EU Moves Closer to Sweeping PFAS Restrictions
The European Chemicals Agency (ECHA) is moving forward on what would be one of the most consequential chemical regulatory actions in recent memory: a broad, class-based restriction on per- and polyfluoroalkyl substances (PFAS) under the EU’s REACH regulation. ILMA members with European operations or supply chain exposure should take note.
Two Committees Concur
Two key ECHA scientific committees have now weighed in. The Committee for Risk Assessment (RAC) issued its final opinion in March 2026, concluding that an EU-wide restriction on the manufacture, use and sale of PFAS is the most appropriate regulatory response to risks posed by these substances. RAC estimates that a comprehensive restriction could reduce PFAS emissions by approximately 96% over a 30-year period.
The Committee for Socio-Economic Analysis (SEAC) also released a draft opinion — open for public comment through May 25 — similarly supporting broad restrictions, while cautioning that an immediate, blanket ban may not be proportionate given the limited availability of alternatives in certain applications. SEAC favors a framework pairing a general prohibition with use-specific, time-limited exemptions.
The proposal targets PFAS broadly as a chemical class — potentially encompassing more than 10,000 substances — across manufacturing, import and use in products spanning textiles, medical devices, packaging and industrial applications. Exemptions are anticipated for sectors where alternatives remain technically unavailable, though these would carry additional compliance obligations including emissions monitoring, supply chain reporting and labeling requirements.
Significant Findings for the Lubricants Sector
The lubricants sector received direct attention in both committee opinions, and the findings are significant.
RAC identified high PFAS volumes and emissions in lubricants, estimated at approximately 800 metric tons per year, and concluded that those emissions are not adequately controlled and must be minimized. Regarding restriction options, RAC evaluated a full ban (RO1) and a ban with broad derogations (RO2). While RAC found RO1 effective, it concluded that RO2 would result in an estimated 16,825 additional metric tons of PFAS emissions over 30 years and characterized the associated risk as uncontrolled. If RO2 is ultimately adopted, RAC recommends comprehensive lifecycle risk management measures to reduce emissions.
SEAC’s findings offer a more nuanced picture. On substitution, SEAC concluded that for industrial and professional lubricant uses, characterized as applications requiring performance under harsh conditions, substitution potential is low and technically feasible alternatives are generally not available. SEAC also flagged that a broad ban would have cascading effects across downstream sectors including automotive, aerospace, nuclear, medical devices and industrial machinery, and acknowledged that downstream costs are likely underestimated. On that basis, SEAC concluded that a full ban (RO1) would likely not be proportionate for the lubricants sector. While SEAC could not reach a definitive conclusion on the proportionality of RO2, citing cost uncertainty and reduced environmental benefits, it indicated that a 12-year derogation for industrial and professional uses may be justified given current evidence.
Implications for the U.S. Lubricants Industry
Following the close of the SEAC consultation, ECHA will transmit both committee opinions to the European Commission, which will then draft a formal amendment to REACH Annex XVII for consideration by EU member states and review by the European Parliament and Council. SEAC is expected to finalize its opinion by the end of 2026, though the path to a final regulation will involve additional procedural steps.
ILMA members with a European market presence — or those supplying customers who do — can face exposure as this regulation advances. Lubricant formulations that incorporate PFAS-based raw materials or fluorinated components can be affected given the broad class-based scope of this regulatory approach, which means that substitution strategies will require careful technical and regulatory analysis. Early engagement and proactive supply chain mapping will be essential for members seeking to stay ahead of what is likely to be an evolving and expanding global regulatory picture.
ILMA is monitoring these developments through its engagement with the Technical Association of the European Lubricants Industry (ATIEL) PFAS Working Group and will continue to support member advocacy efforts as the regulatory process advances.
