Is PFAS Banned? Where EU and US Rules Stand, Product by Product
Summary
No, as of 2026-10-15 no EU or US federal rule bans all PFAS; current bans cover named PFAS or specific product categories. The EU universal restriction is still a proposal (CIRS, 2026). Maine and Minnesota ban intentionally added PFAS in any product from 1 January 2032 unless the use is currently unavoidable (Minn. Stat. 116.943, 2025; 38 M.R.S. 1614, 2025).
The European Chemicals Agency (ECHA) Committee for Risk Assessment (RAC) adopted its opinion on the universal PFAS restriction in March 2026, and the Committee for Socio-Economic Analysis (SEAC) aims to adopt its final opinion by the end of 2026 (Linklaters, 2026; CIRS, 2026).
The SEAC draft consultation drew 3,511 comments, and lubricants accounted for 5.3% of comments in the industry-specific surveys (CIRS, 2026).
Under the proposal, the PFAS prohibition would apply 18 months from entry into force of the restriction, with derogations for named uses (SGS, 2026).
Minnesota's PFAS law covers products sold or distributed for commercial or industrial use, including for use in making other products (Minn. Stat. 116.943, 2025).
When is PFAS banned in the EU or the US, and when not?
PFAS is banned in the EU or the US only for named substances, such as PFOS, PFOA and PFHxS, or for named product categories, such as EU firefighting foams and the Minnesota product list. A PFAS-containing industrial product that falls outside those lists is not banned as of 2026-10-15 in the EU or under US federal law (CIRS, 2026; EPA, 2026). To use the table, find each PFAS by name or CAS number on the safety data sheet or supplier declaration, then match the product category and the market; a Yes needs both to match. The table below gives the verdict by PFAS group, product category and market:
Condition | Verdict | Why |
|---|---|---|
PFOS, PFOA or PFHxS, their salts and related compounds, EU | Yes | Listed in Annex I of the POPs Regulation (EU) 2019/1021 (Regulation (EU) 2019/1021, 2019); PFOA added by Regulation (EU) 2020/784 and PFHxS by Regulation (EU) 2023/1608 (Regulation (EU) 2020/784, 2020; Regulation (EU) 2023/1608, 2023) |
C9-C14 perfluorocarboxylic acids (PFCAs), EU | Yes, since 25 February 2023 | REACH Annex XVII entry 68: below 25 ppb for the sum of C9-C14 PFCAs and their salts (Regulation (EU) 2021/1297, 2021) |
PFHxA in consumer mixtures, cosmetics, food-contact paper, consumer clothing and footwear, EU | Yes, since 10 October 2026 | REACH entry 79: below 25 ppb PFHxA and salts and below 1,000 ppb PFHxA-related substances (Regulation (EU) 2024/2462, 2024) |
PFAS in firefighting foams, EU | Yes, from 23 October 2030 for most uses; until 23 October 2035 for Seveso sites, offshore oil and gas, military vessels and some ships | REACH entry 82: below 1 mg/L for the sum of all PFAS; portable extinguisher foams may be placed on the market only until 23 October 2026, alcohol-resistant ones until 23 April 2027 (Regulation (EU) 2025/1988, 2025) |
PFAS in food-contact packaging, EU | Yes, since 12 August 2026 | Packaging and Packaging Waste Regulation, Article 5(5): below 25 ppb for any targeted PFAS, 250 ppb for their sum and 50 ppm for total PFAS including polymers (Regulation (EU) 2025/40, 2025) |
Any other PFAS, such as fluoropolymers or PFAS in industrial lubricants, EU | No, not yet | Universal restriction still in committee review (CIRS, 2026) |
Any PFAS, US federal law | No | Rules require notice and EPA review for listed PFAS uses, not a general ban (EPA, 2026) |
Intentionally added PFAS in 11 listed product categories, Minnesota | Yes, since 1 January 2025 | Minn. Stat. 116.943, subd. 5(a) (2025) |
Intentionally added PFAS in any other product, Minnesota | Only if sold from 1 January 2032 and not a currently unavoidable use | Minn. Stat. 116.943, subd. 5(d) (2025) |
Intentionally added PFAS, Maine | Yes since 1 January 2026 for listed categories such as cleaning products, cookware and textile articles; any other product from 1 January 2032 unless a currently unavoidable use | 38 M.R.S. 1614(5)(B-1) and (D); cooling, heating, ventilation, air conditioning and refrigeration equipment from 1 January 2040 under (E) (38 M.R.S. 1614, 2025) |
The key row for a lubricant or process chemical supplier is the sixth: PFAS in industrial lubricants are not banned in the EU as of 2026-10-15, because the universal restriction has not been adopted (CIRS, 2026).
Which PFAS are already restricted under EU law?
Five PFAS restrictions are already adopted under EU law: PFOS, PFOA and PFHxS under the Persistent Organic Pollutants (POPs) Regulation, C9-C14 PFCAs under REACH entry 68, PFHxA under REACH entry 79, all PFAS in firefighting foams under REACH entry 82, and PFAS in food-contact packaging under the Packaging and Packaging Waste Regulation (Regulation (EU) 2019/1021, 2019; Regulation (EU) 2025/40, 2025).
The PFHxA restriction, Regulation (EU) 2024/2462, applies in phases. Training and testing foams and public fire service foams, except those used at industrial fires at Seveso establishments, were covered from 10 April 2026; consumer mixtures, cosmetics, food-contact paper and consumer clothing and footwear from 10 October 2026; other consumer textiles from 10 October 2027; and civil aviation foams from 10 October 2029 (Regulation (EU) 2024/2462, 2024). Mixtures and articles placed on the market before 10 October 2026 are exempt from that phase (Regulation (EU) 2024/2462, 2024). An industrial lubricant sold only to professional users is not in the listed consumer uses.
The firefighting foam restriction, Regulation (EU) 2025/1988, restricts placing on the market and use of foams with 1 mg/L or more for the sum of all PFAS from 23 October 2030 (Regulation (EU) 2025/1988, 2025). Derogations run to 23 October 2035 for foams at Seveso Directive establishments, offshore oil and gas installations, military vessels and some civilian ships; portable extinguisher foams may be placed on the market only until 23 October 2026, or 23 April 2027 if alcohol-resistant (Regulation (EU) 2025/1988, 2025).
Do US states ban PFAS in industrial products?
Yes, Maine and Minnesota ban PFAS in industrial products, but most industrial products are covered only from 1 January 2032 (Minn. Stat. 116.943, 2025; 38 M.R.S. 1614, 2025). Minnesota's law defines a product as an item sold or distributed for "personal, residential, commercial, or industrial use, including for use in making other products" (Minn. Stat. 116.943, 2025).
Since 1 January 2025, Minnesota bans intentionally added PFAS in 11 categories, including cleaning products used for domestic, commercial or institutional cleaning, cookware and ski wax (Minn. Stat. 116.943, 2025). That ban does not apply when the PFAS are only in electronic components or internal components. From 1 January 2032, any product with intentionally added PFAS is banned unless the Minnesota Pollution Control Agency commissioner has determined by rule that the use is currently unavoidable. The commissioner may also add categories by rule with effective dates no later than 1 January 2032 (Minn. Stat. 116.943, 2025).
The law exempts products where federal law preempts state authority, products regulated under Minnesota sections 325F.072 or 325F.075, and the resale of used products, and the sales bans exclude medical devices and drugs regulated by the US Food and Drug Administration (Minn. Stat. 116.943, 2025). Check each state where a product is sold.
Is PFAS banned under US federal law?
No, PFAS is not banned under US federal law; federal rules require notice and EPA review before listed PFAS uses start or resume (EPA, 2026). Under the Toxic Substances Control Act (TSCA), the US Environmental Protection Agency (EPA) issued a significant new use rule (SNUR) in July 2020 requiring notice and EPA review before phased-out long-chain PFAS uses could begin again, and articles containing certain long-chain PFAS as a surface coating "can not be imported into the United States without EPA review" (EPA, 2026).
In January 2024, EPA finalized a second SNUR that prevents anyone from resuming manufacture or processing of PFAS listed as inactive on the TSCA Inventory without EPA review (EPA, 2026).
To map which of your own products fall under which of these rules, Lubinpla works the case from your own SDSs, TDSs and certificates and returns one cited document for your review.
Frequently asked questions
When will the EU universal PFAS restriction apply?
No date is set as of 2026-10-15. SEAC aims to adopt its final opinion by the end of 2026, after which the European Commission drafts the restriction and submits it to the REACH Committee for a vote (CIRS, 2026). Under the proposal, the prohibition would apply 18 months after the restriction enters into force (SGS, 2026), and SEAC supports standard derogation periods of five or twelve years on top of that for named uses (Linklaters, 2026).
Are fluoropolymers such as PTFE banned?
Not in the EU as of 2026-10-15. RAC's opinion and SEAC's draft opinion both reject a derogation for fluoropolymers as a group in the universal restriction, so fluoropolymers would fall under it unless a use-specific derogation applies (Linklaters, 2026). PTFE is a fully fluorinated polymer and meets Minnesota's definition of PFAS as chemicals with at least one fully fluorinated carbon atom, so a product with intentionally added PTFE faces the 1 January 2032 ban unless the use is ruled currently unavoidable (Minn. Stat. 116.943, 2025).
Does the EU universal PFAS restriction cover lubricants?
Yes, lubricants are one of the sectors in the consultation. In the SEAC consultation that closed on 25 May 2026, lubricants drew 5.3% of comments in the industry-specific surveys, while electronics and semiconductors drew the most, at 12.7% (CIRS, 2026; Linklaters, 2026).