Highlights of ECHA's December Meeting: Progress on PFAS Restriction Proposal, vPvB Classification Forthcoming

On December 17, 2025, the European Chemicals Agency's (ECHA) Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC) made significant progress at their December meeting. They held in-depth discussions on the assessment of the restriction proposal for per- and polyfluoroalkyl substances (PFAS) and, for the first time, issued a classification and labeling opinion for the new hazard category of "very persistent and very bioaccumulative" (vPvB) substances.

Progress on PFAS Restriction Assessment

RAC and SEAC have reached preliminary conclusions regarding the manufacturing stage of PFAS, with SEAC also formulating specific opinions on PFAS use in the electronics and semiconductor industries. The committees continued detailed discussions on cross-cutting issues within the restriction proposal, including:

• The concentration threshold for PFAS restrictions;
• Management plans and recycling schemes;
• Exemption clauses for spare parts;
• Enforceability and monitorability of measures;
• Whether the proposed restrictions constitute the most appropriate risk management option at the EU level.
  As planned, RAC is set to formally adopt its final opinion at the March 2026 meeting, while SEAC will finalize the draft and launch a 60-day public consultation to gather further feedback from stakeholders.

vPvB Classification

During the meeting, RAC adopted seven unified classification and labeling opinions, with the classification of 4,4'-methylenebis(dibutyldithiocarbamate) as vPvB standing out as a key highlight. This marks the first opinion issued by RAC for the new hazard category since the revision of the Classification, Labelling and Packaging (CLP) Regulation in 2023.

Classification and Labeling Opinions for Seven Substances

PBT or vPvB Properties

Classification criteria for PBT and vPvB substances

A mixture shall be classified respectively as a PBT or vPvB when at least one component contained in the mixture has been classified respectively as a PBT or vPvB and is present at or above 0.1 % (weight/weight).

Label elements for PBT and vPvB properties