PFAS Update December 2025

Posted on Dec 12, 2025 Tags: Industry News

The proposal to restrict PFAS in the EU/EEA was prepared by authorities in Denmark, Germany, the Netherlands, Norway and Sweden. It was submitted to ECHA on 13 January 2023. It aims to reduce PFAS emissions into the environment and make products and processes safer for people

Since then, several rounds of consultation and review have taken place and as of December 2025, much progress has been made, however, we are still quite some way from having a clear roadmap for all those involved in the sealing industry.

Here Russ Pimblett shares a coffee break guide to the current state-of-play in relation to the sealing industry and sealing applications.

Formal Inclusion Under REACH

We reported positively earlier in the year that ECHA’s August 2025 Background Document officially identifies “sealing applications”—including seals, gaskets, valve parts, and pipe linings—as one of eight newly assessed sectors. This recognition ensures the sector is subject to dedicated evaluation and policy outcomes UKGSA PFAS/ECHA Quick Guide.

Exposure to Restrictive Scenarios

Three restriction options (RO1–RO3) are under consideration:

RO1: A complete ban with an 18‑month phase-out.
RO2: Ban with time‑limited, sector-specific exemptions (5–12 years), potentially including extended relief for industrial seals e.g., 12-year grace period
RO3: Continued use under stringent “controlled-use” conditions—requiring lifecycle closed systems, emission controls, and high recycling rates

Chemical Thresholds

Alongside, time-restricted phaseout options, ECHA’s proposal also sets PFAS thresholds:

25 ppb per individual PFAS
250 ppb total PFAS (excluding polymeric PFAS)
50 ppm total PFAS (including polymeric PFAS)

Sealing manufacturers will need thorough testing and verification to confirm compliance within these limits. This does introduce additional burden on seal and gasket manufacturers and their supply chains to determine PFAS levels.

Sealing Industry Advocacy

The European Sealing Association (ESA) and other industry bodies are actively arguing for balanced restrictions—emphasizing essential roles of fluoropolymer seals and urging ECHA to grant controlled-use or exemption paths.

The ESA is preparing for the SEAC consultation (March 2026) by compiling evidence on the lack of viable alternatives, economic impact, and technical necessity of PFAS-based seals.

Critical Reliance on Fluoropolymers

PTFE and related fluoropolymers are deemed technically indispensable for high-performance sealing due to their exceptional chemical resistance, thermal stability, and longevity.

Alternatives like HNBR, NBR, or ACM can’t fully replicate these properties, limiting substitution options.

Currently, the latest proposal requires a technical case to be made for each and every sealing application to demonstrate that there is a critical reliance on the use of fluoropolymers in that application.

Summary

The sealing industry now faces a regulated environment where PFAS—including use of PTFE, FFKM and FKM—are tightly reviewed.

Outcomes may range from extended, conditional use (under RO2/RO3) to stricter limits or bans.

Sealing manufacturers can expect additional burdens including evidence collation, technical defences, and compliance planning in order to maintain market presence in the EU.

The ECHA PFAS proposal significantly raises the regulatory burden for seal manufacturers and their associated supply chains, shifting responsibility for PFAS management onto them.

Companies selling PFAS-bearing products must review their entire value chain, invest in compliance, and plan for reformulation or managed exemption strategies to sustain market access within the EU and EEA.

11 December 2025