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EXPERTISE · PFAS

PFAS

Per- and polyfluoroalkyl substances, regulated through several overlapping regimes at once, in Great Britain and the EU.

One substance group, several routes of regulation.

PFAS (per- and polyfluoroalkyl substances) are a very large group of substances, widely used for their resistance to heat, water and oil across industries including aerospace, defence, electronics and consumer products. Their persistence in the environment has earned them the label “forever chemicals”, and that persistence is now driving significant regulatory action.
Rather than being controlled by a single regulation, individual PFAS are already addressed through REACH restrictions, POPs listings and RoHS thresholds, while a broad REACH restriction covering PFAS as a group is moving through the EU legislative process at the same time.
✓PFAS identification within products, materials and bills of materials
✓Tracking PFAS-specific developments across REACH, POPs and RoHS
✓Alternatives analysis where a PFAS substance needs to be substituted
✓Building a defensible, evidenced PFAS position ahead of regulatory change
WHAT MAKES A SUBSTANCE PFAS

A very wide net, defined by chemistry rather than a name.

PFAS is a broad structural category, which is precisely what makes screening for it difficult — a substance can qualify without the term “PFAS” ever appearing on a supplier data sheet.

A structural definition, not a single substance
The EU restriction proposal defines PFAS structurally: any substance containing at least one fully fluorinated carbon atom (a CF₃ or CF₂ group with no attached hydrogen, chlorine, bromine or iodine). That structural test brings thousands of individual substances within scope, not a short named list.
Persistence is the core concern
The carbon-fluorine bond that gives PFAS their useful properties is also extremely resistant to breakdown, which is why these substances persist in the environment and in the body for very long periods, and why they are commonly described as “forever chemicals”.
Widespread historic use
PFAS have been used in firefighting foams, surface coatings, textiles, electronics and many industrial processes for decades, which means they can be present in legacy equipment, sites and materials without an obvious label pointing to them.
REGULATED THROUGH MULTIPLE ROUTES

Existing controls today, and a broad restriction on the way.

A number of individual PFAS are already regulated directly: PFOA and PFHxS (and related compounds) are listed under the POPs Regulation, and others are subject to existing REACH restrictions on specific uses.

Alongside these, a broad REACH restriction proposal covering PFAS as a group has received a final opinion from ECHA’s Risk Assessment Committee, with the Socio-Economic Analysis Committee’s opinion still in draft and due to be finalised later in 2026, ahead of adoption by the European Commission. Once in force, it would represent one of the most significant restrictions in REACH’s history.

✓Monitoring the EU-wide PFAS restriction proposal as it moves toward adoption
✓Tracking existing PFAS listings under POPs and REACH restrictions
✓Screening products and materials against current and proposed PFAS scope
✓Assessing exposure to firefighting foam and other legacy PFAS uses
GB & EU DIVERGENCE

Two different strategies, moving at different speeds.

Great Britain and the EU are approaching PFAS from different angles at present, and a position built for one market cannot be assumed to transfer directly to the other.

Great Britain
The UK government published its first comprehensive PFAS Plan in early 2026, setting a coordinated strategy for reducing exposure, and HSE has consulted separately on a UK REACH restriction targeting PFAS in firefighting foams — a use with direct relevance to defence sites.
European Union
A broad REACH restriction proposal covering PFAS as a group has progressed through ECHA’s formal committee opinions, moving toward adoption by the European Commission and representing a EU-wide, cross-sector restriction rather than a use-by-use approach.
HOW WE HELP

Building a defensible PFAS position, ahead of the deadline.

PFAS is one of the harder substance groups to get a clear position on, precisely because it is being addressed through several regimes at once, each moving on its own timetable, in Great Britain and the EU separately.
We help organisations identify PFAS within their products, materials and legacy sites, track the regulatory routes that apply, and build the evidence and alternatives analysis needed to respond as restrictions are finalised.
✓PFAS identification within products, materials and legacy equipment
✓Global Regulatory monitoring across REACH, POPs, RoHS and the UK PFAS Plan
✓Alternatives analysis where a PFAS substance needs to be substituted
✓Evidence-building for defence and industrial sites with historic PFAS use
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