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Pressure is no longer coming from governments alone!

Update on PFAS Initiative 02/2026

Kaprun | March 2026

1. PFAS: From a niche topic to a strategic industrial issue

Even though the debate has quieted somewhat in recent months, PFAS (per- and polyfluoroalkyl substances) remain one of the key future issues for the plastics industry. In a short period of time, PFAS have evolved from a niche topic into a strategic issue that now affects numerous industries — from mechanical engineering and the semiconductor sector to mobility and medtech.

2. A brief history: On the path to an EU-wide REACH procedure

Under the EU chemicals regulation REACH, substances with hazardous properties are to be more strictly restricted or banned in the future. For PFAS, a comprehensive Annex XV restriction dossier was prepared and first submitted to ECHA in March 2023 by five countries. The objective was a group-based restriction covering more than 10,000 PFAS substances.

During the public consultation in 2023, more than 5,600 comments were submitted, including contributions from Zell Materials. Based on this extensive feedback, the dossier was revised and republished in updated form on August 20, 2025. It now covers 23 sectors in which PFAS uses are being assessed — ranging from industrial applications to consumer products.


3. New momentum: Insurers are also increasing the pressure

The EU is no longer the only authority critically assessing PFAS-containing products. Increasingly, product liability and environmental liability insurers are demanding the removal or significant reduction of PFAS in products. The reason lies in long-term liability and recourse risks that are difficult for insurers to quantify.

Applications containing PFAS are often associated with potential legacy contamination, future regulatory tightening, and hard-to-predict follow-up costs in the event of environmental or health damage. As a result, PFAS-free material concepts are increasingly viewed as a risk mitigation measure and are indirectly required during contract negotiations or policy renewals.


4. Why the discussion must be conducted in a differentiated manner

It is important to note that the current debate does not only concern “classically critical” PFAS, but potentially also fluoropolymers. Many industries argue that fluoropolymers differ significantly from low-molecular-weight PFAS, among other reasons due to their high molecular weight and their well-established applications, for example in medical and food technology.

We therefore advocate for a differentiated discussion in order to avoid impermissible generalizations.


5. PFAS at Zell Materials: Current applications

At Zell Materials, PFAS are used both in certain materials for modification purposes (particularly for tribological optimization) and in auxiliary substances used in production (e.g., lubricants).

Examples of modified products include:

In addition, fluoropolymers are also used directly as base polymers, for example in:


FAQ

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What is PFAS?
What is the EU PFAS initiative?
What is REACH?
What is ECHA?
What are Fluorpolymers?

Mögliche Zeitschiene

Q1/2023

Restriction dossier

(DE, NE, SE, NO, DK)

March 2025

RAC/SEAC evaluation

Fluorierced Gases, Transport- und Energysector

June 2025

RAC/SEAC evaluation

Medical devices, lubricants.

RAC only: Electronics and semiconductors.

SEAC only: Transport and energy sector.

Sept./Dec 2025

RAC/SEAC evaluation

Electronics and semiconductors, other applications

Q1/2026

60 days Consultation

for socio-economic evaluation (SEAC)


Mid of 2026

ECHA opinion




2028

Discussion in REACH-Comitee


Drafting of the European Commission’s regulatory proposal

2028

Examination

by the Council and the European Parliament of the EU


2029 - ca. 2035

Publication in the Official Journal of the European Union


Entry into force (+1.5 years) transitional periods (+5 or +12 years)


6. Current status (end of January 2026)

The revised restriction dossier has been officially published since August 2025 and forms the basis for the next steps in the REACH procedure. It outlines long-term concepts for PFAS restriction, essentially comprising three pathways: a complete ban after transitional periods, bans with time-limited derogations for applications that are difficult to substitute, and controlled use under strict emission and risk conditions.

The document now comprises more than 3,300 pages. The ECHA scientific committees RAC and SEAC are currently working on their evaluation. Opinions are expected במהלך the course of 2026 and will be decisive for the final regulatory framework.


7. Implications for semi-finished plastic products and machinable materials

For the semi-finished plastics industry, the discussion is particularly relevant. Fluoropolymers such as PTFE or PVDF are chemically classified as PFAS and are technically indispensable for many applications, for example in seals, bearings, or chemically resistant components. Should a group-wide restriction be implemented, these materials could face increased regulatory scrutiny — even if transitional periods or exemptions are предусмотрed.

Equally critical is the potential restriction of PFAS additives, such as PTFE particles used in tribologically optimized compounds. In such cases, new developments and requalification processes would be required. Another open issue concerns analytics: How can PFAS be reliably detected in semi-finished products, particularly at low concentrations? New threshold values or reporting obligations could create additional compliance hurdles at short notice.


8. Practical recommendations for designers and machinists

We recommend that our partners:

  • Review your material portfolio:
    Which semi-finished products are fluoropolymers (PTFE/PVDF/PFA/ECTFE), and which contain fluorinated additives?

     

  • Obtain supplier statements:
    Request “PFAS-free statements” / declarations of conformity — ideally product- and batch-specific. These are available from Zell Materials upon request.

     

  • Test substitution options at an early stage:
    Particularly for sliding and wear parts (bearings, guides, seals), conduct early prototyping and lifetime testing with alternative materials. Zell Materials already offers PFAS-free alternatives in some areas and is also happy to support you with material and application development where needed.

     

  • Increase design robustness:
    If the performance of PTFE cannot be replaced on a one-to-one basis, timely adjustments to the component design (geometry, surface pressure, lubrication) may enable the use of alternative materials. Zell Materials will be pleased to support you in this process.


    9. Conclusion

    2026 will be a decisive year in the restriction process, as the opinions of RAC and SEAC will form the basis for the subsequent decision by the European Commission.

    What is clear is that the regulation will not take effect overnight, but it will shape material development and innovation strategies in the semi-finished plastics industry in the long term.

    Companies that address alternatives and robust material concepts at an early stage can also view this development as an opportunity. Fluoropolymers possess strong — and in some cases still irreplaceable — properties that remain economically and technically indispensable for certain applications.

Zell Materials will therefore continue, for the time being, to pursue the development and distribution of these materials, while at the same time advancing alternatives as an opportunity for new material applications.


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