Restriction work

PFAS

The latest update of the background document marks an important milestone towards a universal PFAS restriction. In January 2023, the dossier for this universal restriction was submitted by the Netherlands and Germany together with Denmark, Norway and Sweden. The proposal aims to restrict the entire group of PFAS within the European Union.

PFAS, or per- and polyfluoroalkyl substances, are a large group of man-made substances. These substances degrade very slowly in the environment. Several PFAS have been shown to be harmful to humans and the environment.

Following submission of the dossier, ECHA launched a six-month public consultation. More than 5,600 responses were received, comprising over 100,000 pages of information. The team of five countries processed all relevant information into the dossier, which from that point onwards is referred to as the background document.

In August, ECHA published this document, marking the completion of the main part of the work. As the dossier grew from 1,800 to more than 3,300 pages, we also prepared a summary. The scientific committees of ECHA (RAC and SEAC) are expected to finalise their opinions in the course of 2026.

PPDs

In close cooperation with Austria, further preparations were made over the past year to develop a restriction proposal for the group of PPDs. These substances are used in rubber tyres, where they function as antioxidants and antiozonants, extending the lifespan of tyres.

In the United States, transformation products of these substances, released from tyre wear particles, have been shown to enter surface waters and cause mass salmon mortality. In Europe, concentrations have also been measured that may be harmful to fish species related to salmon.

Work has therefore been carried out to compile an overview of substances on the European market belonging to the PPD group. In December, a Call for Evidence was launched, requesting all stakeholders to provide available information on PPDs and possible alternatives.

This includes data on substance properties such as toxicity, information on transformation products in the environment, the extent of their use in tyres, and their release from tyre wear particles. The restriction proposal will be further developed in 2026, with submission to ECHA planned for March 2027.

Steel slags

There has been considerable attention over the past year on steel slags. Bureau REACH previously provided advice to the Human Environment and Transport Inspectorate (ILT), concluding that LD steel slags should be classified as a hazardous substance in accordance with CLP criteria.

RIVM colleagues have also conducted research into the leaching of hazardous substances from steel slags and concluded that current soil legislation is insufficient to manage the risks associated with their use.

In summer 2025, the State Secretary for Infrastructure and Water Management introduced a temporary measure to restrict the use of steel slags in the Netherlands. For example, steel slags may no longer be used in layers thicker than half a metre or in open applications where direct contact is possible.

As a result of this national measure, the Ministry submitted a REACH Article 129 notification to the European Commission. The Commission must now assess whether the emergency measure is sufficiently substantiated and acceptable. If so, the Netherlands must prepare and submit a restriction dossier for the entire EU.

At the request of the Commission, the Netherlands, with input from Bureau REACH, has provided additional supporting information. A decision from the Commission is expected in the course of 2026.

Asbestos

Work on the restriction of unintentionally added asbestos, as a supplement to the existing REACH asbestos restriction, has been suspended indefinitely.

Information submitted in the Call for Evidence indicates that the technical feasibility of amending the restriction needs to be reconsidered. In addition, a discussion has started on the enforceability of the current restriction and the need for international cooperation to identify suspect flows of products that may contain asbestos.

This discussion will be taken forward by Dutch inspection representatives within the European Forum network.