“Universal PFAS”: European Space Sector comments on socio-economic assessment sent to ECHA, urging EU policy makers to move away from universal ban model

ASD-Eurospace is pleased to announce that we have submitted the European Space Sector response to the European Chemicals Agency’s (ECHA) consultation on the SEAC (Socio-Economic Analysis Committee) Draft Opinion concerning the proposed universal PFAS restriction on 22 May 2026.

Key points delivered with the response:

According to the response, the current “ban-with-derogations” approach could seriously undermine Europe’s space capabilities.

PFAS substances remain indispensable across a wide range of European space applications, including satellites, launchers, propulsion systems, thermal insulation, photonic sensors, cable systems, hydraulic systems, semiconductor equipment and defence-related space infrastructure. Further to the input provided by ASD-Eurospace for the 1^st ECHA public consultation in 2023, many additional PFAS-dependent applications have been identified, and viable substitutes are still unavailable for mission-critical uses.

The response recalls – substantiated by further data collected by the European Space Agency (ESA) – that the European Space Sector operates with extremely low PFAS volumes and negligible terrestrial emissions, making the proposed restriction disproportionate compared with its potential environmental benefits. Space hardware is fundamentally different from mass-market industrial sectors currently grouped under the proposal, such as transport, electronics or lubricants. We strongly object the restriction dossier approach of bundling spacecraft into the “transport” category alongside cars and other high-emission products, despite vastly different use patterns and risk profiles.

A central demand of our submission is the addition of a dedicated aerospace and defence (A&D) derogation which would cover all civil and military space applications in a single provision. The current patchwork of sector-specific derogations leaves critical uses uncovered and creates legal uncertainty for manufacturers and suppliers. We also reject the proposed transition timelines of 18 months to 12 years, because qualification cycles for space hardware often exceed two decades and PFAS-free technologies typically do not exist yet.

Our response further highlights the strategic implications for European sovereignty and security. If the restriction proposal was adopted and implemented, it could jeopardise Europe’s independent access to space, create structural risks to Europe’s security and technological autonomy, and threaten the on-going and future cooperation with international partners such as NASA and JAXA. Also, since many space and defence technologies rely on shared supply chains, a loss of access to critical PFAS materials would simultaneously affect both sectors. We also fear that unilateral EU action risks increasing strategic dependencies on non-European suppliers.

In case of a universal PFAS ban without effective derogations, it is estimated that current European space systems could no longer be designed, manufactured or operated. For ESA hardware launched in 2024 alone, the estimated cost at completion was approximately €6.9 billion, while the total PFAS content amounted to only several hundred kilograms. This demonstrates an extreme disproportion between the regulatory risk and achievable environmental benefit.

Our submission also challenges SEAC’s assessment methodology, arguing that the committee itself acknowledges major gaps in data, socio-economic analysis and sector coverage. These uncertainties make it impossible to conclude that a broad PFAS restriction is the “most appropriate EU-wide measure.” We further criticise the PFAS definition used in the proposal as overly broad and scientifically insufficient.

Concerns are also raised about the practicality and enforceability of proposed reporting obligations. Importers of complex space hardware would be unable to obtain the detailed PFAS composition data required from non-EU suppliers. Furthermore, mandatory disclosures could conflict with defence, security and dual-use confidentiality requirements. Our response therefore calls for space applications to be excluded from ECHA reporting obligations and site-specific PFAS management plan requirements.

Conclusion

Continued PFAS use in space applications – combined with upstream emission controls and targeted risk management measures – would represent a more proportionate and effective policy approach than the current restriction proposal. We therefore urge EU policymakers to move away from a universal ban model toward a more targeted and science-based regulatory approach aligned with other international frameworks.

Preparation by Space Restrictions Task Force 

This is the second contribution to the universal PFAS restriction initiative of ASD-Eurospace (internal ref. # MPTB-ES-PO-0225); it builds and follows on the first set of inputs to the 2023 ECHA public consultation (ECHA #8544, internal ref. # MPTB-ES-PO-0131). It has been prepared with the support of the Space Restrictions Task Force (RTF) of European space companies, key suppliers, the European Space Agency (ESA) and national space agencies as well as independent research organisations and REACHLaw Ltd. as a consultant. Observers to the RTF include the European Defence Agency (EDA) and the Aerospace, Security and Defence Industries Association of Europe (ASD).

Further information

• Eurospace (RTF) response submitted on 22 May 2026 to the ECHA public consultation on the SEAC Draft Opinion (internal ref. # MPTB-ES-PO-0225) – The response will be published on the ECHA website here
• Eurospace news alert of 25 September 2023 on the 1st RTF consultation response on UPFAS to ECHA in 2023, available here
• Eurospace news alert of 27 February 2023 on the Space Restrictions Task Force kick-off, available here
• Secretariat: Valentin Marie, Research Analyst & Compliance Manager, ASD-EUROSPACE, valentin.marie@eurospace.org, +33 (0) 7 86 58 74 34
• RTF Coordinator: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143