The universal PFAS restriction

PFAS – or forever chemicals – are receiving increased attention in the media and in the policy-making sphere because of numerous pollution scandals and public health issues, as well as calls for bold action from scientists, policymakers, and environmental organisations.
On 7th February the European Chemicals Agency (ECHA) published the “universal PFAS restriction dossier” (“uPFAS”), paving the way for a broad ban of PFAS under the EU’s chemical regulation, REACH.
The dossier is impressive and of unprecedented ambition, and its technical and procedural aspects can be daunting. We try to shed light on these to make the 2000-page document more palatable and to provide a rough structure to guide the reader.
Moreover, REACH restrictions follow complex processes with uncertain timing and speculative outcome. Here we attempt a brief explanation of the logic.