EU PFAS Regulatory Update & New EU Toys Regulation

On February 25, 2026, Keller and Heckman LLP Partner Ales Bartl, Ph.D. delivered a REACH 30/30 webinar exploring two of the most consequential developments on the horizon: the upcoming REACH PFAS restriction and the sweeping changes introduced under the new EU Toys Regulation. The summary below highlights the key takeaways from the session.

PFAS Regulation: Key EU & UK Developments 
Efforts to restrict PFAS in the EU are accelerating. The Packaging and Packaging Waste Regulation (PPWR) introduces PFAS limits aligned with the proposed REACH PFAS restriction, applying from August 12, 2026.

There is an unofficial version of Commission Draft Guidance which outlines a stepwise testing approach: (1) total fluorine < 50 mg/kg is compliant; (2) > 50 mg/kg requires analysis to distinguish organic from inorganic fluorine; (3) organic fluorine > 50 mg/kg triggers the need to comply with the 25 ppb limit for targeted PFAS analysis. Ales Bartl provided further insights into the applicability of these limits and practical consequences.

A final 60‑day public consultation is expected in March 2026, focusing on socio‑economic impacts and alternatives. The UK’s February 2026 PFAS Plan emphasizes mapping sources and reducing emissions, with possible UK REACH restrictions by December 2028. An EC study estimates EU costs of €440 billion by 2050 if no PFAS action is taken.

New EU Toys Regulation (2025/2509)
Published December 12, 2025, and applicable August 1, 2030, the new regulation expands chemical safety rules. Restrictions now cover endocrine disruptors, STOT, sensitizers, PFAS use, listed bisphenols, and require consideration of the cocktail effect. Restrictions apply only to substances with harmonized CLP classifications. 

Toys will also require a Digital Product Passport with chemical‑safety data. Connected and AI‑enabled toys must comply with the EU AI Act, Cyber Resilience Act, and Radio Equipment Directive.

View a webinar recording and learn more about the PFAS Regulation and New EU Toys Regulation presented by Partner Ales Bartl, Ph.D.

For more information or questions related to the EU PFAS Regulatory Update or New EU Toys Regulation, contact Ales Bartl, Ph.D. (bartl@khlaw.com or +32 (0) 2 645 5085).

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