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Regulation

PFAS Restrictions and Plastic Additives: 13 Rules and 5 Affected Additives

Regulatory status verified: 22 September 2026.

PFAS restrictions reach plastics through five additives, not through the polymer itself: fluoropolymer processing aids, anti-drip PTFE, PTFE micropowder lubricants, the KPFBS flame retardant and HFO blowing agents that carry a CF3 group. Thirteen instruments in the European Union, the United States and the Stockholm Convention now touch at least one of the five, so which of the thirteen actually binds a compounder today?

The European Union has not banned PFAS as a class. The Packaging and Packaging Waste Regulation's food-contact limits have applied since 12 August 2026, at 25 ppb for a single targeted PFAS, 250 ppb for their sum and 50 ppm for total PFAS including polymeric PFAS, under Article 5(5) of Regulation (EU) 2025/40. The proposed universal restriction under REACH sits at an earlier stage: the Committee for Risk Assessment adopted its final opinion on 2 March 2026, as reported by the law firm Arnold & Porter, which tracked the committee meetings, and the Committee for Socio-Economic Analysis is expected to deliver its final opinion at the end of 2026.

This page maps every rule to the additive it actually reaches, starting with the definition of a PFAS in plastic additives law, the five affected additive uses, the complete list of 13 instruments, the pending EU-wide restriction, the EU limits already in force, the United States rules, how to check a compound for PFAS, what replaces each additive and a compliance calendar running from 2025 to 2033.

Table T1. The 5 plastic additives that are PFAS.

Additive Chemical Class Where It Is Used Status Under PFAS Rules
Fluoropolymer processing aid (PPA) Fluoroelastomer, VDF-HFP copolymer Polyethylene blown and cast film, pipe, wire and cable In scope of the proposed universal restriction; counts toward the PPWR 50 ppm total-PFAS limit in food-contact packaging; reportable under TSCA 8(a)(7)
Anti-drip PTFE Fluoropolymer Flame-retarded PC and PC/ABS, UL 94 V-0 grades In scope of the proposed universal restriction; not on the SVHC Candidate List
PTFE micropowder Fluoropolymer Wear and friction grades of POM, PA and other engineering plastics In scope of the proposed universal restriction; also caught by REACH entry 78 as a polymeric powder
KPFBS (PFBS-K, Rimar salt) Perfluoroalkyl sulfonate salt Transparent flame-retarded polycarbonate SVHC since 16 January 2020 under the group entry "PFBS and its salts"; in scope of the proposed universal restriction
HFO blowing agents Hydrofluoroolefins with a CF3 group Rigid polyurethane and insulation foam Within the OECD PFAS definition; F-Gas Regulation bans F-gas foams from 1 January 2033; EU PFAS-restriction scope not settled

Status as of 22 September 2026. "Proposed" means that no legal obligation follows from it yet.

Are Plastic Additives Covered by PFAS Restrictions?#

Yes: plastic additives are covered wherever the additive itself is a per- or polyfluoroalkyl substance, which in practice means the five fluorinated additives above, while the base polymers polyethylene, polypropylene, PVC, PET and polycarbonate are not PFAS and are not covered. The regulations that use the term PFAS, from the packaging limit to the proposed universal restriction, reach a compound only through what has been intentionally added to it, not through the polymer that carries the additive.

So where does the line run between a PFAS additive and an ordinary plastic? The distinction is structural, not commercial: an additive counts as a PFAS once it contains at least one fully fluorinated carbon atom, no matter how small its dose in the finished compound, while a polyolefin, PVC, PET or polycarbonate backbone does not, because none of the five base polymers meets that structural test. That single distinction is why a polyethylene film dosed with a few hundred parts per million of a fluoropolymer processing aid is, in the regulatory sense, a PFAS-containing article, even though the polymer resin itself carries no fluorine at all.

What counts as a PFAS in a plastic?#

EU law defines a PFAS by structure: a substance that contains at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom, subject to listed exclusions, which is the wording Regulation (EU) 2025/40 uses in Article 5(5). That structural test, not a product category or a brand name, is what every instrument on this page ultimately applies to a plastic additive.

The same article splits that definition into two separate measurements. A targeted analysis looks for 25 ppb of any single named PFAS and 250 ppb for their sum, and it excludes polymeric PFAS, large fluoropolymer molecules such as a processing aid or anti-drip PTFE, from that count entirely. A total-PFAS measurement of 50 ppm includes polymeric PFAS in full. That split decides whether a food-contact polyethylene film passes: a fluoropolymer processing aid is a polymeric PFAS, so it is invisible to the 25 ppb targeted limit and counted completely toward the 50 ppm total, the number that actually constrains the dose a compounder can use. KPFBS, the small perfluoroalkyl sulfonate salt used in polycarbonate, sits on the other side of the split: it is a non-polymeric PFAS, so it falls inside the targeted analysis rather than only the total count.

Which plastic additives are PFAS?#

Five additive uses in plastics are per- or polyfluoroalkyl substances: fluoropolymer processing aids, anti-drip PTFE, PTFE micropowder lubricants, the KPFBS flame retardant for transparent polycarbonate, and HFO blowing agents that carry a CF3 group. Each of the five sits in a different polymer at a different dose, and together they are the only route by which a plastics formulation, rather than a finished consumer product, contains a PFAS.

  1. Fluoropolymer processing aids, dosed at parts-per-million level in polyethylene film.
  2. Anti-drip PTFE, dosed at 0.05 to 10 phr in flame-retarded polycarbonate and PC/ABS.
  3. PTFE micropowder, blended as a solid lubricant into POM, polyamide and other engineering plastics.
  4. The KPFBS flame retardant, used at ultra-low loadings in transparent polycarbonate.
  5. HFO blowing agents with a CF3 group, used in rigid polyurethane and insulation foam.

Is PTFE a PFAS?#

Yes: polytetrafluoroethylene (CAS 9002-84-0) is a fluoropolymer and therefore sits inside the PFAS group, even though it is not on the REACH Candidate List of substances of very high concern. PTFE, ECHA list number 618-337-2, has the repeating unit (C2F4)n and falls within the scope of the proposed universal PFAS restriction, whose Annex XV dossier ECHA published on 7 February 2023. Whether a fluoropolymer such as PTFE should be treated as a polymer of low concern is an active scientific and industry dispute that our source library does not adjudicate; the regulatory fact is that the proposed restriction covers fluoropolymers and the Candidate List does not list PTFE, and identity, grades and the full regulatory matrix for the substance are covered separately by PTFE as a plastic additive.

The 5 Plastic Additives That PFAS Rules Reach#

The five fluorinated additives differ in everything that matters for compliance: the level at which they are dosed, the polymer they sit in, whether they are polymeric PFAS, and which of the 13 instruments reaches them first. The sections below take them in the order that matches how many converters they touch, from the fluoropolymer processing aid used across blown and cast polyethylene film to the HFO blowing agent used only in rigid insulation foam.

1. Fluoropolymer processing aids in polyethylene film#

A fluoropolymer processing aid is a vinylidene fluoride-hexafluoropropylene fluoroelastomer (CAS 9011-17-0, EC 618-470-6) dosed at parts-per-million level in polyethylene film to remove sharkskin melt fracture, and it is delivered as a 2 to 5 percent masterbatch. Immiscible fluoropolymer droplets migrate to and coat the die wall under flow, and the low-energy coating induces interfacial slip of the polyolefin melt, raising the critical output at which sharkskin appears, a mechanism described by Kharchenko and colleagues in 2003 and confirmed by Yang and colleagues in 2025. The US clearance under 21 CFR 177.1520 caps the fluoropolymer content of the finished polymer at 0.2 weight percent for the 65 to 71 percent fluorine grade with a Mooney viscosity of at least 28, and at 1.0 weight percent for the grade with at least 87 percent vinylidene fluoride.

It is a polymeric PFAS, so it is excluded from the PPWR's 25 ppb targeted limit and fully counted in the 50 ppm total-PFAS limit that has applied to food-contact packaging since 12 August 2026; it is also within the scope of the proposed universal restriction, and it is reportable under TSCA section 8(a)(7). On 20 December 2022, 3M announced that it would leave PFAS manufacturing, including fluoropolymers and PFAS-based additive products, by the end of 2025, which removes a significant share of supply independent of how the restriction itself is decided. The full mechanism and dosage range for fluoropolymer processing aids are covered on the family page.

2. Anti-drip PTFE in flame-retarded polycarbonate and PC/ABS#

Anti-drip PTFE is a fluoropolymer added at 0.05 to 10 phr, most often near 0.1 phr and usually SAN-encapsulated, to stop a flame-retarded polycarbonate or PC/ABS from dripping during the UL 94 test. A 2024 study combining 20 weight percent BAPDP with 0.4 weight percent PTFE reached UL 94 V-0 in PC/ABS, inside that same patent range. The additive is commonly supplied as TSAN, SAN-encapsulated PTFE in ratios from 40/60 to 60/40 PTFE to SAN, to avoid the fibrous agglomerates that plain PTFE powder forms and to improve its dispersion in the melt.

No dedicated PFAS restriction applies to anti-drip PTFE today, and it is not on the SVHC Candidate List; it sits within the scope of the proposed universal restriction, which is why every flame-retarded polycarbonate formulation is being re-examined. PTFE itself is not an Annex I entry of EU Regulation No 10/2011, which lists starting substances rather than fluoropolymers, though its monomer tetrafluoroethylene is authorised as FCM substance No 281 (CAS 116-14-3) for monomer use only, with a specific migration limit of 0.05 mg/kg. The full V-0 package for the same polymer is covered on flame retardants for polycarbonate.

3. PTFE micropowder as a lubricant and tribological additive#

PTFE micropowder is a low-molecular-weight fluoropolymer powder blended into POM, polyamide and other engineering plastics as a solid lubricant that lowers friction and wear. It is one of four tribological additives used this way, alongside silicone, molybdenum disulfide and graphite, and wear and friction data for all four solid lubricants are compared on that family page.

Two rules reach it: the proposed universal restriction, and REACH Annex XVII entry 78, under which polymeric powder additives such as PTFE micropowder have carried supplier information duties since 17 October 2025 and face annual reporting to ECHA by 31 May from 2026, a duty staged in under Regulation (EU) 2023/2055 from 17 October 2023. The same entry's information and reporting duties for polymeric microparticles generally are set out on the EU microplastics restriction page.

4. KPFBS flame retardant in transparent polycarbonate#

KPFBS, potassium nonafluorobutane-1-sulfonate (CAS 29420-49-3, EC 249-616-3, C4F9KO3S, molecular weight 338.19), is the perfluoroalkyl sulfonate flame retardant used at very low loadings in transparent polycarbonate, where it migrates to the surface and catalyses charring. LANXESS sells it under the trade name Bayowet C4, and the substance is also known as PFBS-K or Rimar salt. Full identity, grades and hazard data for the substance are recorded under PFBS-K (Rimar salt).

It is the only one of the five additives already on the SVHC Candidate List, listed on 16 January 2020 through the group entry "PFBS and its salts" on grounds of an equivalent level of concern for human health and the environment under Article 57(f), so it carries the REACH Article 33 communication duty above 0.1 percent by weight in an article; it is also within the scope of the proposed universal restriction. Two named alternatives exist in our source library, KSS and BDP, though KSS deserves a direct disambiguation: KSS, potassium 3-(phenylsulfonyl)benzenesulfonate (CAS 63316-43-8, EC 264-097-3), is a different substance, is not a PFAS and is not an SVHC, despite sitting on the same substitution shortlist as KPFBS. Every listed additive, including this one, is tracked on the SVHC Candidate List page.

5. HFO blowing agents with a CF3 group#

HFO-1233zd(E) and HFO-1336mzz(Z) are hydrofluoroolefin blowing agents for rigid insulation foam with 100-year global warming potentials of 3.88 and 2.08, and both carry a CF3 group that places them inside the OECD definition of PFAS. Both values are set out in Annex II, section 1 of the F-Gas Regulation (EU) 2024/573. In the United States, both grades carry a GWP below 150 and sit outside the foam limits of 40 CFR 84.54. Grades and GWP values for both are covered on HFO blowing agents.

The binding date is the F-Gas Regulation's ban on foams containing fluorinated greenhouse gases from 1 January 2033, under Annex IV point 17(c), with an exception where a fluorinated gas is required to meet safety requirements. Whether the proposed universal PFAS restriction also covers HFO-1233zd(E) and HFO-1336mzz(Z) is not settled. The foam-specific dates and the US AIM Act are set out on F-Gas rules for foam blowing agents.

Table T2. Identity and level of the 5 fluorinated additives.

# Additive CAS / EC Function Polymer and Typical Level Polymeric PFAS? Non-PFAS Option We Document
1 Fluoroelastomer processing aid 9011-17-0 / 618-470-6 Melt-fracture control PE film, ppm level, 2-5% masterbatch Yes Polyether-grafted PDMS, boron nitride, TPU and modified polyolefin masterbatches
2 Anti-drip PTFE 9002-84-0 / 618-337-2 Anti-dripping (UL 94 V-0) FR PC and PC/ABS, 0.05-10 phr, 0.1 phr common Yes None recorded
3 PTFE micropowder 9002-84-0 / 618-337-2 Solid lubricant POM, PA and other engineering plastics Yes Silicone, molybdenum disulfide, graphite
4 KPFBS (PFBS-K, Rimar salt) 29420-49-3 / 249-616-3 Flame retardant Transparent PC, ultra-low dose No (non-polymeric) KSS, BDP
5 HFO-1233zd(E) / HFO-1336mzz(Z) no single CAS Physical blowing agent Rigid PU / insulation foam No (non-polymeric) Not established in our source library

Row 1: the fluoroelastomer processing aid has its own substance record.

Complete List of PFAS Restrictions That Reach Plastic Additives#

Thirteen instruments reach a plastic additive that is a PFAS: ten in the European Union, one global treaty, and two United States measures, one federal and one made of state product bans.

Table T3. All 13 rules that reach plastic additives.

# Rule Jurisdiction What It Covers for Plastic Additives Limit Status and Date Guide
1 Universal PFAS restriction under REACH (Annex XV dossier, DE/DK/NL/NO/SE, submitted 13 Jan 2023, updated 2025) EU About 10,000 PFAS, including fluoropolymers, fluoroelastomers and HFO blowing agents No limit set; options under review PROPOSED This page
2 PPWR, Regulation (EU) 2025/40, Article 5(5) EU Food-contact packaging 25 ppb single / 250 ppb sum / 50 ppm total IN FORCE since 12 Aug 2026 PPWR
3 REACH Annex XVII entry 68 (C9-C14 PFCAs), Reg. (EU) 2021/1297 EU C9-C14 perfluorocarboxylic acids in articles 25 ppb sum; 260 ppb related substances IN FORCE since 25 Feb 2023 REACH Annex XVII
4 REACH Annex XVII entry 79 (PFHxA and related substances), Reg. (EU) 2024/2462 EU Consumer textiles, footwear, paper FCM, mixtures, cosmetics 25 ppb / 1,000 ppb SCHEDULED, 10 Oct 2026 REACH Annex XVII
5 REACH Annex XVII entry 82 (firefighting foams), Reg. (EU) 2025/1988 EU PFAS in firefighting foams 1 mg/L sum SCHEDULED, 23 Oct 2030, transitions to 2035 REACH Annex XVII
6 REACH Annex XVII entry 78 (synthetic polymer microparticles), Reg. (EU) 2023/2055 EU Polymeric powder additives, incl. PTFE micropowder 0.01% by weight IN FORCE, staged from 17 Oct 2023 EU microplastics restriction
7 SVHC Candidate List (PFOA, PFHxS, "PFBS and its salts" and further PFAS entries) EU Substance-level hazard listing; Art. 33 communication duty 0.1% w/w in an article IN FORCE SVHC Candidate List
8 POPs Regulation (EU) 2019/1021 (PFOS, PFOA, PFHxS) EU Legacy fluoropolymer-manufacture residues Prohibition or restriction per listing IN FORCE POPs in plastics
9 Toy Safety Regulation (EU) 2025/2509, Annex II Part III point 5 EU Intentional use of PFAS in toys Prohibited SCHEDULED, 1 Aug 2030 EU Toy Safety Regulation
10 F-Gas Regulation (EU) 2024/573, Annex IV point 17(c) EU Foams containing fluorinated greenhouse gases Banned unless required for safety SCHEDULED, 1 Jan 2033 F-Gas rules
11 Stockholm Convention (PFOS COP-4, PFOA SC-9/12, PFHxS SC-10/13, long-chain PFCAs SC-12/12) Global Legacy residues, binds Parties, not the US Listing-specific IN FORCE pops.int
12 FDA food contact: authorised uses of PFAS, 21 CFR 177.1520 and the FCN route US federal Manufacturing aids for food-contact polymers 0.2 wt% / 1.0 wt% by grade IN FORCE FDA food contact rules
13 TSCA section 8(a)(7) PFAS reporting (40 CFR 705) plus Maine 38 MRSA §1614, Minnesota Minn. Stat. 116.943, Washington ch. 173-337 WAC (sub-rows 13a-13d) US federal and states One-time retrospective reporting; state product bans Reporting duty; sale prohibitions IN FORCE, staged to 2032 TSCA / US state laws

Only one of the thirteen, the universal restriction under REACH, is still a proposal; the other twelve are law, and each has its own guide in plastic additive regulations, while every substance named here has a record in the plastic additives database.

The EU Universal PFAS Restriction: What Is Proposed and Where It Stands#

The universal PFAS restriction is a restriction proposal under REACH, not a ban in force: five national authorities submitted the Annex XV dossier on 13 January 2023 and updated it in 2025, and no legal obligation follows from it yet. The restriction route is one of four REACH instruments described on REACH and plastic additives, alongside the Candidate List, Annex XIV authorisation and the individual Annex XVII entries that already bind named PFAS. If the Committee for Socio-Economic Analysis's final opinion supports the restriction as currently proposed, the European Commission drafts an implementing act and the REACH Committee votes on it, the next two steps after September 2026.

What the Annex XV dossier covers#

The Annex XV dossier proposes a group restriction on about 10,000 per- and polyfluoroalkyl substances, covering manufacture, placing on the market and use, with time-limited derogations for uses where no alternative exists. The substances named among that group include fluoropolymers, specifically anti-drip PTFE in flame-retarded polycarbonate and PC/ABS, fluoropolymer processing aids and PVDF, fluoroelastomers as a class, and HFO blowing agents that carry a CF3 group. The dossier was submitted by five national authorities, Germany, Denmark, the Netherlands, Norway and Sweden, which places every plastics use named on this page inside the group the restriction targets, not only the small-molecule PFAS that dominate consumer coverage.

The 2025 update added four separate manufacturing restriction options for the authorities to choose between. The figure of about 10,000 substances and the four-option structure come from the dossier record itself, and both are kept approximate here because the dossier's own substance count is a working estimate rather than a fixed list. A derogation, where granted, buys a use additional time to comply rather than exempting it permanently, which is the distinction that separates a derogated PFAS use from one that is simply out of scope.

Where the dossier stands in September 2026#

As of 22 September 2026 the restriction is still pending: the Committee for Risk Assessment adopted its final opinion on 2 March 2026 and the Committee for Socio-Economic Analysis agreed a draft opinion on 10 March 2026, published on 26 March 2026 for consultation until 25 May 2026. The Risk Assessment Committee's opinion supports a full ban, granting the proposed derogations only for personal protective equipment, a narrower carve-out than the dossier itself requested. The Socio-Economic Analysis Committee's opinion remains a draft at this stage, and its final opinion is expected at the end of 2026.

After that final opinion is delivered, the European Commission prepares a draft implementing act and the REACH Committee votes on it, the two steps that stand between a final SEAC opinion and a legally binding restriction, with no date fixed for either yet. The dates in this section are reported as tracked by the law firm Arnold & Porter, not as an ECHA publication, and this page re-verifies them against echa.europa.eu at each update; if ECHA's own record is unreachable at that time, only the month, March 2026, is kept. Nothing on this page states that the European Union has banned PFAS, because no restriction is in force yet, only a dossier under review.

What a universal restriction would mean for a compounder#

If the restriction is adopted in the form the Risk Assessment Committee supports, a compounder would have to replace five additive functions rather than five products: melt-fracture control, anti-dripping, solid lubrication, low-dose flame retardancy in transparent polycarbonate, and part of the insulation-foam blowing-agent range.

  • Reformulation and requalification of every affected grade.
  • New food-contact documentation where the substitute has a different FDA or EU status.
  • Supply-chain due diligence on masterbatch and compound imports.
  • Line trials, because the die-wall mechanism of the incumbent PPA is not reproduced by every alternative.

That would-scenario rests on two limits worth naming. The incumbent fluoropolymer processing aid has no single drop-in substitute across every grade, and the incumbent itself is not without limits of its own: a fluoropolymer PPA did not eliminate stick-slip in HDPE in a 2015 study by Adesina and colleagues, where gross melt fracture reappeared at a shear rate of 141 per second even at a 0.05 weight percent dose. Commercial PFAS-free alternatives already exist for several of the five functions, and 3M's exit from PFAS manufacturing by the end of 2025 removes a share of the incumbent supply regardless of how the restriction itself is decided, so the substitution work above is already under way independent of the restriction's outcome.

Which EU PFAS Limits Already Apply to Plastics?#

Six EU instruments already restrict PFAS in ways that reach plastics, and only one of them, the packaging regulation, sets a number a compounder can test a finished film against. The other five set thresholds for named substance groups, residues or firefighting foam rather than for a plastics formulation directly.

Table T4. EU limit values.

Instrument Substance Scope Limit Applies From
PPWR Art. 5(5), targeted Any single targeted PFAS in food-contact packaging 25 ppb 12 Aug 2026
PPWR Art. 5(5), sum Sum of targeted PFAS 250 ppb 12 Aug 2026
PPWR Art. 5(5), total Total PFAS including polymeric PFAS 50 ppm 12 Aug 2026
Annex XVII entry 68 C9-C14 PFCAs 25 ppb sum; 260 ppb related substances 25 Feb 2023
Annex XVII entry 79 PFHxA, its salts and related substances in consumer textiles, footwear, paper food-contact materials, consumer mixtures and cosmetics 25 ppb / 1,000 ppb 10 Oct 2026
Annex XVII entry 82 PFAS in firefighting foams 1 mg/L sum 23 Oct 2030
Annex XVII entry 78 Synthetic polymer microparticles, including polymeric powder additives 0.01 % by weight Staged from 17 Oct 2023

PPWR: PFAS limits in food-contact packaging since 12 August 2026#

Since 12 August 2026, food-contact packaging placed on the EU market may not contain more than 25 ppb of any single targeted PFAS, 250 ppb of the sum of targeted PFAS, or 50 ppm of total PFAS including polymeric PFAS, under Article 5(5) of Regulation (EU) 2025/40. Regulation (EU) 2025/40 was published in the Official Journal on 22 January 2025 and became applicable on 12 August 2026, the date every PPWR PFAS limit on this page carries. The other Article 5 limits are on the EU Packaging and Packaging Waste Regulation (PPWR) page, alongside the regulation's 100 mg/kg heavy-metal sum and its recycled-content targets.

The consequence for additives runs through the same split described earlier: a fluoropolymer processing aid is a polymeric PFAS, so it is invisible to the targeted analysis and fully counted in the 50 ppm total, while a total-fluorine screen above 50 mg/kg moves the burden of proof onto the supplier, who must then show on request whether the fluorine detected is PFAS or non-PFAS in origin. That single screen decides whether a food-contact PE film needs targeted PFAS analysis at all, because a result under 50 mg/kg total fluorine closes the question. Article 5(4) of the same regulation, for context, limits the sum of lead, cadmium, mercury and hexavalent chromium in packaging to 100 mg/kg, a separate limit that applies from the same date but reaches metal-based additives rather than PFAS. The whole package recipe for a food-contact film, including the barrier, slip and oxygen-scavenger functions that PFAS limits do not touch, is set out on additives for food packaging.

REACH Annex XVII entries 68, 79 and 82#

Three Annex XVII entries restrict named PFAS groups: entry 68 for C9 to C14 perfluorocarboxylic acids since 25 February 2023, entry 79 for PFHxA from 10 October 2026, and entry 82 for PFAS in firefighting foams from 23 October 2030. Entry 68 sets 25 ppb sum and 260 ppb for related substances under Regulation (EU) 2021/1297. Entry 79 sets 25 ppb and 1,000 ppb for consumer textiles, footwear, paper food-contact materials, consumer mixtures and cosmetics under Regulation (EU) 2024/2462. Entry 82 prohibits a sum of 1 mg/L of PFAS in firefighting foams under Regulation (EU) 2025/1988, with a transition period running to 2035.

None of the three names a plastic additive directly. They matter to additive suppliers as impurity and residue limits rather than as formulation choices, and entry 82 matters as precedent, because it is the first Annex XVII entry written with an OECD-style PFAS definition, the same structural test the PPWR and the universal restriction proposal both use. REACH Annex XVII entries now run to 83, and entries 23, 50, 51, 52 and 63, covering cadmium, several phthalates and lead in PVC, are covered on REACH Annex XVII restrictions.

POPs Regulation: PFOS, PFOA and PFHxS#

PFOS, PFOA and PFHxS are persistent organic pollutants under Regulation (EU) 2019/1021, and they reach plastics as residues of fluoropolymer manufacture rather than as additives in their own right. PFOS was listed at the Stockholm Convention's fourth Conference of the Parties in 2009; PFOA followed at COP-9 in 2019 (SC-9/12) and was implemented in the EU by Delegated Regulation (EU) 2020/784; PFHxS followed at COP-10 in 2022 (SC-10/13) and was implemented by Delegated Regulation (EU) 2023/1608; long-chain PFCAs were listed at COP-12, held from 28 April to 9 May 2025 (SC-12/12). The United States is not a Party to the Stockholm Convention, so none of the four listings binds it directly.

PFOA carries its own additional EU record: it has been an SVHC since 20 June 2013 on the grounds of reproductive toxicity and PBT properties under Article 57(c) and 57(d), and in California it is listed under Proposition 65 for developmental toxicity since 10 November 2017 and for cancer since 25 February 2022. None of the three is a plastic additive in the sense this page uses the word; PFOA in particular is a historic fluoropolymer polymerisation aid, not a substance added to a compound for function, and it carries no dedicated substance page on this site for that reason. The other plastics POPs, including UV-328 and Dechlorane Plus, are covered on POPs in plastics.

Toys and foams: the Toy Safety Regulation and the F-Gas Regulation#

Two further EU acts set PFAS dates a compounder has to plan for: the Toy Safety Regulation (EU) 2025/2509 prohibits the intentional use of PFAS in toys from 1 August 2030, and the F-Gas Regulation (EU) 2024/573 bans foams containing fluorinated greenhouse gases from 1 January 2033. Regulation (EU) 2025/2509 was adopted on 26 November 2025, published in the Official Journal on 12 December 2025, entered into force on 1 January 2026, and its PFAS prohibition under Annex II Part III point 5 applies from 1 August 2030. The F-Gas Regulation reaches a different plastics application, rigid insulation foam, through Annex IV point 17(c), which bans foams containing fluorinated greenhouse gases from 1 January 2033 unless the gas is required to meet safety requirements.

Both dates sit years ahead of the PPWR's 2026 packaging limits, which is why a toy or foam formulation has more time to requalify than a food-contact film does. The CMR and bisphenol bans set out in the same Toy Safety Regulation are covered on EU Toy Safety Regulation.

PFAS Rules for Plastic Additives in the United States#

There is no federal United States ban on PFAS in plastics: the federal layer is a food-contact authorisation list at the FDA and a reporting rule at the EPA, while the actual product bans come from individual states. Three federal-level measures and three state laws make up that matrix on this page: the FDA authorisation list governs which PFAS uses remain permitted in food-contact plastics, the EPA's TSCA reporting rule applies retrospectively back to 2011, and the product bans are enacted separately by Maine, Minnesota and Washington, each phasing in named product categories first and moving toward an economy-wide ban on a fixed date unless a use qualifies as a currently unavoidable one.

Table T5. US measures.

Measure Agency Scope for Plastic Additives Duty Date
Authorised uses of PFAS in food contact FDA Fluoropolymer PPAs remain authorised as manufacturing aids for other food-contact polymers Comply with the 21 CFR 177.1520 conditions of use, or hold an effective FCN 35 grease-proofer FCNs determined no longer effective, January 2025
TSCA section 8(a)(7), 40 CFR 705 EPA PFAS and PFAS-containing articles manufactured or imported since 1 January 2011 One-time retrospective report Submission period opens 31 January 2027 or 60 days after the scope-revision rule, whichever is earlier
Maine 38 MRSA §1614 Maine DEP Intentionally added PFAS in listed product categories No sale of listed products 1 January 2026 categories; all products 1 January 2032 unless a currently unavoidable use
Minnesota Minn. Stat. 116.943 (Amara's Law) MPCA 11 product categories, then all products No sale; reporting and one-time fee of USD 800 Reports due 15 September 2026; all products 1 January 2032 unless a currently unavoidable use
Washington ch. 173-337 WAC WA Ecology PFAS in carpets, rugs, treatments, leather and textile furnishings, plus the Cycle 1.5 categories No sale; reporting Cycle 1 from 1 January 2025; Cycle 1.5 from 1 January 2027

FDA food contact: which PFAS uses are still authorised#

The FDA has not withdrawn the food-contact authorisation that matters to plastics: fluoropolymer processing aids remain authorised as manufacturing aids for other food-contact polymers, at up to 0.2 weight percent for the 65 to 71 percent fluorine grade and 1.0 weight percent for the high-VDF grade under 21 CFR 177.1520. Two further use categories remain authorised at the federal level, non-stick cookware coatings and sealing gaskets in food-processing equipment, both outside the plastics-additive scope this page covers. The FDA has never issued a blanket PFAS approval; each use sits inside its own regulation or Food Contact Notification, so a compound complies with 21 CFR 177.1520 for olefin polymers or is the subject of an effective FCN, not "FDA approved" in the way that phrase is used for a drug.

What did change: 35 Food Contact Notifications for grease-proofing agents were declared no longer effective in January 2025, after the market exit for those uses was announced in February 2024, and fluorinated HDPE containers are under FDA review following a July 2022 request for information. The 21 CFR sections that set the remaining fluoropolymer limits are mapped in full on FDA food contact rules.

TSCA section 8(a)(7): reporting PFAS and PFAS-containing articles#

Section 8(a)(7) of the Toxic Substances Control Act requires everyone who manufactured or imported PFAS, or articles containing PFAS, since 1 January 2011 to file a one-time retrospective report under 40 CFR 705. The rule was finalised on 11 October 2023, and the reporting window itself has moved twice. A May 2025 interim final rule set the submission window from 13 April to 13 October 2026, with small article importers given until 13 April 2027, before an April 2026 final rule, effective 13 April 2026 and published at 91 FR 18786, moved the start of the window to 31 January 2027 or 60 days after the effective date of a forthcoming scope-revision rule, whichever comes first. That scope revision, proposed in November 2025, would exempt PFAS present at or below 0.1 percent in mixtures, PFAS in imported articles, byproducts, impurities, research-and-development uses and non-isolated intermediates; the comment period closed on 29 December 2025 and the revision was still pending on 22 September 2026.

Importers of fluoropolymer-PPA masterbatch and of PTFE-containing compounds are the plastics-side addressees of this reporting duty. Risk evaluations and the PBT rules that sit alongside this reporting requirement are covered on TSCA and plastic additives.

State laws: Maine, Minnesota and Washington#

Three states set the pace: Maine, Minnesota and Washington all ban intentionally added PFAS in named product categories and then move to economy-wide bans, Maine and Minnesota both from 1 January 2032 unless a use qualifies as a currently unavoidable use. Maine's law, 38 MRSA section 1614, started with carpets, rugs and fabric treatments on 1 January 2023, added cleaning products, cookware, cosmetics, dental floss, juvenile products, menstruation products, textile articles, ski wax and upholstered furniture on 1 January 2026, and reaches artificial turf and outdoor apparel for severe wet conditions on 1 January 2029, before all products on 1 January 2032; HVAC-R equipment follows in 2040, and the rule defining the currently-unavoidable-use exemption took effect on 7 October 2025.

Minnesota's Amara's Law, Minn. Stat. 116.943, restricts 11 product categories from 1 January 2025 and reaches all intentionally added PFAS from 1 January 2032 on the same currently-unavoidable-use basis; its reporting and fee rule was adopted on 8 December 2025, initial reports are due 15 September 2026 with a 90-day extension available to 14 December 2026, and the one-time fee is USD 800. Washington's Safer Products program, chapter 173-337 WAC, restricted PFAS in carpets, rugs, treatments, leather and textile furnishings from 1 January 2025, and its Cycle 1.5 amendment, effective 21 December 2025, adds further restrictions from 1 January 2027 with reporting from 1 January 2026. Further states, among them Vermont, Colorado, Connecticut, New Mexico, Rhode Island and Maryland, have their own PFAS or flame-retardant product laws; the phthalate and flame-retardant state rules for all of them are set out on US state laws on plastic additives.

How Do You Find Out Whether a Compound Contains PFAS?#

A PFAS check on a plastic compound starts with the recipe, not with the laboratory: four of the five fluorinated additives are identifiable from a single CAS number on the supplier's declaration. That declaration route works faster than any test, because the additive's CAS number and chemical class settle the question directly, while a Declaration of Compliance for a food-contact film has to be read for what it actually states rather than assumed to cover PFAS by default, since the EU 10/2011 additive route for the fluoroelastomer processing aid is not established in our source library beyond its two monomer entries. The check runs in four steps.

  1. Read the formulation for the five additive functions named on this page.
  2. Ask each additive supplier for the CAS number and the chemical class in writing.
  3. Screen the finished compound for total fluorine; above 50 mg/kg the PPWR moves the burden of proof onto you.
  4. Run targeted PFAS analysis only where the screen or the formulation gives a reason.

What a supplier must actually state, rather than imply, in that written declaration is set out on declaration of compliance. Methods and detection limits for the targeted and total-fluorine routes are set out on PFAS testing of plastics and packaging.

What Replaces a PFAS Additive?#

Substitution is solved for two of the five additives, partly solved for two and open for one: PFAS-free processing aids and non-PFAS solid lubricants are commercial, KPFBS and the HFO blowing agents have named candidates, and no anti-drip replacement for PTFE is recorded in our source library. Alternatives to the fluoropolymer processing aid include polyether-grafted polydimethylsiloxane (CAS 68937-54-2), cleared by the FDA at up to 0.3 weight percent of the polymer as an extrusion aid under 21 CFR 177.1520, alongside boron nitride, TPU-based processing aids and modified polyolefin or ester masterbatches. Three commercial PFAS-free processing-aid lines have already launched: Ampacet in 2023, Baerlocher's Baerolub AID, announced 29 November 2023, and Clariant's AddWorks PPA, announced 23 April 2024 at Chinaplas. Five classes of PFAS-free processing aids are compared with the fluoropolymer incumbent on the family page, including a limitation worth carrying over from the incumbent itself: a fluoropolymer PPA did not eliminate stick-slip in HDPE in a 2015 study by Adesina and colleagues, where gross melt fracture reappeared at a shear rate of 141 per second at a 0.05 weight percent dose.

Anti-drip PTFE has no substitute recorded in our source library; no alternative anti-drip mechanism for flame-retarded polycarbonate and PC/ABS is documented here, so that function remains open. KPFBS has two named alternatives, KSS and BDP, both already used as substitution candidates in transparent polycarbonate. Tribological alternatives to PTFE micropowder are commercial and established: silicone, molybdenum disulfide and graphite all serve the same solid-lubricant function. For HFO blowing agents, a 2026 multi-criteria assessment of non-fluorinated alternatives in insulation foams, published in RSC Sustainability by Figuière, Kirik, Aggarwal, Peters and Cousins, is the most recent named source in our source library, though it stops short of naming a single drop-in replacement.

Table T7. Substitution.

PFAS Additive Function to Replace Non-PFAS Option We Document Status or Named Grade
Fluoropolymer processing aid Melt-fracture control Polyether-grafted PDMS (CAS 68937-54-2), boron nitride, TPU-based PPA, modified polyolefin/ester masterbatches Commercial: Ampacet (2023), Baerlocher Baerolub AID (2023), Clariant AddWorks PPA (2024)
Anti-drip PTFE Anti-dripping in FR PC/PC-ABS None recorded Open
PTFE micropowder Solid lubrication Silicone, molybdenum disulfide, graphite Commercial, established
KPFBS Flame retardancy in transparent PC KSS, BDP Named candidates
HFO blowing agents Physical foam blowing Non-fluorinated alternatives under assessment (Figuière et al., 2026) Partly solved

Request quotes for a named PFAS-free grade with the plastic additive supplier finder.

PFAS Compliance Dates for Plastic Additives, 2025 to 2033#

Between 1 January 2025 and 1 January 2033, fourteen dates change what a plastics business may sell or must report, and only one of them, the SEAC final opinion expected at the end of 2026, is not yet fixed in law. Reading the calendar in order shows two things at once: the United States moves first, with Minnesota and Washington's initial restrictions from 1 January 2025, while the European Union's first binding PFAS number for plastics, the PPWR's food-contact limit, lands on 12 August 2026, roughly midway through the calendar. This page summarises the legal texts it cites and is not legal advice.

Table T6. Compliance calendar, 2025 to 2033.

Date Jurisdiction What Changes Which Additive It Touches
1 Jan 2025 US (Minnesota, Washington) Minnesota and Washington first restrictions Consumer product categories, not plastics-specific
1 Jan 2026 US (Maine) Maine category bans expand Consumer product categories
13 Apr 2026 US federal TSCA scope rule effective; reporting window moved Fluoropolymer PPA, PTFE and KPFBS importers
25 May 2026 EU SEAC consultation closes All 5 additives (universal restriction)
12 Aug 2026 EU PPWR PFAS limits apply Fluoropolymer PPAs in food-contact film
15 Sep 2026 US (Minnesota) Minnesota initial reports due PFAS-containing compounds sold in Minnesota
10 Oct 2026 EU Annex XVII entry 79 applies Residue limit, not a named additive
End 2026 EU SEAC final opinion expected (SCHEDULED, not law) All 5 additives
1 Jan 2027 US (Washington) Washington Cycle 1.5 Consumer textile and furnishing categories
31 Jan 2027 US federal TSCA submission period opens at the latest Fluoropolymer PPA, PTFE and KPFBS importers
1 Aug 2030 EU Toy Safety Regulation applies PFAS in toys (indirect)
23 Oct 2030 EU Annex XVII entry 82 applies Firefighting foam PFAS, not a listed additive
1 Jan 2032 US (Maine, Minnesota) All-product bans All 5 additives, where sold in consumer products
1 Jan 2033 EU F-Gas foam ban HFO blowing agents

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Why Are PFAS Restricted at All?#

PFAS are restricted for persistence rather than for any single use: the REACH grounds recorded for the three PFAS groups most relevant to plastics are reproductive toxicity and PBT properties for PFOA, very persistent and very bioaccumulative properties for PFHxS, and an equivalent level of concern for PFBS and its salts. The exposure and environmental evidence behind those grounds is set out on PFAS in plastics, including how fluoropolymer processing aids, anti-drip PTFE and fluorinated containers reach the environment.

PFOA was added to the SVHC Candidate List on 20 June 2013 under Article 57(c), reproductive toxicity, and 57(d), persistent, bioaccumulative and toxic properties. PFHxS and its salts followed on 7 July 2017 under Article 57(e), very persistent and very bioaccumulative properties. PFBS and its salts, the group that includes KPFBS, were added on 16 January 2020 under Article 57(f), an equivalent level of concern for human health and the environment that does not fit the other two criteria exactly.

How much PFAS reaches food through packaging?#

The Food Packaging Forum's FCCmigex review by Phelps and colleagues (Environmental Science and Technology, 2024) recorded 68 PFAS detected in food contact materials, 87 percent of them perfluorocarboxylic acids or fluorotelomer-based substances. The remaining 13 percent span further PFAS classes recorded in the same database. That finding describes detections across food-contact materials generally, not plastics-specific additives, and it is this page's only citation from the environmental health literature rather than the regulatory record.

Which countries ban PFAS?#

No country has banned PFAS as a class today: the broadest measures in force are the Stockholm Convention listings of PFOS, PFOA, PFHxS and long-chain PFCAs, which bind the Parties to the treaty but not the United States, which is not a Party. The European Union has a proposal under review rather than a ban in force, and the United States has no federal ban at all, only the FDA authorisation list, the TSCA reporting duty and the state product laws already described on this page. Maine and Minnesota's state-level, all-product bans, both scheduled for 1 January 2032 unless a use qualifies as a currently unavoidable one, are the broadest PFAS bans scheduled anywhere in this page's regulatory matrix.

How this page is kept current#

This page carries a regulatory status verified date of 22 September 2026 and is re-checked in three cases: during the January and June SVHC windows, when the European Chemicals Agency publishes the SEAC final opinion on the universal PFAS restriction, expected at the end of 2026, and when the US EPA publishes the TSCA 8(a)(7) scope-revision final rule. Proposed and in-force items are never mixed on the same line on this page, and every change to a date or a status is logged in plastic additives news first.