European Space Restrictions Task Force discusses progress on EU REACH proposals for Universal PFAS and Chrome VI

by

At its 7th meeting on 28 May 2025 (by WebEx) the European Space Restrictions Task Force (RTF) held its second meeting of the year to discuss the progress and next steps on the EU REACH restriction processes for Universal PFAS and Chrome VI, which are currently with the European Chemicals Agency (ECHA).

The meeting was also attended by members of the Materials and Processes Technology Board (MPTB) and the Chromates Space Task Force (STF). Overall, 26 participants from industry, space agencies and the European Defence Agency (EDA) joined the meeting, reflecting the continued high interest in these topics.

The European Space Agency (ESA) REACH Officer provided an update on ESA’s activities to map the impact of the Universal PFAS restriction proposal and plans to collect information about additional uses for the upcoming 2nd ECHA public consultation.

Status summary of Universal PFAS and Chrome VI restriction initiatives:

  • Universal PFAS restriction proposal under EU REACH: The proposal is progressively updated by the five national authorities from Denmark, Germany, the Netherlands, Norway and Sweden and is concurrently assessed on a per-sector basis in the ECHA Committees for Risk Assessment (RAC) and Socio-Econonomic Analysis (SEAC).

At the last SEAC-66 meeting in March 2025 Eurospace (as ECHA Accredited Stakeholder Organisation) and ESA (as occasional observer), both attending this meeting for the first time, recalled the detailed Eurospace (RTF) input to the restriction process of 22 September 2023 and reiterated the vital request for a specific recognition of ‘equipment designed to be sent into space’ as part of a dedicated derogation for concerned PFAS uses.

The European Space Sector is also represented at the SEAC-67 meeting on 10/12 June 2025 which addresses relevant PFAS-using sectors for space applications, namely “transport” and “lubricants”.

As such, space applications of PFAS are currently not reflected in proposed derogations from the envisaged comprehensive ban, but only in a general way as part of other “sectors”. This presents a high risk that some needed derogation proposals are still not available at the end of the ECHA process. The Eurospace (RTF) initial contribution to the restriction proposal is available HERE, and summaries in five languages HERE.

  • Chrome VI restriction proposal under EU REACH: Acting on the request of the European Commission, ECHA has now published a restriction proposal for certain Chrome VI substances on 29 April 2025 (available HERE). This restriction would eventually aim to replace the authorisation system for these substances. The ECHA proposal foresees a ban of the use of Chrome VI substances in the European Economic Area unless they fall in a “closed list” of six use categories (including surface treatments such as chemical conversion coating) and users comply with defined scientific limit values for worker exposure and emissions of Cr(VI) to the environment. The restriction proposal will be subject to a 6-month ECHA public consultation of stakeholders, which is expected to start on 18 June 2025. A joint sectorial response through Eurospace is being investigated.

On Chrome VI it is important to note that for the time being (i.e. until conclusion and entry into effect of a restriction replacing it), these substances remain subject to the authorisation process. The latest European Space Sector Compliance Guidelines, focusing on the use of Henkel formulations formerly known as ‘Alodine’, have recently been published on the Eurospace website, available HERE.

Updated RTF Terms of Reference and membership:

The RTF has revised its terms of reference in January 2025 to operate on a long-term basis, given the increasing number and duration of restriction processes, including but not limited to the key initiatives mentioned above.

Current RTF members include:

Industry: Airbus Defence and Space, ArianeGroup, Avio, Beyond Gravity, ESR Technology (ESTL), HPS GmbH (new member since RTF-7), Leonardo Company, Maxon International AG, OHB, Safran Aero Boosters, Thales Alenia Space, W.L. Gore & Associés S.A.R.L.

Agencies: European Space Agency (ESA), Agenzia Spaziale Italiana (ASI), Centre National d’Etudes Spatiales (CNES) and Deutsches Zentrum für Luft- und Raumfahrt e.V. (DLR)

Observer: European Defence Agency (EDA)

Independent research organisations: Max Planck Institute for Extraterrestrial Physics, TNO

Secretariat: ASD-Eurospace

Consultant: REACHLaw

The group is an open forum. New participants with a Space Sector interest, including those from outside the MPTB, may be admitted.

The RTF has been established in 2023 within the European Space Components Coordination (ESCC) system by initiative of the Materials and Processes Technology Board (MPTB), which is currently chaired by the ESA REACH Officer.

Next meeting:

The next 8th meeting of the RTF will probably be held in the beginning of September 2025 (to be confirmed).

Contact for further information:

  • 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