Get Ready for the ECHA SEAC Consultation

In March 2026, the European Chemicals Agency (ECHA) is expected to launch the much-awaited consultation on the draft opinion on PFAS restrictions issued by its Committee for Socio-Economic Analysis (SEAC). The consultation will be open for 60 calendar days (not working days). The consultation will use a structured survey format (the Global Electronics Association will run a consolidated survey and consolidate input on behalf of members), covering both general questions on the SEAC draft opinion and specific questions on the SEAC evaluation by sector (for 14 sectors, including electronics and semiconductors). Stakeholders will be asked to provide input on:

• Potential impacts of restricting PFAS across sectors, e.g., repercussions of non-use scenarios such as no impact, closure of operations, relocation, or substitution of PFAS
• Availability and feasibility of alternatives
• Information on missed uses and derogations, where relevant to socio-economic aspects.

Please note the following:

• Feedback will be entered directly into the survey fields, i.e. attachments will not be accepted
• Confidential information will be treated appropriately if clearly flagged as confidential
• Information on PFAS risks will not be considered, as these are assessed separately by RAC
• The consultation will focus only on SEAC's opinion, not on the entire background document.

The consultation will be open to all interested parties. Stakeholders are encouraged to start preparing to ensure SEAC's final opinion will be robust and fit-for-purpose. Of note, ECHA will hold an online information session on 30 October 2025, with further details and consultation guidelines to be published on its website. Additionally, ECHA will confirm the exact start date of the consultation in March 2026, and additional guidance may be provided to help stakeholders with their submissions. After reviewing the feedback, SEAC is expected to adopt its final opinion by the end of 2026. This step will conclude the scientific evaluation by ECHA's committees of the proposed PFAS restriction and will be followed by the submission of the dossier to the European Commission.

The Commission has reaffirmed its intention to adopt a strict, science-based ban, but will allow time-limited exemptions for critical uses without alternatives. While NGOs call for fast action, industry warns of major supply chain disruptions if transition timelines are too short. Why this matters:

• The restriction could redefine entire product portfolios
• Supply chains will need full transparency on PFAS content
• R&D for alternative substances will accelerate - but time is short and, for many PFAS uses in electronics, in particular function-essential fluoropolymers, alternatives may not be feasible.

The Association urges members to become familiar with the current ECHA Draft Background Document (note: it is not yet final, but some members have already identified missed uses for specific electronics application) and to start considering how gaps identified by SEAC can be addressed, in line with the anticipated content of the future survey and the type of questions that it will include. The Association will have a face-to-face informal meeting with SEAC in Brussels in mid-October.

Members are invited to send their questions for the SEAC to [email protected] by 24 September 2025 EOD.

Read more on ECHA's webpage and contact [email protected] for follow-up.