFAS-free” positioning.
Track 4 — National acceleration (France sets an early hard deadline)
France enacted a PFAS law that bans PFAS in cosmetics starting January 1, 2026. Accordingly, if France is in your EU footprint, plan to that date as your earliest binding deadline—then harmonize the rest of your EU rollout around it.
EU comparison table
| EU track | What it is | How it hits cosmetics | What you do now |
|---|---|---|---|
| REACH / ECHA PFAS class restriction | EU-wide restriction proposal covering a broad PFAS class under REACH evaluation. | Drives class-based phase-out thinking; affects “intentionally added PFAS” strategies and exemptions debates. | Build the BOM risk register, lock supplier PFAS statements + change-control, and create a reformulation roadmap that does not rely on PFAS-to-PFAS substitution. |
| REACH Annex XVII (existing restrictions) | Restrictions already listed under Annex XVII for certain PFAS families/substances. | Can create immediate supplier compliance issues and portfolio clean-up needs. | Have QA/regulatory confirm current raw materials against Annex XVII entries; request updated supplier declarations for any “treated powder” or “wear enhancer” material. |
| POPs Regulation (PFOS/PFOA entries) | EU persistent organic pollutant controls, including thresholds for unintentional trace contamination in substances/mixtures/articles. | Raises scrutiny around trace contamination and evidence quality; impacts how confidently you can communicate “PFAS-free.” | Define your internal PFAS evidence standard (supplier statements + screening where risk demands it) and store results with lot-level traceability. |
| France PFAS law | National ban that includes cosmetics. | Earliest hard deadline for many EU portfolios if France is a target market. | Plan cutover by Jan 1, 2026 for France-facing SKUs; avoid building inventory that can’t be sold post-deadline. |
Where PFAS hide in EU cosmetic portfolios
For EU readiness, you should assume PFAS are more likely to hide in raw-material structure than in obvious INCI lists. Therefore, screen these recurring “entry points” first:
- Treated powders and pigments: “treated pigment,” “surface modifier,” “wear additive,” “adhesion enhancer.”
- Film-forming color systems: long-wear foundation, transfer-resistant lip systems, eyeliners, mascaras.
- Repellency modifiers: water/oil resistance, smudge-proof wear, sebum resistance.
- Upstream processing aids: additives used by third parties (mold release, surface modification) that can be poorly documented.
EU triage flags (names that should trigger supplier disclosure)
- “fluoro-”, “perfluoro-”, “polyfluoro-”, “PTFE”, “fluoroacrylate”, “perfluoroalkyl phosphate”.
- Vague descriptors: “treated powder,” “wear enhancer,” “surface modifier,” “special dispersion.”
EU 12-month execution plan (R&D + RA + QA)
PhasPhase 1 — Portfolio audit (Month 0–2)
BOM extraction: Pull full BOMs (including treated pigments/fillers), then flag PFAS keywords plus “wear/repellency” raw materials.
Risk register: Track PFAS exposure by SKU, EU market mix (include France if relevant), and dependency on long-wear claims.
Phase 2 — Supplier declarations (Month 1–3)
Disclosure letter: Issue a PFAS Supplier Disclosure Letter requiring an explicit “intentionally added PFAS” statement and a management-of-change commitment.
Evidence collection: Gather updated SDS/TDS and declarations for each flagged material, including treated powders and proprietary blends.
Phase 3 — EU-focused verification (Month 2–8)
Escalation ladder: When documentation is weak or the ingredient is high-risk, run TOF screening for broad signal, then confirm with targeted methods when screening indicates risk.
Benchmarking: Validate reformulation against the EU claim set (wear time, rub-off, transfer, removal) and document outcomes (photos, instrumental data, and panels where appropriate).
Phase 4 — Dossier readiness (Month 6–12)
EU evidence file: Create a per-SKU record pack: supplier declarations, change-control history, screening results (where used), reformulation log, and claim-language rationale.
Cutover control: Align label/pack changes with the reformulation cutover to avoid reprint waste and split inventories.EU claims and documentation discipline
- Prefer: “Formulated without intentionally added PFAS.”
- Only use stronger “PFAS-free” language if you define the standard and can support it with your evidence file.
- Keep version control: claims must match the exact formula version and supplier evidence in your files.
Research References
- https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas
- https://echa.europa.eu/-/echa-publishes-updated-pfas-restriction-proposal
- https://echa.europa.eu/-/echa-to-consult-on-pfas-draft-opinion-in-spring-2026
- https://echa.europa.eu/substances-restricted-under-reach
- https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32021R1297
- https://www.sgs.com/en/news/2025/03/safeguards-04025-france-bans-pfas-on-consumer-products
- https://www.oeko-tex.com/en/news/infocenter/france-bans-pfas-in-textiles-per-2026/
- https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=PI_COM%3AC%282025%292189
- https://www.intertek.com/products-retail/insight-bulletins/2025/1482-eu-pfos-limit-update-pops-regulation/
