PFOA & Products Placed on the Market Before Restrictions

The EU Directive 2017/1000 for REACH and Perfluorooctanoic Acid (PFOA) came into effect on July 4, 2020. What is the status of products placed on the market for order prior to that date?

The EU Directive 2017/1000 called for the restriction of PFOA by including it on the REACH Annex XVII list. However, the PFOA restriction was subsequently removed from the REACH Annex XVII list because of an update to the EU POPs Recast Regulation which resulted in PFOA instead being restricted as a persistent organic pollutant (POP). The restriction start dates under POPs were the same as the Annex XVII restriction dates, but there are different exemptions and applicable begin dates, and some of the exemptions related to semiconductors have been removed.

The “placed on the market” language goes beyond the first time a product was ever placed on the market, and impacts products going into the EU after that date. For the PFOA restriction, that means all products in the EU before July 4, 2020, can have PFOA over threshold, and any products going into the EU after July 4, 2020, must have PFOAs below threshold.

For more information, see EU REACH and PFOA.

Article is current as of 2021-08-21.

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