The European Chemicals Agency has invited stakeholders to comment until May 25 on the draft opinion of its SEAC Committee on the proposed restriction of PFAS, including f-gases.

The European Chemicals Agency (ECHA) announced on March 25 that until May 25 EU stakeholders can provide comments that will help inform the final opinion of the Committee for Socio-economic Analysis (SEAC) regarding restrictions on PFAS (per- and polyfluoroalkyl substances), including applications of fluorinated gases.

Stakeholders can submit comments via the PFAS – SEAC Draft Opinion consultation page here.

The consultation uses a structured survey format, inviting participants — including industry, non-governmental organizations, producers and developers of alternatives, researchers and members of the public — to respond to questions on the potential impacts of restricting the use of PFAS across various sectors as described in the SEAC draft opinion, published March 10.

The Coalition for PFAS Free Cooling & Heating, which supports regulations on PFAS refrigerants, will host a webinar to discuss the consultation process and the importance of participating. The webinar will be held April 9 at noon CET; register here. ATMOsphere, publisher of NaturalRefrigerants.com, is a member of the coalition.

PFAS refrigerants include both HFCs and HFOs, such as HFC-125, HFC-134a, HFC-143a, HFO-1234yf, HFO-1234ze(E), HFO–1336mzz(Z) and HFO-1336mzz(E). SEAC’s draft evaluation of applications of fluorinated gases, including refrigeration, air conditioning and heat pumps, can be found here and transport (including mobile air-conditioning and transport refrigeration) here. Other sector evaluations can be found here.

Participants are also asked to provide specific information about the availability and feasibility of alternatives to PFAS chemicals. Any information marked as confidential will be treated appropriately. Information on the hazards and risks to human health and the environment associated with PFAS will not be considered, as these are covered by the opinion of the Committee for Risk Assessment (RAC).

ECHA has published consultation guidelines and a mapping of PFAS uses to help contributors prepare and submit relevant information. The agency said it encourages participants to carefully review the SEAC draft opinion and follow the guidelines “to ensure their input is as useful as possible for SEAC.” All non‑confidential consultation responses will be published on ECHA’s website.

Relevant information submitted through the consultation will be assessed to confirm modify SEAC’s conclusions as presented in the draft opinion. SEAC is expected to adopt its final opinion by the end of 2026. This adoption will conclude ECHA committees’ scientific evaluation of the proposed restriction and the opinions will be formally submitted to the European Commission.

Based on the final opinions of SEAC and RAC, the Commission will propose a restriction for discussion and vote in the REACH Committee, composed of EU Member States.

The Coalition for PFAS Free Cooling & Heating will be holding a webinar on the consultation process on April 9 at noon CET.

The proposal to restrict PFAS in the EU and EEA (European Economic Area) was prepared by authorities in the Netherlands, Germany, Denmark, Norway and Sweden, and was submitted to ECHA on January 13, 2023. It aims to reduce PFAS emissions into the environment and make products and processes safer for people. The six-month consultation on the restriction proposal ran from March 22 to September 25, 2023. ECHA’s Committee for Risk Assessment (RAC) adopted its final opinion on the proposal on March 2 2026.

ECHA defines PFAS as substance that contains at least one fully fluorinated methyl or methylene carbon atom, without any hydrogen, chlorine, bromine or iodine attached to it. This aligns with the OECD definition of PFAS published in 2021, which is widely accepted by the international scientific community. PFAS encompasses thousands of almost exclusively synthetic substances that are used in numerous applications globally. In addition to refrigerants, these include textiles, food packaging, lubricants, electronics, construction and many more. Exposure to many PFAS has been linked to adverse health effects.

F-gas exemptions

ECHA announced last August that it had published an updated proposal from five European countries to restrict PFAS, with most restrictions on PFAS refrigerants remaining the same but with some refrigerant applications being given a longer exemption.

The PFAS proposal offers two main restriction options (ROs). The first (RO1) is a full ban with a transition period of 18 months following the date the restriction regulation enters into force (EiF). The second (RO2) establishes a ban with use-specific, mostly time-limited exemptions (derogations) lasting five years (6.5 including the transition period) or 12 years (13.5 including the transition period) following the EiF date. The third option (RO3) allows continued use under strict conditions that minimize PFAS emissions over a product’s full life cycle.

Most HVAC&R applications fall under RO1, several are covered under RO2 and a few under R03. HVAC&R applications targeted for exemptions (most of them time-limited) include:

• PFAS refrigerants in low-temperature refrigeration below -50°C (-58°F) can be used until 6.5 years after the EiF date.
• PFAS refrigerants used in transport refrigeration other than marine applications can be used until 6.5 years after the EiF date. Marine applications have no exemption beyond the transition period.
• PFAS refrigerants in laboratory test and measurement equipment can be used until 13.5 years after the EiF date.
• PFAS refrigerants in refrigerated centrifuges can be used until 13.5 years after the EiF date.
• PFAS refrigerants in mobile air-conditioning (MAC) systems in combustion engine vehicles with mechanical compressors, can be used until 13.5 years after the EiF date.
• PFAS refrigerants used in light-duty electrical vehicles (such as passenger cars and vans), can be used until 6.5 years after the EiF date.
• PFAS refrigerants used for the maintenance and refilling of existing HVAC&R equipment for which no drop-in alternatives exist, have a “time-unlimited” exemption. This applies to equipment already in use when the restriction enters into force or equipment that has been put into operation within any of the relevant time exemptions.
• PFAS refrigerants used in HVAC&R-equipment in buildings where national safety standards and building codes prohibit the use of alternatives can continue to be used.

In its new draft opinion, SEAC said that the exemptions for low-temperature applications, lab equipment, refrigerated centrifuges and buildings where standards/codes prohibited alternatives were “not justified” because they would “create a conflict with measures in the F-gas Regulation.” However, SEAC recommends an exemption “whose only goal is to avoid interfering with current and future prohibitions in the F-gas Regulation.”

In regard to refrigerants used for maintenance and refilling of existing HVAC&R equipment, SEAC said the time-unlimited exemption was “justified from a general standpoint” but recommended it be “aligned with the provisions from the F-gas Regulation.”

Regarding mobile AC and transport, SEAC “cannot conclude whether a derogation is justified.”

Concerns about TFA

The updated proposal released last year raised whether “additional, complimentary, risk management” beyond the EU’s F-gas Regulation and the MAC (Mobile Air-Conditioning) Directive is justified to regulate f-gases that break down in the atmosphere into the very persistent degradation product trifluoracetic acid (TFA).

“The F-gas Regulation and the MAC Directive primarily target the GWP of f-gases, while the risks that have been identified in this restriction proposal, i.e., those associated with the formation of very persistent degradation products (e.g. TFA) in the environment, are not addressed,” the proposal said. “Therefore, it is appropriate to explore whether existing legislation for f-gases,” it added, “remains appropriate to control these other identified risks.”

The main concern for all PFAS and their degradation products in the scope of the restriction proposal is their very high persistence. Emblematic of that persistence is TFA, formed by the complete breakdown over a few weeks of commonly used HFO-1234yf after it leaks into the atmosphere.

“With the constantly increasing concentrations of [PFAS] in the environment due to their persistence and ongoing emissions, the exposure of humans and the environment to these substances will inevitably lead to negative effects,” said the proposal.

In addition to certain f-gases, TFA can be generated from the breakdown of some pesticides and pharmaceuticals. In its new draft opinion, SEAC said that excluding these applications from the PFAS ban via time-unlimited exemptions is not justified, in part

because “TFA is one of [their] possible major metabolites/degradation products.”

 Under the EU’s CLP (classification, labelling and packaging) Regulation, TFA is classified as Aquatic Chronic 3, H412 (harmful to aquatic life with long-lasting effects) and Skin Corrosion 1A, H314 (causes severe skin burns and eye damage). In May 2025, three German government agencies announced that their assessment of TFA and its trifluoroacetate salts as reproductively toxic, very persistent and very mobile was officially submitted to the ECHA for consideration under the EU’s CLP Regulation.

Concerns about TFA-related harm to human health are limited to “effects at high doses in experimental animals: liver effects (increased liver weight, hepatocellular hypertrophy, increased ALT), increased kidney weight, decreased white blood cells, reduced weight of reproductive organs, litter loss, reduced body weight of offspring, and malformations,” the 2025 PFAS proposal said.

However, in an ongoing study of North Carolina firefighters, Duke University researchers are examining a potential link between PFAS (including TFA) exposure and biomarkers of thyroid dysfunction and disease.

The original 2023 PFAS restriction proposal noted that many different PFAS co-occur in the environment, drinking water, food and in human blood. Thus there is combined exposure to multiple PFAS, many exhibiting similar effects on the liver, kidney, thyroid, serum lipids and immune system. “Accordingly, an assessment of hazards and risks taking into account such combined exposure would reflect more realistic exposure conditions than single compound assessments,” the proposal said.

Following a request from the European Commission, the European Food Safety Authority (EFSA) is reviewing the health-based reference values for TFA; a conclusion is expected this year.

The fluorochemical Industry points to the UN Environment Programme (UNEP) and its 2022 Environmental Effects Assessment Panel (EEAP) report. The report says that TFA is not bioaccumulative, is “not expected to pose significant risk to humans or the environment at the present time” and “is unlikely to cause adverse effects out to 2100.” The report does not comment on the contribution of pesticides and other precursors to TFA since they don’t fall under the purview of the Montreal Protocol.

The UNEP report noted that deposition of TFA from HFOs and HCFOs will result in greater concentrations near the locations of release. “This is unlikely to present a risk to humans or the environment in these locations but changes in concentration in surface water (or soil) would respond rapidly to releases,” it said, adding, “Monitoring of the environment for residues of TFA would provide an early warning if trends in concentration indicate rapid increases.”