[Regulatory Update] "Historical Liability" Spreads to PFAS Manufacturers: The Chemours Settlement Signals a New Era of Lifecycle Regulation for the Chemical Industry

Global Roadmap of PFAS Regulation Worldwide

Purpose and Background PFAS (per- and polyfluoroalkyl substances) have been widely used across semiconductors, automotive, electronics, apparel, and many other industries due to their exceptional heat resistance, water- and oil-repellency, and chemical stability. At the same time, because they do not readily break down in the environment, they are known as "forever chemicals," and the world is now seeing one of the largest-scale regulatory and restriction movements in history. This card provides a cross-regional comparison of PFAS regulatory status and roadmaps across the European Union (EU), the United States (federal and state level), Japan, and China, and outlines the supply-chain implications and practical considerations for businesses. 1. Cross-Regional Comparison of Major PFAS Regulations European Union (EU) — REACH Universal PFAS Restriction Proposal - Status: ECHA is reviewing a restriction proposal covering approximately 10,000 PFAS substances. The RAC adopted its final opinion on March 2, 2026, and SEAC published its draft opinion on March 26, 2026 (public consultation closed May 25, 2026). SEAC's final opinion is expected by end-2026; the timing of the subsequent European Commission and Member State decision remains unconfirmed. - Threshold: Proposed at 25 ppb (0.025 ppm) for total PFAS, or 250 ppb for polymeric PFAS (subject to change in the final restriction text). - Business impact: With the exception of specific hard-to-substitute uses (e.g., semiconductor manufacturing, fluoroelastomer seals), a general use ban is expected to apply following an 18-month transition period after entry into force. Longer exemption or transition periods may be granted for certain uses. United States (Federal) — TSCA Section 8(a)(7) and CERCLA/RCRA Designations - Status: EPA requires reporting of historical manufacturing, import, and article-content data for all PFAS manufactured or imported since 2011. PFOA and PFOS have also been designated as hazardous substances under CERCLA. - Threshold: All intentional additions are reportable (no threshold). - Business impact: Retrospective tracing of PFAS-containing products is required, creating a significant reporting burden for importers and local subsidiaries. United States (State Level) — State Consumer Product PFAS Bans (CA, NY, WA, ME, etc.) - Status: Since late 2023, bans on the sale of products with intentionally added PFAS — including apparel, food packaging, carpets, and cosmetics — have been phased in across multiple states. - Threshold: California applies a Total Organic Fluorine (TOF) threshold of 100 ppm (further tightening is under discussion). - Business impact: Companies handling covered products need to transition to alternative materials and maintain TOF quantitative analysis to demonstrate compliance. Japan — Act on the Evaluation of Chemical Substances (Class I Specified Chemical Substances) - Status: Under the Stockholm Convention (POPs Convention), the manufacture, import, and use of PFOS, PFOA, and PFHxS are, in principle, prohibited. - Threshold: Intentional addition is prohibited. - Business impact: While the transition to alternative substances is largely complete, proper management of existing inventory and disposal of PFAS-containing waste remains an ongoing requirement. International Harmonization Efforts - Status: The OECD and UNEP are leading efforts to harmonize PFAS definitions, scope, and thresholds, which currently vary across jurisdictions. - Business impact: If mutual recognition of environmental and safety standards, and common data submission formats, are achieved in the future, compliance costs for companies operating across multiple regions could be reduced.