In a letter sent on May 15, 2020, to the European Chemicals Agency (ECHA) following a consultation on a restriction proposal for perfluorohexanoic acid (PFHxA; CAS 307-24-4), its salts, and related substances, a consortium of non-governmental organizations has advocated for a much lower concentration limit for PFHxA and related substances. The NGOs support the restriction and also the grouping approach being used to restrict all PFHxA-related substances. However, they disagree with the currently proposed concentration limits of 25 and 1000 ppb, which were taken from an earlier restriction of the substance perfluorooctanoic acid (PFOA; CAS 335-67-1) and influenced by previous limitations in analytical testing methods. The NGOs argue that “testing methods have developed rapidly since the PFOA dossier was submitted and there are no constraints today for establishing a threshold of 2 ppb [(parts per billion)].” Current EU and US limits for other per- and polyflouroalkyl substances (PFAS) are in the range of 10-100 parts per trillion (ppt), and the NGOs, therefore, believe that a restriction proposal that sets several orders of magnitude higher concentration limits “should include a transparent justification on the data and scientific justification for deriving this threshold.”

The current restriction proposal also includes a number of derogations that will be granted to a range of uses for PFHxA and related substances for a limited time, including use in aqueous firefighting foams (AFFFs), personal protection equipment, and isolated intermediates. The NGO letter challenges these derogations arguing that PFHxA should be allowed for “narrowly defined essential ‘need to have’ rather than ‘nice to have’ uses where no alternatives exist.” The consortium “believe[s] that the current derogations and delayed application of the restriction include uses where feasible, cost-effective non-fluorinated alternatives are available.”

PFHxA-related substances are specifically noted in the restriction proposal as being often used in the production of paper and board intended for food contact applications. A section of the proposal outlines the use of the substances in food contact materials (FCMs) and provides examples of implemented alternatives to avoid their use. The consultation on the restriction proposal will remain open until September 25, 2020.

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European Environmental Bureau (May 13, 2020). “ARNIKA, CHEM TRUST, CLIENT EARTH, EEB and IPEN comments to the REACH restriction: PFHxA, its salts and related substances.”

ECHA (April 23, 2020). “Consultation on the proposed restriction of PFHxA.”

Leigh Stringer (May 28, 2020). “Proposed PFHxA restriction limit should be ‘several orders of magnitude’ lower.” Chemical Watch


ECHA (December 20, 2019). “Annex XV Restriction Report Proposal for a Restriction: PFHxA, its salts and related substances.”