European Space Restrictions Task Force scrutinises latest ECHA files on Universal PFAS and Chrome VI

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At its 8th meeting on 9 September 2025 (by WebEx) the European Space Restrictions Task Force (RTF) held its third 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 still with the European Chemicals Agency (ECHA).

The meeting was also attended by members of the Chromates Space Task Force (STF), in order to prepare the joint contribution for the on-going ECHA public consultation on the ECHA restriction proposal for Chrome VI.

Overall, 22 participants from industry, space agencies and the European Defence Agency (EDA) joined, reflecting the continued high interest in these regulatory proposals, with possible significant impacts in particular for Universal PFAS.

The European Space Agency (ESA) REACH Officer provided an update on ESA’s ‘Phase 2’ activities to map the impact of the Universal PFAS restriction proposal and collect information about additional uses for the upcoming 2nd ECHA public consultation on the draft opinion of the ECHA Committee for Socio-Economic Analysis (SEAC), which is now expected in spring 2026.

Status summary and next steps for Universal PFAS and Chrome VI proposals:

  • Universal PFAS restriction proposal under EU REACH: On 20 August 2025, ECHA published the updated PFAS restriction proposal by the five national authorities from Denmark, Germany, the Netherlands, Norway and Sweden (available HERE). This update completes the authorities’ evaluation of the more than 5 600 comments received from stakeholders – including Eurospace – during the 2023 ECHA public consultation. In the meantime, the ECHA scientific committees (SEAC and RAC, the Committee for Risk Assessment) have progressed their assessment of the (updated) restriction proposal: The last SEAC-67 meeting earlier in September 2025 (ECHA highlights available HERE) was again attended by Eurospace (as ECHA Accredited Stakeholder Organisation) and ESA (as occasional observer), further to their participation in the previous SEAC-66 (June 2025) and SEAC-65 (March 2025) meetings. In terms of next steps, the RTF is now preparing for the abovementioned 2nd ECHA public consultation on the SEAC draft opinion expected in spring 2026. The final ECHA opinion is currently expected by the end of 2026. As soon as possible thereafter, the European Commission intends to present its own restriction proposal.

While there has been a stark increase in the number of derogation proposals in the updated restriction proposal, space applications of PFAS are regretfully still not reflected as such in proposed derogations from the envisaged comprehensive ban, but only in a general way as part of other “sectors”, such as transport, electronics or lubricants. This derogation “patchwork” – if eventually adopted – would be very complex to apply and present a high risk that some needed derogation proposals are still not available at the end of the 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 published a restriction proposal for certain Chrome VI substances in 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 ECHA restriction proposal is currently subject to a 6-month ECHA public consultation of stakeholders from 18 June 2025 – 18 December 2025. Eurospace, acting with the support of the STF, has already submitted a first joint sectorial response to ECHA on 17 September 2025 (ref. MPTB-ES-PO-0202), which generally supports the intent to de-list Cr(VI) substances from the REACH authorisation list in the interest of legal certainty and enhancing competitiveness of the European space business, but also raises some points of concern given the broader scope of the restriction; the response has been published on the ECHA website (HERE, see ECHA comment ID 9662).

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 Issue 8 of the European Space Sector Compliance Guidelines, focusing on the use of Henkel formulations formerly known as ‘Alodine’, has recently been published on the Eurospace website, available HERE.

Updated list of RTF participants

Current RTF members include:

Industry: Airbus Defence and Space, ArianeGroup, Avio, Beyond Gravity, ESR Technology (ESTL), HPS GmbH (new member since RTF-7), INVENT GmbH (new since RTF-8), 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.

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