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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

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 assesses the potential effects of a full or partial restriction. Conducted by RPA Ltd and published in December 2025, the study focuses on six fluoropolymers and fluorinated gases (F-gases) used across aerospace, defence, green energy, and semiconductor sectors.

The report finds that substitution of PFAS is often unfeasible in strategic sectors such as aerospace and semiconductors due to the lack of alternatives and long qualification cycles. For defence, limited public data complicates the analysis. In green energy and clean technologies, the substitution potential varies by application, with some use cases requiring further development before alternatives can be implemented.

Socio-economic modelling estimates significant costs under both regulatory options. A full ban (RO1) could lead to economic losses of at least €562.8 billion in the first year and €72.8 billion annually thereafter. A restriction with time-limited derogations (RO2) would result in slightly lower costs—€561.7 billion initially and €71.7 billion per year. Up to 2.9 million jobs and 39,000 enterprises—90% of which are SMEs—could be affected.

The study recommends time-unlimited derogations for PFAS use in aerospace, defence, and semiconductors. In aerospace, it suggests periodic review every 10–15 years and support for alternative development. For defence, it calls for comprehensive supply chain mapping and gradual substitution aligned with security priorities.

For F-gases, the report proposes excluding them from the scope of the universal PFAS (UPFAS) restriction and maintaining regulation under the existing F-gas Regulation to allow gradual transition to alternatives while preserving innovation capacity.

Regarding green energy, the study advises a review of proposed derogations and the creation of a task force to monitor alternative development. In semiconductors, it supports a permanent derogation and recommends integrating PFAS policy within the European Chips Act, including dedicated funding under the European Genesis Programme for abatement and alternative technologies.

Cross-sector recommendations include strengthening research into the health and environmental effects of fluoropolymers and establishing an innovation fund to support emissions control and the development of alternatives.
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