FAQ: PFAS Banning

The proposed ban was drawn up by authorities from Germany, the Netherlands, Denmark, Norway and Sweden as part of the EU chemicals regulation REACH. The aim of the ban is to reduce the release of PFAS into the environment (source: https://www.baua.de/DE/Services/Presse/Pressemitteilungen/2023/02/pm08-23.html)

More than 5,600 comments were submitted during the consultation phase from March to September 2023. Since then, these have been discussed in subgroups and finally summarized in a joint document, which will be submitted to the European Commission as a draft decision. There is no longer a transparent timeline for this, meaning that the period for a potential ban and any exemptions or transfer periods are completely unclear as of today. 

What are PFAS?

PFAS stands for per- and polyfluoroalkyl substances, which are fluorinated compounds used in many products and industrial applications, including coatings, upholstery, textiles and more. PFAS are not naturally occurring (and have only been produced since the late 1940s). Chemically, the organic compounds consist of carbon chains of various lengths in which the hydrogen atoms are completely (perfluorinated) or partially (polyfluorinated) replaced by fluorine atoms. undefinedproducts. They are often referred to as “eternal chemicals” as they hardly degrade in nature and accumulate in animal foodstuffs and water.

It is a group of substances that comprises around 10,000 individual substances.

What should the possible PFAS ban look like?

ECHA has presented two options:

- A complete ban without exemptions (“full ban”) (RO1)

- A complete ban with use-specific, time-limited exemptions (RO2)

Option 2 is more likely, as PFAS cannot simply be replaced everywhere. 

If PFAS are included in Annex XVII of the REACH Regulation, an 18-month transitional period will begin. Once this has expired, the manufacture, import and use of PFAS as such and the placing on the market and use of PFAS as a component of a (different) substance, in mixtures or articles will be prohibited if certain concentration limits are exceeded. Under option 2 (RO2), an additional five or twelve years could be granted as a transitional period; for fields of application in which PFAS are indispensable, possibly even permanent exemptions.

What is the background to the PFAS ban?

PFAS are a large family of thousands of man-made chemicals that are widely used throughout society (e.g. in textiles, electronic devices, food contact materials, medical devices, etc.).

The majority of PFAS are persistent substances or degrade to persistent substances in the environment. Once PFAS are released, they remain in the environment for a long time.

Due to their water solubility and mobility, surface water, groundwater, drinking water and soil have been contaminated both in the EU and worldwide. It has proven difficult and extremely costly to remove PFAS once they have been released into the environment.

In addition, some PFAS have been shown to have toxic and/or bioaccumulative properties, both in terms of human health and the environment.

If no action is taken, their concentrations in the environment will continue to increase and their toxic and environmentally harmful effects will be difficult to reverse.

When can we expect the PFAS ban?

Unfortunately, this is completely unclear at the moment, as there is no longer an official timeline from ECHA. The contributions from the consultation are being discussed in the individual subgroups, and the agenda can be viewed on the ECHA website.

There is a chance that at least all subgroups will have been discussed by the end of 2025 and, at best, all will have reached a preliminary result. This must result in an overall document, which will be reviewed again by the SEAC (Social Economic Assessment Committee) and released for consultation in order to ultimately serve as a draft decision for the European Commission. The document is then adopted into active law and a transitional phase of at least 18 months begins. At the end of this phase, the ban in its negotiated and agreed form comes into force immediately.

Who is affected by the PFAS ban?

The European Chemicals Agency ECHA is examining regulation in the European REACH area. Germany would therefore be affected. Some countries in Europe are already working with individual solutions or are looking to do so in the future, as the ban at European level is too slow for them. France, for example, has decided to ban PFAS in cosmetics, among other things, and Sweden is preparing a broad ban through volume tracking of all imported PFAS.

However, PFAS are also under close scrutiny in the USA, where the state of Maine has already issued a ban on PFAS by 2030. Other US states are currently preparing limits, restrictions or bans. In addition, the US EPA (Environmental Protection Agency) has issued a directive requiring all PFAS importers and manufacturers to provide the authorities with various pieces of information from the last ten years. Further restrictions should be derived from this.

Regulatory and political pressure is already having a major impact on some manufacturers and users: 3M in California, for example, will cease PFAS production completely in 2025, and other companies will follow suit.

What options are there?

In order to best prepare for the potential ban, alternative products must be developed and qualified. In order to cope with the large quantities of parts, mergers of components into component families or the identification of very challenging parts are possible.

In addition, OEM specifications must allow and ideally require the use of PFAS-free product alternatives so that the market moves in a PFAS-free direction, even during the transition period.

Does the possible PFAS ban affect DÖRKEN corrosion protection products?

The possible PFAS ban affects DÖRKEN's corrosion protection products. Some of our coating systems from the DELTA-PROTEKT^®, DELTA^®-SEAL, DELTA-LUBE^® product lines contain industry-standard fluoropolymers (such as PTFE) as lubricants.

Does DÖRKEN already have PFAS-free alternatives?

In March 2025, DÖRKEN launched the first completely new PFAS-free products as alternatives to long-established existing products. The DÖRKEN^® BASE, DÖRKEN^® SEAL and DÖRKEN^® TOP families bundle the new PFAS-free products, including the two basecoats DÖRKEN^® BASE 105 and 120, the organic topcoats DÖRKEN^® SEAL 711 BLACK and SILVER and the inorganic DÖRKEN^® TOP 500 BLACK. More information here: GET Ready - PFAS-FREE

There are also relevant products in the portfolio that have always been PFAS-free. These include the established basecoat DELTA-PROTEKT^® KL 100 and the silver multifunctional topcoat DELTA-PROTEKT^® TC 502 GZ.

Over the next few months, further PFAS-free products will gradually be introduced to the market, so that the entire portfolio will be PFAS-free in the future.

If you require PFAS-free products for current projects, please do not hesitate to contact us. If you are interested in acting as a development partner, please also contact us.

As of: June 2025