What the EU’s PFAS restriction means for coatings and paints

For coatings and paints, this potentially encompasses fluorinated surfactants, waxes, binders, additives and even some polymer systems previously assumed to be “polymerexempt”. In practical terms: every fluorinated raw material in existing formulations must be carefully reevaluated, analytically verified and assessed for substitution.

Regulatory status (as of Q3 2025)

– The national authorities of Denmark, Germany, the Netherlands, Norway and Sweden have submitted a joint Annex XV PFAS restriction dossier to ECHA.

– The 14th edition of the Background Document was released by ECHA in August 2025.

– RAC and SEAC evaluations are expected to conclude by the end of 2026, followed by public consultation in early 2026.

– A final regulation is thus unlikely before 2027–2028, yet data collection, substitution studies and supplychain mapping need to start immediately.

Understanding which fluorinated substances are in scope

Substance group	Typical examples	PFAS status (Annex XV proposal)	Key remarks
Fluorinated surfactants	Fluoroalkyl sulphonates, phosphate esters	clearly in scope	high efficacy at low dosages; limited viable replacements
Fluorinated waxes	PTFE micropowders, fluoropolyols	potentially in scope if lowMW fractions < 10 kDa are present	polymer exemption valid only if no lowMW PFAS fraction detectable
Fluoropolymers (e.g. PTFE, PVDF)	Polytetrafluoroethylene, polyvinylidene fluoride	often formally “polymerexempt” yet coatings or articles containing them may still trigger notification or restriction	endoflife emissions and surface wear matter
LowMW sidechain fluorinated polymers	Fluoroacrylates, fluorourethane oligomers	fully in scope	substitution mandatory

Critical point: supplier data sheets describing materials as “not affected (polymerexempt)” are seldom sufficient. If lowmolecular fractions (< 1 000 Da) or releasable PFAS fragments are present, they fall under the proposed restriction.

Implications for coating formulations

Typical affected additives and potential alternatives

Function	Typical fluorinated type	Possible nonfluorinated approach	Technical caution
Wetting / levelling	Polyetherfluorosurfactants (C₄–C₈ chain)	siliconemodified polyethers, shortchain nonfluorinated surfactants	surface tension may rise, cratering risk
Slip / scratch resistance	PTFE or FEP microwaxes	UHMWPE, paraffin or amide waxes	reduced chemical and heat resistance
Antigraffiti / easytoclean	Sidechain fluoroacrylates, perfluoropolyethers	hybrid siliconeacrylates, solgel / SiO₂based topcoats	altered optical appearance, adhesion shift
Corrosion protection / adhesion	Fluorinated acrylates or primers	functional silanes, titanates, siloxanemodified binders	must reoptimise crosslinking and wetadhesion balance

Substitution is rarely a dropin replacement: tests on chemical resistance, contact angle, QUV weathering and saltspray are mandatory before freezeout of any PFAScontaining component.

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Event tip: PFAS

The next EC Conference on this crucial topic – PFAS – will take place on 03 – 04 December 2025 in Cologne, Germany. With an EU-wide PFAS ban expected from 2026, the coatings industry faces urgent questions: Which PFAS substances are most critical? What alternatives exist? And how can formulators prepare for upcoming regulations? This conference brings together international experts to discuss the latest material innovations, regulatory developments and challenges in reformulating PFAS-free coatings. Topics include: PFAS materials and substance groups, substitution strategies and functional alternatives, regulatory compliance and industry impact.

Analytical control – screening and limitations

Recommended hierarchy

1. Screening:
Total Fluorine (TF) or Extractable Organic Fluorine (EOF) to quantify overall fluorine levels.
– Pros: identifies hidden PFAS quickly
– Cons: matrix effects; cannot distinguish individual species

2. Targeted analysis (LC–MS/MS, GC–MS):
Detects 80–100 known PFAS species. Availability of reference standards remains limited.

Guidance:
Use TF/EOF for internal mapping, then run targeted analysis if anomalies occur. Document limits of detection (LOD/LOQ). Authorities increasingly refer to orientational thresholds of ≈ 25 µg PFAS kg⁻¹ for declaration purposes.

Technical action plan for R&D laboratories

Step	Objective	Practical implementation
1	Build a complete fluorinatedsubstance inventory	Request supplier CAS numbers, molecularweight distribution (< 1 000 Da) and detectionlimit data
2	Establish an analytical baseline	TF/EOF on representative raw materials and formulations; include QA data in internal database
3	Prioritise affected product lines	Focus on hydrophobic / antistick systems first
4	Develop and benchmark alternatives	Laboratory substitution followed by customerrelevant performance trials (contact angle, abrasion, chemical resistance, UV)
5	Adjust process and cure conditions	Nonfluorinated systems often show different surface energy; reoptimise film formation
6	Document essentialuse justification	Provide technical evidence, functionality data and socioeconomic reasoning
7	Validate “PFASfree” claims	Only if below analytical detection; retain laboratory certificates (TF/EOF + targeted test)

Common pitfalls and misconceptions

Issue	Typical misconception	Clarification
“Polymerexempt = safe”	All fluoropolymers automatically excluded	Not if lowMW or degradable PFAS fractions exist
Screening = compliance proof	TF/EOF values suffice for legal declaration	Screening is qualitative; numerical values not REACHapproved
Substitutes readily available	Alternative = functional equivalent	Performance often lower; durability to be validated
Long transition periods	Final restriction far away	OEMs already request PFASfree statements by 2025/26

Strategic R&D considerations

– Transition towards hybrid and nonfluorinated systems (silicone, acrylate, solgelbased).

– Build internal databases of fluorine content and analytical results for rapid supplier assessment.

– Collaborate with testing institutes to benchmark performance of alternatives (contact angle, cleanability, chemical and weathering resistance).

– Monitor nonEU developments – the US TSCA process already restricts new PFAS introductions; Canada and parts of Asia are drafting aligned timelines.

Summary

For R&D coating chemists, PFAS regulation is not merely compliance work — it is a comprehensive formulation challenge.

– Analytical mapping of all fluorinated ingredients is the essential first step.

– Polymer exemptions are conditional; lowmolecular fractions remain a highrisk zone.

– Alternative technologies exist but must be rigorously validated for longterm durability.

– Documented transparency throughout the supply chain avoids later market interruptions.

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