Chemicals
The PFAS Restriction and Declarations in the Passport
Where the PFAS restriction stands, which PFAS are already banned and how to declare PFAS presence in a textile, paint, cosmetics or electronics passport
Per- and polyfluoroalkyl substances (PFAS) are a group of thousands of substances known as "forever chemicals". In January 2023 five countries submitted a restriction proposal to ECHA targeting the whole group; the proposal is still under assessment and, as of September 2026, there is no final decision. That does not mean PFAS are unrestricted: specific PFAS have been restricted for years, PFAS in food-contact packaging are limited under PPWR from 2026, and market surveillance treats PFAS as a priority test topic.
From the Digital Product Passport's point of view the question is: how do you declare PFAS before the restriction is finalised, and what does saying "free" cost?
Where the restriction stands
| Measure | Scope | Status |
|---|---|---|
| PFOS, PFOA, PFHxS | Under the POPs Regulation | In force |
| C9–C14 PFCAs | REACH Annex XVII | In force |
| PFAS in food-contact packaging | PPWR, PFAS above thresholds | Applies from 2026 |
| Universal PFAS restriction | Whole PFAS group, use-based derogations | Under ECHA assessment; decision pending |
| National bans | Some member states such as Denmark, some US states | In force per country |
If the universal restriction is adopted, it is expected to apply with use-based transition periods and derogations; how long each use gets is not yet known. For the enforcement side, see market surveillance and DPP inspection.
Where PFAS sit in products
PFAS are the chemistry of a function, not of a sector: water, oil and dirt repellency, heat and chemical resistance.
- Textiles: durable water repellent (DWR) finishes, outerwear and technical textile membranes. See textile DPP data points and chemical management in textiles: ZDHC and MRSL.
- Paints and coatings: oil- and water-repellent additives, fluoropolymer coatings. See DPP for paints and coatings.
- Cosmetics: film-forming and water-repellent ingredients in some formulations. See DPP for cosmetics.
- Cookware: non-stick coatings.
- Electronics: fluoropolymers, refrigerants, cable coatings.
Being on this list creates no declaration duty; but you cannot say "free" without knowing where PFAS could be.
How to declare in the passport
The substances-of-concern field needs a specific structure for PFAS. Our recommendation:
- Substance or group: substance name and CAS where the individual CAS is known; otherwise the group name (fluoropolymer, short-chain PFCA and the like) and the definition used.
- Concentration range: a range by weight, structured so it can be reclassified when restriction thresholds change.
- Test method and date: total fluorine or total organic fluorine screening (for screening) and targeted LC-MS/MS analysis (for substance-level confirmation). Method and detection limit are part of the declaration.
- Source: supplier declaration or your own test result; the document link sits in the restricted tier.
Formulation detail stays in the restricted tier; the public tier shows presence, range and method. See restricted data tiers and authorised access and DPP for chemicals, REACH and SCIP.
The risk of a "PFAS-free" claim
"PFAS-free" is strong in marketing and fragile in law. Absolute absence cannot be proven for a group of thousands of substances; what can be proven is staying below a given detection limit with a given method. Green-claims rules ban generic, unsubstantiated environmental claims. See the Green Claims Directive and greenwashing.
A phase-out plan and an evidence trail
The restriction of PFAS is a question of timing, not probability. Preparation:
- List the functions in your product families where PFAS could be present (repellency, resistance) and request structured declarations from suppliers.
- Screen-test high-risk items; where positive, identify the substance with targeted analysis.
- Plan the switch to alternative chemistry per product and version the transition date in the passport; old and new batches carry separate declarations. See audit trail and versioning.
- Keep the declaration, test report and supplier document in one record; in an inspection you should be able to present the evidence chain within minutes.
For textile-focused preparation, see the textile DPP guide.
Frequently asked questions
When will the PFAS restriction enter into force?
There is no decision on the universal restriction; ECHA's scientific committees are completing their opinions in stages and the Commission decision follows. Restrictions on specific PFAS and on food-contact packaging are already in force.
Is a PFAS declaration mandatory in the passport?
If the product group's delegated act covers substances of concern, restricted and candidate-list PFAS are declared. For PFAS outside that scope the declaration is voluntary today, though customer contracts may require it.
Can I write "PFAS-free"?
Avoid the absolute wording. A test declaration with method, detection limit and date is both accurate and defensible; a generic "free" claim is risky under green-claims rules.
