EU PFAS Restriction: PPWR Updates + RoHS Exemptions

Three significant regulatory developments in the EU now directly impact packaging materials, PFAS restrictions, and RoHS exemptions. Here's a breakdown of what’s changing and how manufacturers should prepare.

🇪🇺 PPWR: ECHA Call for Evidence on Substances in Packaging (closed 28 October 2025)

Original Regulation:

ECHA ran a Call for Evidence under Article 5(2) of the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, to gather information for its study report on substances of concern in packaging. The PPWR entered into force on 11 February 2025 and has applied since 12 August 2026, repealing Directive 94/62/EC.

The focus is on packaging, materials used, packaging waste, waste management, and recycling technologies. The regulation aims to reduce packaging use and waste, minimise primary raw material consumption, and support the transition to a circular, sustainable economy.

Status: Call for evidence closed 28 October 2025

The call for evidence was addressed to interested parties across the entire packaging supply chain — manufacturers, importers, distributors, formulators, end-users of packaging and packaging components, waste management practitioners, trade associations and recyclers. Other stakeholders (scientific organisations, NGOs, Member State authorities and international organisations) were also invited to upload written submissions.

Deadline for providing input: 28 October 2025. The window is now closed. ECHA is using the input to prepare its study report mapping substances of concern in packaging, which will inform future REACH restriction priorities.

ECHA: Call for Evidence on substances in packaging and packaging waste

📌 What This Means for Manufacturers

• Audit your product packaging materials and any components potentially affected by substance-level scrutiny.
• Keep the scientific, technical and commercial evidence for your packaging materials on file — the same data will be requested again when ECHA consults on the restriction priorities that follow from its study report.
• Coordinate across regulatory, procurement and sustainability teams — manufacturer input to this exercise will shape the substance restrictions that follow.

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🇪🇺 EU PFAS Restriction: SEAC Draft Opinion Consultation (closed 25 May 2026)

Original Regulation:

ECHA's Committee for Risk Assessment (RAC) adopted its final opinion on the proposed EU-wide restriction of per- and polyfluoroalkyl substances (PFAS) on 2 March 2026. The Committee for Socio-Economic Analysis (SEAC) agreed its draft opinion on 10 March 2026, and ECHA ran a 60-day consultation on that draft opinion from 26 March to 25 May 2026. An online information session was held on 30 October 2025 to help interested parties prepare.

The proposal to restrict PFAS in the EU/EEA was prepared by the authorities of Denmark, Germany, the Netherlands, Norway, and Sweden and submitted to ECHA on 13 January 2023. The proposal aims to reduce PFAS emissions into the environment and make products and processes safer for humans.

Status: Consultation closed 25 May 2026; SEAC's final opinion is expected by the end of 2026

The consultation was open to all interested parties, including industry representatives, civil society organisations, researchers and the public. Once SEAC adopts its final opinion, both committee opinions go to the European Commission, which then drafts a restriction proposal for a vote in the REACH Committee.

ECHA: SEAC agrees its draft opinion on the PFAS restriction proposal

📌 What This Means for Manufacturers

• Identify and map all PFAS use across product lines — prepare justifications or alternatives.
• Review RAC's and SEAC's published opinions to see which derogations and transition periods apply to your uses.
• Finish your cross-functional impact assessment now: the Commission's draft restriction is the next formal step, and substitution lead times for PFAS are measured in years, not months.

🇪🇺 RoHS Exemptions: Renewals, New Sub-Entries (7(c)-V/VI), and Expiry Dates (2026–2027)

Original Regulation:

The European Commission's RoHS Delegated Directives on lead exemptions — (EU) 2025/1802 (exemption 7(a)), (EU) 2025/2363 (exemption 7(c)) and (EU) 2025/2364 (exemptions 6(a), 6(b) and 6(c)) — were published in the Official Journal on 21 November 2025. Member States had to transpose them by 30 June 2026, and the revised Annex III entries have applied since 1 July 2026.

Exemptions 7(a) and 7(c)-I remain in Annex III and now expire on 30 June 2027 for all categories. Narrower applications have been carved out of them into new sub-entries: 7(a)-I to 7(a)-VII for high-melting-temperature solders, and 7(c)-V and 7(c)-VI for specific glass and ceramic uses. Those new sub-entries, and the existing 7(c)-II, expire on 31 December 2027.

Status: In force since 1 July 2026

Under RoHS, a renewal application must reach the Commission at least 18 months before an exemption expires, which set the following cut-offs:

Exemptions expiring 30 June 2027 (7(a), 7(c)-I, 6(c)): renewal applications were due by 31 December 2025.
Exemptions expiring 31 December 2027 (7(a)-I to 7(a)-VII, 7(c)-II, 7(c)-V, 7(c)-VI): renewal applications were due by 30 June 2026.

Learn more here

📌 What This Means for Manufacturers

• Update your EN IEC 63000 technical documentation so it cites the correct sub-entry — a declaration still citing 7(a) or 7(c)-I for an application that has moved to a sub-entry is wrong from 1 July 2026 onwards.
• Ask suppliers to restate their declarations against the new exemption IDs and expiry dates.
• Both renewal windows (31 December 2025 and 30 June 2026) have closed. Check whether the exemptions your product relies on were applied for; where no application was made, plan redesign or substitution before the 2027 expiry dates.

✅ Need to integrate these shifts into your product compliance workflow? At EcoComply, we monitor EU regulatory changes in real time and translate them into clear, actionable tasks for your operations, legal, and R&D teams.

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👉 See how our RoHS compliance service works

More packaging guidance: visit the PPWR resource hub for requirements, practical guides, templates and the relationship with packaging EPR.