As of October 2026, no EU-wide PFAS ban applies to electronic components yet, but the proposal has cleared its main scientific step. ECHA's Risk Assessment Committee (RAC) adopted its final opinion in March 2026, and the Socio-Economic Analysis Committee (SEAC) aims to adopt its final opinion by the end of 2026. The restriction would reach PTFE coax dielectrics, fluoropolymer wire insulation, FKM seals and much of the chemistry used to make ICs. For a buyer, the work to do in 2026 is a BOM check and a document chase. A redesign is not needed yet.
Where the EU PFAS restriction stands in October 2026
The universal PFAS restriction is still a proposal. It covers roughly 10,000 substances, and on the dossier's own timetable the first bans cannot apply before late 2028. The table below shows each step and what it means for anyone buying components for products sold in the EU.
| Date | Step | What it means for buyers |
|---|---|---|
| 13 January 2023 | Authorities in Denmark, Germany, the Netherlands, Norway and Sweden submit the restriction dossier under REACH | The scope is set: manufacture, use and placing on the market of PFAS in substances, mixtures and articles |
| March to September 2023 | First public consultation, with more than 5,600 comments | Electronics makers argue that fluoropolymers have no drop-in substitutes |
| March 2026 | RAC adopts its final opinion and SEAC agrees a draft opinion. Both are published on 26 March 2026 | The scientific committee backs an EU-wide restriction with time-limited derogations |
| 26 March to 25 May 2026 | Consultation on the SEAC draft: 3,511 comments. The results summary was published on 3 June 2026 | Electronics and semiconductors drew the most comments of any named sector |
| End of 2026 (target) | SEAC adopts its final opinion, and both opinions go to the European Commission | Derogation lengths for your use become visible for the first time |
| 2027 onward | The Commission drafts the regulation, member states vote in the REACH Committee, and a scrutiny period follows | Bans would apply after a transition period. The dossier proposes 18 months, followed by 5- or 12-year derogations for specific uses |
The late-2028 floor is simple arithmetic: even if the Commission's regulation entered into force in 2027, the dossier's 18-month transition would end in late 2028 at the earliest, and later if adoption slips into 2028. Industry wants that window to be longer. Germany's electrical industry association ZVEI says that four to eight years are needed even where substitutes exist, and it calls the 18 months "insufficient" in its November 2025 statement on the PFAS restriction. The same statement asks for a general derogation for fluoropolymers and a 1,000 ppm limit value for articles. Both requests are still open as of October 2026.
Which electronic components contain PFAS
In most BOMs, PFAS is concentrated in a small set of lines: RF connectors, high-temperature cable, sealed parts and lithium cells. In those lines a fluoropolymer or fluoroelastomer does a job that ordinary plastics cannot do. The EU definition counts any substance with at least one fully fluorinated CF3 or CF2 carbon. PTFE, FEP, PFA, ETFE, PVDF and FKM fluororubber all meet it.
| Component family | Typical PFAS material | Why it is there | Priority to check |
|---|---|---|---|
| Coax connectors, RF contacts, coax cable | PTFE dielectric | Stable dielectric constant and low loss at GHz frequencies | High |
| High-temperature wire and cable assemblies | PTFE, FEP, PFA, ETFE insulation | 200 C and higher ratings, chemical resistance, thin walls | High |
| IP67 connectors, sealed sensors, drive and motor parts | FKM O-rings and gaskets | Oil, fuel and heat resistance | High |
| Lithium-ion cells and battery packs | PVDF electrode binder | Electrochemical stability | High |
| High-frequency PCB laminates | PTFE-based substrates | Low loss for radar and RF front ends | Medium to high |
| Switches, relays, connectors with lubricated contacts | Perfluoropolyether (PFPE) greases, where used | Lubrication that does not migrate or degrade | Medium |
| Packaged ICs and discretes | Mainly fab process chemistry: photoresists, etch and cleaning | Lithography and etch steps where alternatives are still being qualified | Supply continuity, not article content |
This list is not theoretical. Beckhoff, the automation maker in Verl, states in its PFAS declaration of 23 March 2026 that PTFE and FKM can be present "in seals/O-rings, cables, or connectors" across servo motors, drives, EtherCAT Box modules and cables. RoHS does not cover any of this. RoHS restricts ten substances and PFAS is not among them, so a RoHS-compliant part says nothing about fluoropolymers.
The gotcha: a "PFAS-free" letter often answers a different question
Most supplier PFAS statements are written to a narrower definition than the EU proposal, or carry a qualifier that excludes fluoropolymers. Read the wording before you file the letter.
Here are two real examples from 2026. Harwin's PFAS statement (Issue 3, 8 January 2026) is honest and useful: it names PTFE in specific coax contact and cable products and links a part list. It is also explicitly framed around US TSCA Section 8(a)(7) reporting, and it says that "no routine analytical testing is implied". Beckhoff's declaration says the company does not intentionally add PFAS "in free or unprocessed form". That qualifier carves out exactly the fluoropolymers the EU proposal would restrict, and the next sentence of the same declaration confirms that PTFE and FKM are present.
Neither document is misleading. Each answers the question it was written for. The trap is a procurement file that holds a company-wide letter saying "not intentionally added" when the auditor's question is "which of our 400 part numbers contain a fluoropolymer, and in which homogeneous material?". Buyers who ask for "a PFAS statement" get a letter. Buyers who send part numbers and name the definition get data.
A 5-step PFAS check for an existing BOM
Five steps will tell you which BOM lines need attention before the SEAC final opinion lands: sort, request, tag, split and decide.
- Sort lines by material family. Use the table above to mark every RF connector, cable assembly, sealed part, cell and high-frequency laminate. Do it during a normal BOM scrub so lifecycle and PFAS data sit in the same sheet.
- Request part-level data, not a company letter. Ask for a full material declaration per manufacturer part number (IPC-1752 Class D or the maker's own material content sheet). Name the EU REACH PFAS definition in the request. Keep the documents with the certificate of conformance for that lot.
- Tag the function of every PFAS hit. Record the function for each hit, for example "PTFE dielectric, 6 GHz path" or "FKM seal, gearbox oil contact". Derogations in the final text will be written per use, so a tagged use can be matched to them in hours.
- Split article content from process use. For ICs and discretes, the realistic risk is that a fab loses a process chemical and the part receives a PCN. Watch these lines through PCN alerts rather than material tests.
- Decide per line. Where a PFAS-free equivalent exists, qualify it now as a second source. For long-life equipment, note that the dossier proposes time-limited derogations for spare parts and that RAC said it can support them. If your use falls outside every derogation, plan a last time buy for repair stock before the ban date, not after it.
Worked example: triaging four in-stock GlobX parts
We ran four lines from a typical industrial control board through step 1. None of them falls into a high-priority family, and that is the usual result for most of a BOM. The table shows live GlobX stock as of 12 October 2026. All four parts are held in Germany with status Active.
| Part | Type | GlobX stock | What to ask the manufacturer | Priority |
|---|---|---|---|---|
| STM32H743VIT6 (ST) | MCU, LQFP100 | 9,200, DC 21+ | Process continuity only: watch for PCNs that cite chemical changes | Low |
| 1042470617 (Molex) | FFC/FPC connector, 0.5 mm, 6 positions | 18,000, DC 21+ | Housing resin and any contact lubricant | Low to medium |
| A6S-1101-H (Omron) | DIP switch | 4,200, DC 22+ | Whether a fluorinated grease is used on the contacts | Medium |
| EEF-HX0D471R6 (Panasonic) | Polymer aluminium capacitor, 470 uF, 2 V | 22,000, DC 22+ | Materials in the sealing and internal structure, per homogeneous material | Medium |
On a typical control board, the high-priority work usually comes down to three or four lines that are not shown here: the SMA connector on the radio module, the PTFE-insulated harness to the heater, and the sealed pressure sensor. Those are the lines to chase first. The rest can follow the routine declaration cycle.
What changes in your RFQs from now on
Add one line to every RFQ for a high-priority family: "Provide part-level PFAS content to the EU REACH restriction definition, by homogeneous material." Suppliers who can answer that line in 2026 will be able to answer the auditor in 2029. GlobX quotes stock location, date code and condition for every line. If you write "PFAS declaration needed" in your RFQ, we will request the manufacturer's current material declaration together with the quote. For the wider substance picture, our REACH compliance guide covers SVHC reporting, which already applies today.
