On December 11, 2019, the German Environment Agency (UBA) published a final report documenting two completed information collection activities to support the preparation of restriction proposals under REACH for two groups of per- and polyfluoroalkyl substances (PFAS). The first group investigated was long-chain perfluoroalkyl carboxylic acids (PFCAs) and the second group included short-chain PFAS. The collection also covered the salts of the chemicals in the two groups as well as precursor substances including polymers. Information was collected through literature reviews, surveys, and targeted stakeholder interviews.

The report provides a detailed description of the information found covering the chemicals’ uses and applications across various product groups, manufacturers and importers, identifications and market volumes, and fluorine free alternatives. For long-chain PFCAs, the investigation found no indication that the chemicals are used intentionally in any sector within the EU, and applications containing them as impurities were seen to be of low relevance. Overall, the report writes that “no arguments could be found that would not justify the introduction of a restriction.” For short-chain PFAS, the collected data “showed that these substances are present in a wide range of applications, in most cases as basic raw materials (building blocks) in the production of fluorinated polymers.” Stakeholders across many sectors commented that “substitution potential is limited when special properties must be met,” and the report found that a restriction on them “seems not be possible in some areas currently due to a lack of technical feasible alternatives.”


UBA (December 2019). “Potential SVHC in environment and articles – information collection with the aim to prepare restriction proposals for PFAS.”

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Chemical Watch (December 17, 2019). “Germany’s UBA publishes report on PFAS restriction proposal.”