FPG’s Statement on ECHA’s Updated PFAS Background Document

Fluoropolymers Recognised: FPG’s Statement on ECHA’s Updated PFAS Background Document

Brussels, 25 August 2025

With the recent publication of the updated PFAS Background Document by the European Chemicals Agency (ECHA), the Fluoropolymers Product Group (FPG) recognises the efforts made by the dossier submitters in reviewing and integrating new data and evidence from the public consultation. FPG also welcomes the further recognition of the significant socio-economic benefits of fluoropolymers.

In their document, the authorities are proposing extensive derogations for the manufacturing of fluoropolymers, providing operations are under controlled conditions. This approach reflects the voluntary manufacturing programme set forward by the FPG. These developments are an encouraging step in recognising the critical role of fluoropolymers to enable a wide variety of products of high societal value, vital for achieving key European policy objectives and strategies – particularly those aiming for the sustainable transition of the EU economy.

Nonetheless, recognising the strategic importance of these materials and the fact that they can be responsibly managed across their lifecycle, FPG remains convinced that fluoropolymers should be afforded a full exemption from the restriction, based on the weight of scientific evidence.

The updated Background Document was prepared by regulatory authorities from Denmark, Germany, the Netherlands, Norway, and Sweden, and may be further amended as ECHA committee reviews continue. The publication of the Background Document is an important step in ensuring transparency in the process.

We remain committed to supporting the ECHA process in the coming months by providing scientific evidence and data to inform decision-making.

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The PFAS Background Document

What is the PFAS Background Document?

When a restriction dossier is submitted to ECHA, the proposal and its annexes become the “Background Document.” This document is usually confidential and shared only with stakeholders directly implicated in the restriction (such as industry associations or NGOs).

The Background Document is updated by the dossier submitters, in the case of the PFAS restriction, Germany, Sweden, Denmark, the Netherlands, and Norway. Since 2023, these authorities have been reviewing and integrating information shared during the public consultation, including data and evidence from industry, civil society, organisations, and regulators.

If new evidence justifies it, the Background Document is amended. Importantly, it is not the final PFAS REACH restriction, but it forms the basis for ECHA’s committees when drafting their opinions. ECHA has also confirmed that the document may continue to be updated during committee evaluation.

Read the full Background Document, here: https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas

Why the ECHA process matters

The ECHA restriction process is central to shaping EU chemicals policy. It ensures that decisions on PFAS are based on scientific evidence, socio-economic analysis, and transparency. By contributing data, evidence, and technical expertise, stakeholders like FPG help ensure that the committees’ work reflects the critical importance of fluoropolymers and the need for a balanced, risk-based approach.

Ultimately, ECHA’s committees, the Committee for Risk Assessment (RAC) and the Socio-Economic Analysis Committee (SEAC), will finalise an opinion that guides the European Commission’s decision-making on the PFAS restriction.