Global Outlook: PFAS developments

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Global

Throughout 2026, parties to the Stockholm Convention on Persistent Organic Pollutants (POPs) are expected to continue progress towards amending existing (or creating new) domestic legislation to fulfil their obligations relating to PFAS entries. The convention is taking an iterative approach to the regulation of PFAS. It is progressing relatively slowly, having made just four PFAS entries to date. There is, therefore, no immediate prospect of global regulation of PFAS as a class. Nevertheless, the most recent entry, for long-chain perfluorocarboxylic acids (LC-PFCAs), made in 2025, represents a significant departure, as it covers a group of PFAS (plus salts and related compounds) rather than an individual chemical.

The three older entries are for:

• perfluorooctane sulfonic acid (PFOS);

• perfluorooctanoic acid (PFOA); and

• perfluorohexane sulfonic acid (PFHxS).

Europe

By and large, Europe is the region with the broadest, most extensive PFAS regulation, with the outlook dominated by the proposed REACH universal PFAS restriction. Some member states are advancing national-level measures, but those measures are often somewhat aligned with the EU’s efforts, and there seems to be little appetite for taking the initiative from the bloc as a whole.

Consequently, if the restriction is implemented according to the original proposal, there should be a high degree of harmonisation across the bloc. That said, there are signs that the version of the restriction the European Commission puts forward may be significantly less severe than the original proposal. If this happens, those member states in favour of stronger regulation may respond with national-level measures that supersede EU legislation, making for a more uneven landscape.

EU

The REACH universal PFAS restriction proposal will pass major milestones in 2026, but the Commission is unlikely to propose draft legislation before the end of the year. In particular, ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-Economic Analysis (SEAC) are drafting opinions on the proposal. RAC is expected to adopt its opinion at its 2-6 March meeting. SEAC is expected to agree a draft opinion at its 9-13 March meeting, after which ECHA will launch a 60-day public consultation on that text. The agency will use a new consultation process created specifically for this particular restriction proposal. The consultation will invite stakeholders to respond to predetermined questions on the potential impacts of the restriction. To help companies determine which aspects of the restriction apply to their specific applications, ECHA released “use-mapping” guidance in December.

The agency should publish the final SEAC opinion by the end of 2026. The Commission is supposed to propose draft legislation within three months of receiving the RAC and SEAC opinions. It seems likely, however, that the Commission could take longer, given that the restriction proposal is much bigger and more complex than any previously submitted. The EU adopted the REACH PFAS restriction for firefighting foams in 2025. Parts of the restriction will come into force on 23 October, from which point companies will be prohibited from placing on the market portable fire extinguishers containing PFAS above 1 milligram per litre (mg/l) for the sum of all PFAS. Other parts will come into force in 2027 and beyond.

North America

The North American outlook is dominated by activity in the US, the region’s biggest economy. The US federal government is moving slowly on PFAS regulation, leading individual states to pursue stricter approaches to advance their own regulations. Maine, Minnesota and New Mexico have adopted legislation that is broad in scope, with extensive bans are on the horizon, but in other states regulation is much more limited. Consequently, the region is heading for a patchwork of different measures that will be hard for companies to track.

US

The US federal government is taking a data reporting approach, with significant deadlines in 2026. There is no immediate prospect of any broad restriction at the federal level. The TSCA PFAS reporting period is scheduled to run from 13 April to 13 October. However, industry has called for a six-month delay to avoid frustrating the aims of a 13 November EPA proposal that would reduce the proportion of companies obligated to report their PFAS uses. The PFAS Regulatory Coalition said in 2025 that, without the delay, companies might waste resources preparing for obligations that, in their case, never actually apply.

US States

Mostly, those US states that want to go beyond the federal government’s focus on reporting are advancing bans on specific uses that may be especially high-risk. A Colorado ban on the sale or distribution of products containing intentionally added PFAS comes into force on 1 January. The ban covers cleaning products, cookware, dental floss, menstrual products and ski wax. Floor maintenance cleaners used in medical settings are exempt. From 1 July, Connecticut legislation requires companies to label certain products containing intentionally added PFAS and notify the state Department of Energy and Environmental Protection (DEEP) prior to marketing them in the state.

The requirement covers:

• cleaning products;

• cookware;

• dental floss;

• non-soap cosmetics;

• menstrual products;

• ski wax;

• non-electronic children’s products;

• clothing;

• fabric furnishings;

• upholstered furniture;

• carpets and rugs; and

• textile treatments.

Under the same legislation, from 2026, PFAS-containing outdoor clothing for experts in severe wet conditions must bear the statement “made with PFAS chemicals”. From January 2026, New Jersey legislation bans the manufacture, distribution, sale or use of firefighting foam with intentionally added PFAS. The ban applies to class B foam, which is intended for fires involving flammable and combustible liquids, petroleum greases, tars, oils, oilbased paints, solvents, lacquers, alcohols or flammable gases. Manufacturers should already have informed New Jersey retailers in writing of their obligations under the statute. By April 2026, they must recall the foam and refund buyers. From 2026, Vermont legislation passed in 2024 bans the manufacture, sale or distribution of some products containing intentionally added PFAS. The ban covers disposable incontinence pads, cookware, children’s products, and textiles if the PFAS concentration exceeds 100ppm. The textiles threshold will drop to 50ppm from 1 July 2027. In addition, from 1 January 2026, the legislation bans the installation of synthetic turf with PFAS. While some US states are moving to restrict specific uses, a handful of others are considering stricter measures. Maine has led the way with a universal restriction that will eventually phase out all products containing intentionally added PFAS, except for “currently unavoidable uses” (CUU).

From 1 January, the ban will cover:

• cleaning products;

• cookware;

• cosmetics;

• dental floss;

• juvenile and menstrual products;

• ski wax;

• upholstered furniture; and

• certain textile articles.

Minnesota and New Mexico have followed with similarly broad measures. In 2025, Minnesota extended the deadline for its rule requiring manufacturers to report on the sale of products containing intentionally added PFAS, part of Amara’s Law targeting the class. The deadline was originally 1 January in the draft rule, but the Minnesota Pollution Control Agency (MPCA) changed it to 1 July in the final rule, adopted on 8 December, to allow more time for development of the reporting platform. The approach in New Mexico is somewhat different again, with regulators considering a potentially broad labelling scheme.

Canada

In 2025, Canada proposed to regulate PFAS as a class, via a three-phase approach that would first restrict the compounds in firefighting foams, before limiting their use in cosmetics, food packaging, textiles and other products. Under the plans, the government would add 163 PFAS to the country’s National Pollutant Release Inventory (NPRI), thereby imposing reporting requirements on facilities that handle the substances. The first reports, covering 2025, would be due on 1 June

Rest of the world

Outside of Europe and North America, the regulatory pace is generally much slower. Mostly, countries are focused on the handful of legacy PFAS listed under the Stockholm Convention, and even then, only in certain applications. Singapore, for example, will phase out the import and use of firefighting foams containing PFOA and PFOS from 1 January 2026. New Zealand is going further by implementing legislation that addresses PFAS generally. A ban on the import and manufacture of cosmetic products containing PFAS will apply from 31 December. Selling PFAS-containing products will be legal until 31 December 2027. The country also recently reached the final stage of its regulatory programme to phase out PFAS-containing firefighting foams. A complete ban came into effect on 3 December 2025. Australia ran a data gathering exercise in 2025, requesting information on 522 PFAS to determine how they are used in the jurisdiction.