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Governments increasingly favour group-based PFAS restrictions

To date, PFAS regulation has largely followed a chemical-by-chemical approach, with only a few exceptions, such as the EU's universal restriction proposal and similar measures in several US states. However, governments are increasingly considering broader, class-based approaches.

Canada

In 2025, Canada proposed to regulate PFAS, excluding fluoropolymers, as a class, via a three-phase approach.

The critical first step is adding PFAS to the Schedule 1 list of toxic substances under the Canadian Environmental Protection Act (CEPA), thereby enabling the government to impose risk management measures. The proposal was subject to public consultation that ended on 7 May, and the government is reviewing the comments received. If the addition is made, the government’s proposed actions may be implemented.

The objective is "to achieve the lowest levels of environmental and human exposure that are technically feasible, taking into consideration socio-economic factors", Nabila Taha, from Environment and Climate Change Canada (ECCC), told PFAS Global 2026.

Phase one would prohibit the use of PFAS in firefighting foams. The government expects to publish a draft regulation for a 60-day public comment period in spring 2027.

Phase two would prohibit PFAS in certain consumer products, such as cosmetics, food packaging, and textiles, where their use is not necessary to protect human health, safety, or the environment.

The government is "actively engaging" stakeholders for its phase two work and expects to publish a consultation document in late 2027.

Phase three would prohibit PFAS that require further evaluation, for which there may be no feasible alternatives, such as in medical devices, fluorinated gas systems and transport and military applications.

At each phase, exemptions would be considered, when necessary, with attention to the feasibility of alternatives, socio-economic factors, and international alignment, Taha said.

All three phases remain contingent on PFAS being added to Schedule 1 under CEPA.

Asia

PFAS regulations in Asia are mostly progressing in close alignment with the Stockholm Convention on Persistent Organic Pollutants (POPs).

Consequently, as regulation of PFAS under the convention has begun to take a group-based approach, Asian countries have started implementing equivalent group-based measures.

Annex A of the convention includes:

• perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds, added in 2019;
• perfluorohexane sulfonic acid (PFHxS), its salts and PFHxS-related compounds, added in 2022; and
• long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds, added in 2025.

Correspondingly, Japan designated 117 PFHxS-related substances class 1 specified substances under the Chemical Substances Control Law (CSCL), leading to a ban on manufacture, import and use that became effective on 17 June.

The government applied the same designation to the LC-PFCA group on 22 May, and it is expected to take effect on 22 November. Manufacture, import and use will be banned unless specific exemptions apply.

The government has proposed a list of 156 LC-PFCA-related substances, which will also become effective on 22 November. The public consultation on the list closed on 30 June.

Some Asian countries, however, are showing an appetite to go beyond the requirements of the convention.

For example, when China added some PFAS to its revised List of Priority Controlled Chemicals (Third Batch), published on 25 December 2025, it included an additional 28 PFAS, along with the LC-PFCA group. The additional PFAS included short-chain PFCAs, perfluoroethers and substances related to perfluorobutanesulfonic acid (PFBS).

Thailand, meanwhile, has copied the broad, class-based scope of some EU legislation for proposed major changes to its rules on non‑plastic food contact containers that would restrict the use of PFAS and other substances. The proposal targets the long-standing Ministry of Public Health (MoPH) Notification No 92 (B.E. 2528/1985) and introduces limits for PFAS, including polymeric PFAS, as a class in metal and paper containers.

The limits are:

• 25ppb for any individual targeted PFAS;
• 250ppb for the sum of targeted PFAS (inclusions and exclusions apply); and
• ≤50ppm (mg/kg) for total PFAS (including polymeric PFAS).

These same limits appear in the EU Packaging and Packaging Waste Regulation (PPWR) and the original proposal for the universal PFAS restriction under EU REACH.

A public consultation on the Thai proposal closed on 31 March.

Cosmetics and FCMs: a major focus for regulators

As well as measures targeting groups of PFAS, governments are implementing measures to restrict the use of PFAS in specific products, particularly cosmetics and food contact materials (FCMs).

In January, China amended its safety and technical standards for cosmetics to prohibit the use of perfluorooctanesulfonic acid (PFOS) and PFOA as cosmetics ingredients from 1 January 2027.

Cosmetics are also a focus in New Zealand and US states such as Illinois, Maryland and Virginia.

Meanwhile, India and Switzerland have joined Thailand in targeting PFAS in FCMs.

India has proposed banning the use of PFAS in the manufacture of FCMs, though it provides little detail on how the class would be defined.

In Switzerland, the government has plans to introduce concentration limits for PFAS in food packaging, single-use consumer articles and firefighting foams. If adopted, the amendment to the country’s Chemical Risk Reduction Ordinance (ORRChem) would take effect on 1 December.

Little global harmonisation 

There is generally scant harmonisation across jurisdictions in regulatory measures regarding PFAS, and Thailand's approach (above) remains the exception.

In places, there is even significant divergence between close trading partners. Australia and New Zealand, for example, are taking different approaches to tackling the PFAS challenge.

"In Australia, the regulatory focus for PFAS is largely on the industrial chemical pathways," Richard Wallis from Arcadian Chemical Consulting told PFAS Global 2026. Therefore, the Australian Industrial Chemicals Introduction Scheme (AICAS) is the key regulator, and the Industrial Chemicals Environmental Management Standard (IChEMS) is the key framework.

Furthermore, the focus is on evaluation, rather than restriction.

In 2025, the AICAS launched a review of the 522 PFAS listed on the Australian Inventory of Industrial Chemicals and the agency’s Rolling Action Plan. The review, which aims to determine whether those PFAS have been introduced into Australia and capture key information about the substances, requires relevant companies to provide information on use, volume and substance identification.

By contrast, New Zealand is already taking targeted actions to reduce health and environmental risk, such as banning firefighting foams containing PFAS, phasing out PFAS in cosmetic products, and testing for background levels of PFAS in the environment, Wallis told delegates.

The upshot of this situation is that the same PFAS may be regulated completely differently in the two jurisdictions, despite the close trading ties, he said.

This point is illustrated by perfluorohexane, a common cosmetic ingredient in skin care products and eye makeup.

The substance is under evaluation in Australia, but its use in cosmetics is permitted, and there are no immediate plans to change that.

In New Zealand, changes to the Cosmetic Products Group Standard that came into effect on 1 January restrict the use of PFAS as a class, including perfluorohexane. From 1 January 2027, companies are prohibited from importing or manufacturing cosmetic products containing PFAS and from 1 January 2028 from selling them.

Compliance challenges depend on the product

The growing number of PFAS controls, combined with limited international harmonisation, is creating increasingly complex compliance obligations for companies.

The regulatory landscape is "fragmented" and evolving "at a very rapid pace", Cindy Vandecasteele from the European Automobile Manufacturers' Association (ACEA) told the conference.

Regulatory measures differ across jurisdictions in terms of definition (are fluoropolymers in or out?), reporting rules (complex objects, mixtures only or substances?), labelling requirements and exemptions, Vandecasteele said.

The EU’s proposed universal PFAS restriction is the biggest challenge for the European automotive sector, which "relies extensively" on fluoropolymers for critical performance and safety applications.

"We have indeed done an extensive search also looking for alternatives, if they are available or not, and to be realistic, in most cases, we do not find any alternatives yet," she said. "Without a doubt, this will create one of the most complex compliance transitions that we face."

Meanwhile, Tomasz Doweyko from Duni Group, which makes food packaging such as trays, boxes, bowls, cups, glasses and cutlery, as well as other related products, said his company had successfully eliminated PFAS from its bagasse fibre-based packaging.

The product is now marketed as containing "no intentionally added PFAS" and is compliant with the EU PPWR, Doweyko said.

A major difference between these two product sectors is the complexity of their supply chains.

Vandecasteele said the average car comprises 8,000 components, and a vehicle manufacturer has an average of 3,000 suppliers globally, rising to billions when companies indirectly involved in the end product are accounted for.

By contrast, bagasse packaging is made from crushed sugar cane stalks, plus coatings or additives for specific functionality.

Eliminating PFAS does not come easily

Even with a relatively simple supply chain, Doweyko said, eliminating PFAS "did not come easily".

Removing PFAS "was not like changing just a colour or modifying the shape of the product. Instead, we were actually removing the functionality of the product, and that functionality still had to be replaced in a practical way," he told the conference.

This meant there were multiple uncertainties, including:

• whether the market would support the change, at this time;
• how the revised product would perform compared with the original; and
• what the revised product would cost, allowing for supply risk.

A key challenge was that suppliers did not have an established solution that could simply replace PFAS like-for-like, meaning "a lot of trial and error" was required, including testing different additives, process settings, product types and performance tests, Doweyko said.

The solution his team landed on was to replace the original PFAS-containing product, which covered a broad range of applications, with two products, each covering a narrower range.

One of the replacements is an uncoated bagasse with an alternative additive, suitable for short-term use and less demanding food conditions. The other is bagasse with a plastic coating, suitable for greasy food, higher moisture, longer holding times, or reheating.

With this approach, Duni Group has managed its transition, but for many other companies, the uncertainties of PFAS regulations globally are destabilising.

One issue that is becoming a particular focus of concern across multiple sectors is how to address PFAS unintentionally present in products due to contamination of raw materials and other routes. Restrictions based on threshold levels do not differentiate between intentional and unintentional occurrences.

Sybille Millet from the French Cosmetics Association for SMEs (COSMED) said that this is a problem for cosmetics manufacturers because traces of PFAS may come from:

• manufacturing processes, through the use of industrial equipment;
• raw materials, which may be natural substances contaminated by the environment; and
• process water.

"This is a very delicate situation because we have to manage traces from potential upstream use that cosmetics manufacturers do not manage and do not control," she said.