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EU study advises PFAS derogations for key industries amid restriction talks
22 December 2025

EU study advises PFAS derogations for key industries amid restriction talks

A new study commissioned by the European Parliament’s Industry, Research and Energy Committee (ITRE) evaluates the role of per- and polyfluoroalkyl substances (PFAS) in industrial competitiveness and the potential effects of a full or partial restriction on their use. The analysis focuses on six fluoropolymers and fluorinated gases (F-gases) used in aerospace, defence, green energy, and semiconductor sectors.

The study finds that substitution of PFAS is often not feasible, particularly in aerospace and semiconductors, due to the absence of alternatives and long qualification timelines. In defence applications, limited data availability further complicates the assessment. For green energy and clean technologies, substitution potential varies by application.

Economic modelling predicts substantial impacts under both restriction options. A full ban (RO1) could cost the European economy at least €562.8 billion in the first year, with annual costs of at least €72.8 billion. A scenario with time-limited derogations (RO2) would result in slightly lower but still significant economic losses. Up to 2.9 million employees and 39,000 enterprises, 90% of which are SMEs, could be affected.

Recommendations include permanent or long-term derogations for aerospace, defence, and semiconductor sectors. In aerospace, a time-unlimited derogation with a review every 10–15 years is suggested, along with funding for alternative materials and end-of-life studies. For defence, the study calls for supply chain mapping and gradual substitution aligned with European security needs.

The study also advises excluding F-gases from the universal PFAS (UPFAS) restriction scope, proposing instead to regulate them solely under the existing F-gas Regulation. For green energy, it recommends a detailed review of derogations and establishing a task force to monitor alternative development.

In semiconductors, a permanent derogation is proposed due to the sector’s critical role in digital infrastructure. The study suggests aligning policy with the European Chips Act and creating funding streams for abatement technology and PFAS alternatives under the European Genesis Programme.

Cross-sector recommendations include increasing research on PFAS impacts and establishing an innovation fund to support alternative development and emissions control.
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