European Space Restrictions Task Force kicks off activities for 2025 – EU REACH regulatory proposals for Universal PFAS and Chrome VI on top of the agenda

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At its 6th meeting on 16 January 2025 (by WebEx) the European Space Restrictions Task Force (RTF) has taken stock of the state of the play of on-going restriction proposals under EU REACH and the Stockholm Convention on Persistent Organic Pollutants (POPs), and discussed milestones ahead in 2025 to progress these files.

The meeting was also attended by members of the Materials and Processes Technology Board (MPTB) and the Chromates Space Task Force (STF). Overall, 44 participants joined the meeting.

Status summary of key restriction initiatives of interest for the Space Sector:

  • Universal PFAS restriction proposal under EU REACH: The proposal is currently updated by the five national authorities and concurrently assessed on a per-sector basis in the ECHA Committees for Risk Assessment and Socio-Econonomic Analysis. The upcoming ECHA Committee meetings in March 2025 will discuss relevant sectors for space applications, especially “transport”. Eurospace hopes to be admitted to attend the discussions as an ECHA Accredited Stakeholder Organisation since June 2024.

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 is expected to submit a restriction proposal for certain Chrome VI substances in April 2025 which would eventually aim to replace the authorisation system for these substances. There are no detailed insights at this point as to the possible content of the restriction, but existing conditions for authorised uses could be one element. The restriction proposal would be followed by a 6-month ECHA public consultation of stakeholders.
  • Bisphenol A and bisphenols of similar concern: After the withdrawal of a restriction proposal by Germany in 2023 for re-assessment detailed plans and timelines for updated or new restriction proposals are currently not known. A regulatory status overview for Bisphenol A is available on the ESCIES website (MPTB-RL-MO-0164).
  • POPs restriction initiatives: The RTF is also following on-going restriction initiatives under the UN Stockholm Convention on POPs, which is implemented in the EU through Regulation (EU) 2019/1021. Concerns arise in particular from the potential EU nomination of D4-6 cyclic siloxanes to the Stockholm Convention.

Updated RTF Terms of Reference and membership:

The RTF has now revised its terms of reference 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), 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 7th meeting of the RTF (by WebEx) is scheduled for Wednesday, 28 May 2025.

Contact for further information:

  • Secretariat: Pierre Lionnet, Research & Managing Director, ASD-EUROSPACE, pierre.lionnet@eurospace.org, +33 (0)1 44 42 00 70
  • RTF Coordinator: Tim Becker, Senior Legal Advisor, REACHLaw Ltd., tim.becker@reachlaw.fi; +358 (0)40 773 8143