Sustainability Insights #20

On 27 June 2025, the European Commission adopted Regulation (EU) 2025/718, updating how perfluorooctane sulfonic acid (PFOS) and its derivatives are controlled under the Persistent Organic Pollutants (POPs) Regulation. As the first PFAS ever regulated in the EU, PFOS had outdated unintentional trace contaminant thresholds. The revision brings PFOS closer to the stricter stance already applied to PFOA—and expands both scope and stringency.

What changed:

• Scope expanded: PFOS, its salts, and PFOS‑related compounds are explicitly included. (Effective: 17 July 2025)
• Test method reference removed: Mandatory CEN standard references are no longer specified.
• Plating exemption removed: PFOS can no longer be used as a mist suppressant for non‑decorative hard chromium (VI) plating.
• New limit values (apply to substances, mixtures, and articles): PFOS and its salts: ≤ 0.025 mg/kg and PFOS‑related compounds: ≤ 1 mg/kg. (Effective: 3 December 2025)

Why it’s important:

• PFOS is regulated under the EU POPs Regulation (not listed as an SVHC) and was removed from REACH Annex XVII via Regulation (EC) No. 552/2009.
• ECHA’s broader PFAS restriction proposal is progressing, with wider measures expected by 2026–2027.

What this means for brands and suppliers:

• Lower limits, wider scope: Expect more sensitive testing and tighter controls across inputs, coatings, and process aids.
• Short runway to compliance: Treat 3 December 2025 as a hard stop in specifications and supplier contracts.
• Process changes: Audit any chromium (VI) plating lines and fast-track alternatives where PFOS mists were used.

Action checklist:

• Map risk: Identify materials, chemistries, and processes where PFOS/PFOS‑related compounds may appear.
• Update specs and contracts: Include the new limit values and the removed plating exemption.
• Align testing: Ensure labs can detect at or below 0.025 mg/kg.
• Supplier engagement: Share updated requirements, request recent test data, and secure declarations.

Read the Official Regulation (EU) 2025/718

Source: European Union

PFOS, a member of the PFAS “forever chemicals,” resists breaking down in the environment and in our bodies and has been used for its water-, oil-, and heat-resistant properties in metal plating, firefighting foams, and stain‑resistant coatings for textiles and paper.

It matters because PFOS is listed as a persistent organic pollutant under the Stockholm Convention due to its persistence and potential health impacts, and because consumers and regulators are demanding greater transparency—making early action critical to reduce disruption and build trust. With tighter PFOS limits now in place and broader PFAS measures expected by 2026–2027, proactive phase‑out and adoption of safer alternatives are the new standard.

We regularly update our Product Safety Requirements to help brands eliminate hazardous substances and stay ahead of global regulations. The program unites:

• Restricted Substances List (RSL) for trims and packaging
• Manufacturing Restricted Substances List (MRSL) for production chemicals (inks, dyes, paints, surface treatments)
• Alignment with leading industry standards and evolving regulations

Highlighted Updates:

• PFAS alignment: Incorporated Regulation (EU) 2025/718 updates on PFOS across purchasing, testing, and documentation.
• VOC controls: Added to the MRSL for clearer manufacturing guidance.
• Siloxanes: Tighter oversight introduced for D-class and L-class siloxanes of concern.
• Synthetic polymer microplastics in decorative articles & Nanomaterials: Newly banned under updated safety requirements.

These updates matter because they speed compliance with ready‑to‑use specifications and supplier declarations, lower risk through detection‑appropriate testing and prioritized screening. Together, they help brands eliminate hazardous substances and stay ahead of evolving global regulations.

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