Key Takeaways
- Australia has restricted three specific PFAS chemicals, PFOS, PFOA and PFHxS, from 1 July 2025, along with certain related compounds.
- The EU is evaluating a proposal to restrict PFAS as a class, potentially covering more than 10,000 substances.
- The EU evaluation is ongoing, with final scientific committee opinions expected by the end of 2026. A European Commission decision would follow. No final EU-wide restriction or confirmed ban date has been adopted.
- Australia’s current approach is focused on specific PFAS chemicals and related substances, while the EU proposal takes a broader group-restriction approach that considers PFAS collectively.
- Australia’s IChEMS Schedule 7 controls for PFOS, PFOA and PFHxS took effect on 1 July 2025. The permitted levels of unintentional trace contamination (UTC) in products are scheduled for review by 1 July 2027, making future changes to these requirements worth monitoring.
PFAS regulation in Australia is changing, while Europe is considering a much broader approach. Australia has already restricted three specific PFAS chemicals. The European Union is evaluating a proposal that could restrict PFAS as a class, potentially covering thousands of substances.
PFAS are widely used because they resist heat, water, oil, and stains. Many PFAS are also highly persistent and can remain in the environment for long periods. Growing concern about their environmental and potential health impacts is prompting regulators to look beyond individual chemicals.
For organisations involved in workwear, PPE and safety equipment procurement, these regulatory developments are worth monitoring. Changes to PFAS requirements could affect material selection, supplier disclosures and future tender specifications. Knowing what regulations are already in place, what is still being considered, and what could change can help procurement teams plan ahead.
What PFAS Are and Why Regulators Are Circling
PFAS, short for per- and polyfluoroalkyl substances, are a large family of synthetic chemicals used since the 1950s. They are valued for their resistance to water, oil, heat, and stains. That makes them useful in products ranging from non-stick cookware and firefighting foams to food packaging and water-repellent textile treatments.

But the same properties that make PFAS useful also make many of them difficult to break down. Some can persist in the environment for long periods, earning them the name “forever chemicals”. They can move through soil and water and, for some PFAS, accumulate in people and wildlife.
There are thousands of PFAS, which makes regulation complex. Rather than assessing every chemical individually, regulators are increasingly considering broader restrictions on the PFAS group. That shift helps explain why Australia and Europe are taking different approaches and why procurement teams should be paying attention.
How Australia Is Regulating PFAS
From 1 July 2025, Australia restricted the import, manufacture and use of three specific PFAS chemicals: PFOS, PFOA and PFHxS, along with certain related compounds.
The restrictions sit within the Industrial Chemicals Environmental Management Standard (IChEMS) framework. The three substances were listed in Schedule 7, which applies to chemicals identified as presenting a very high level of risk and for which the strongest level of controls is considered appropriate.
Why Were These Three Chemicals Restricted?
The restrictions followed an established regulatory process. The chemicals were listed for restriction in December 2023, providing 18 months before the restrictions took effect.
The action also reflects Australia’s international obligations under the Stockholm Convention on Persistent Organic Pollutants, under which PFOS, PFOA and PFHxS have been subject to international controls and phase-out measures.
These substances have also been subject to extensive scientific assessment and regulatory action because of their persistence and established environmental and health concerns. The health and environmental concerns surrounding these substances have also been the subject of extensive scientific and regulatory assessment. In 2023, IARC classified PFOA as carcinogenic to humans and PFOS as possibly carcinogenic to humans.
What About Other PFAS?
Australia’s current restrictions do not amount to a blanket prohibition on all PFAS chemicals. The approach remains primarily chemical-specific, with regulatory action focused on substances that have been assessed and identified for restriction.
That distinction is important. Australia’s current PFAS settings target specific substances rather than treating the entire PFAS family as prohibited.
How Europe Is Considering PFAS Restrictions
The European Union is taking a different route. In January 2023, chemical authorities from Denmark, Germany, the Netherlands, Norway and Sweden submitted a proposal to the European Chemicals Agency (ECHA) to restrict PFAS as an entire class under the EU’s REACH chemicals regulation.
The proposal covers the PFAS group broadly, potentially affecting more than 10,000 substances. It is one of the broadest restriction proposals considered under the REACH framework.
Why Take a Group-Wide Approach?
The proposal takes a precautionary approach rather than relying solely on chemical-by-chemical restrictions.
Instead of waiting for evidence of harm to be established separately for every individual PFAS, the proposal considers the wider group because of the size of the PFAS family, the persistence of many PFAS, and the potential for continued development and substitution within the group.
The proposed framework would introduce broad restrictions while considering exemptions or derogations where continued use can be justified.
Where Does the Proposal Stand?
The evaluation is still underway. ECHA’s scientific committees have been assessing the proposal and considering different uses and applications.
A draft opinion from the Socio-Economic Analysis Committee (SEAC) was published in March 2026, followed by a public consultation that closed in May 2026. ECHA’s scientific committees are currently expected to deliver their final opinions to the European Commission by the end of 2026.
The European Commission will then decide whether to introduce a restriction and, if so, what form it should take, subject to the EU’s decision-making process.
No final EU-wide PFAS restriction has been adopted, and there is currently no confirmed EU-wide ban date.
What Could Happen Next?
The outcome is not yet known. The proposal is still being evaluated, and its scope, exemptions, and implementation timelines could change before any final restriction is adopted.
Current evaluation work indicates that some proposed exemptions may be narrowed as the scientific and socio-economic assessments progress. If the proposal ultimately proceeds in its current direction, some restrictions could potentially begin taking effect from around 2029. However, that is an indicative possibility rather than a confirmed implementation date.
For organisations sourcing materials or products from Europe, the important point is that the regulatory direction is still developing.
Two Different Approaches, One Underlying Problem
The difference between Australia’s and Europe’s approaches reflects a genuine regulatory dilemma rather than simply a difference in ambition.

The Risk of Regrettable Substitution
A chemical-specific approach restricts substances once regulators have sufficient evidence and a regulatory basis for action. It can be evidence-led and targeted, but it can also take time.
One concern with this model is regrettable substitution. A restricted chemical may be replaced with a closely related alternative that has not yet been assessed to the same extent. The result can be a cycle in which one substance is removed while another similar substance takes its place.
A precautionary, class-wide approach attempts to address that problem by considering a broader group of related chemicals together. Instead of assessing each PFAS independently before taking action, the regulatory starting point is a broader restriction, with exemptions considered where continued use can be justified.
Each approach involves trade-offs. A broader restriction can reduce the possibility of substituting one closely related PFAS for another, but assessing thousands of substances, uses and alternatives makes the regulatory process considerably more complex.
Neither Approach Is Simple
Both models face practical challenges.
Because PFAS can enter Australia through imported products, import controls and supply-chain visibility are important parts of Australia’s regulatory response.
In Europe, the scale of the proposed restriction has contributed to a lengthy evaluation process. Assessing thousands of substances, applications, alternatives and potential exemptions is a substantial undertaking.
The Cost of Moving Away From PFAS
There is also a cost dimension. Reformulating a product away from PFAS, testing the replacement and demonstrating that it continues to meet relevant performance or safety requirements can take time and money, regardless of which regulatory model triggers the change.
For manufacturers and suppliers, those considerations can affect how quickly alternatives are developed, tested and adopted. They are also relevant to procurement teams planning long-term contracts and specifications.
Where Australia Might Be Headed
Australia has not announced plans to follow the EU towards a class-wide PFAS restriction. But that does not mean the current three-chemical approach is necessarily permanent.
Signs the Settings Could Change
Australia’s PFAS policy is also being examined more broadly. A Senate enquiry reported in November 2025 with recommendations covering PFAS monitoring, enforcement, imported products, labelling and implementation of existing PFAS restrictions. The committee also recommended stronger coordination between the Australian government, states and territories.
Australia’s current PFAS restrictions are also due for review in 2027.
None of this guarantees that Australia will adopt the EU’s broader precautionary model. But it does suggest that “watch this space” is a better approach than assuming the current settings are permanent.
For organisations specifying materials, garments or coatings under long-term contracts and tenders, future regulatory changes are worth factoring into procurement planning now.
Why State Implementation Matters
There is also a structural reason Australia’s approach requires more than simply tracking national policy.
Listing a chemical under IChEMS does not automatically create a nationwide ban. States and territories need to implement relevant restrictions through their own legislation and regulatory frameworks.
That means national policy direction and state-level implementation are separate things to track. Any future move towards broader PFAS restrictions would likely require attention to both.
What This Means for Procurement and Safety Teams Now
For teams responsible for specifying PPE, workwear, or safety equipment, the practical takeaway is not panic. It is visibility.

A few things are worth building into ongoing supplier conversations:
- Ask about PFAS use. Ask suppliers directly whether PFAS-based treatments are used in products you are sourcing rather than assuming general compliance documentation covers this issue.
- Watch tender requirements. Keep an eye on future specifications that request PFAS disclosure, restricted-substance declarations or PFAS-free requirements.
- Treat PFAS as a supply-chain issue. Most PFAS enter Australia through imported products, so understanding materials, treatments and upstream suppliers can be important when assessing potential exposure.
- Review long-term specifications. If a contract or tender is expected to run for several years, consider whether future chemical restrictions could affect material or supplier requirements.
- Keep documentation current. Supplier declarations, material information, and relevant compliance evidence can make it easier to respond if requirements change.
The goal is not to predict exactly what regulators will do next. It is to avoid being caught unprepared if PFAS requirements become more detailed or broader over the life of a procurement contract.
What Procurement Teams Should Take From the PFAS Regulatory Shift
PFAS regulation is moving, but it is not moving in one uniform direction. Australia has introduced targeted restrictions on PFOS, PFOA and PFHxS, while the EU is still assessing a proposal that could regulate PFAS much more broadly.
For procurement teams, the important point is not to predict which regulatory model will ultimately prevail. It is to recognise that chemical requirements can change over the life of a product, supplier relationship or tender.
Keeping supplier information current, understanding what materials and treatments are being used, and allowing enough flexibility to respond to changing requirements can make future transitions easier. As Australia continues to develop its PFAS framework and the EU works through its restriction proposal, staying informed now can help organisations make more informed procurement decisions later.
FREE RESOURCE

Tel: 1300 241 855
34 Murdock Street, South Clayton VIC 3169, Australia