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ARTICLE · 09 FEBRUARY 2023

Proposal For EU Restrictions For PFAS: The Beginning Of A Long And Complex Process (Part 1)

Steptoe LLP
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Today, the European Chemicals Agency (ECHA) published the proposal for EU REACH restrictions for the largest group of chemically-related substances ever considered, per- and polyfluoroalkyl substances (PFAS).

European UnionEnvironment
Ruxandra Cana
Ruxandra Cana
Eléonore Mullier
Eléonore Mullier

Today, the European Chemicals Agency (ECHA) published the  proposal for EU REACH restrictions for the largest group of chemically-related substances ever considered, per- and polyfluoroalkyl substances (PFAS). The Agency is expected to open the public consultation for comments on March 22, 2023 until September 22, 2023.

The Steptoe team will issue a series of client alerts and contributions related to this most important proposal. This first note raises several matters of principle related to the structure and basis of the proposal. Our next analysis will examine the merits of the proposed exemptions, and what steps can be taken during the soon-to-be-opened consultation.

At the outset, we note that any proposal for restrictions must meet the test set out in the currently applicable version of the REACH Regulation. The changes to REACH announced in the Chemicals Strategy for Sustainability (such as the concept of essential use or the extension of the generic

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