PFAS Update: Guidance for SEAC Consultation Respondents and Updated Mapping of Sector Uses

Dec 19, 2025

by Diana Radovan, Global Electronics Association Sustainability Policy Director

The European Chemicals Agency (ECHA) has released guidelines and an extensive mapping of PFAS uses to support stakeholders participating in the consultation process on the draft opinion of the Committee for Socio-Economic Analysis (SEAC) regarding PFAS restrictions. https://echa.europa.eu/hot-topics/perfluoroalkyl-chemicals-pfas. 

The guidance is consistent with the information provided in the recent ECHA webinar on this matter and describes the structure and procedures of the two types of planned surveys, as well as the specific questions that will be asked, which will include single and multiple choice, numerical, and open-ended responses, with a character limit of up to 5000.  The consultation will open shortly after SEAC’s meeting in March 2026 (now scheduled for 9-13 March) and will run for 60 days. 

Below we provide further explanations on each document, how it will be used, and next steps. 

    A) Guidance for Respondents of the SEAC draft opinion consultation

This is the practical handbook for anyone planning to submit input. It sets out how the consultation will work and what SEAC needs from respondents. There will be two survey tracks: 

  • Sector-specific survey: focusing on sector-specific evaluations of uses for 14 sectors of use and for PFAS manufacturing. 
    The scope of the SEAC evaluation will vary by sector and information requested will range from specific sues to sub uses and individual applications as described PFAS use mapping. This scope is referred as the SEAC evaluation level. 
    The questions of this survey focus on alternatives, volumes and impacts for the organisation and the society. For the relevant sectors there is a question on the cost of feasibility of Restriction Option 3.
  • General survey: This survey contains questions related to the main sections of the SEAC draft opinion, which apply across all sectors. Comments should clearly reference the corresponding sections and conclusions of the opinion and specify the relevant sectors from which the comments are drawn.

The emphasis is on socio‑economic evidence—availability and feasibility of alternatives, expected costs and benefits, timing for substitution, potential business impacts (including profits and jobs), and practicality/enforceability of the options under discussion. SEAC will not consider hazard or exposure data (such tasks belong to the Committees for Risk Assessment (RAC). 

The Guidance also covers the logistics (EU Login, EUSurvey, saving drafts securely) and how to flag confidential information correctly so sensitive data is treated appropriately. Attachments and external links will not be accepted—everything will be typed into the survey fields. 

The Guidance already includes the full set of draft survey questions that we will see in EUSurvey (Section 4), so that we can start preparing your answers now (wording, character limits, conditional logic are all shown). Minor adjustments may still occur before launch.

    B) Updated draft mapping of PFAS uses

The document describes each PFAS sector, breaks it down into use categories → sub‑uses → applications, and ends at the SEAC evaluation level—the unit SEAC uses in its assessment. It also clarifies what is in scope and what is not for each sector, so that misclassifying a use can be avoided. Beyond the 14 sectors SEAC evaluated, the annex lists the 8 additional sectors identified in the updated Annex XV report that are covered via the general survey.

The final version is expected to be published when the SEAC consultation opens in spring 2026.

We recommend to:

  • Locate your uses in the Use‑mapping and note the corresponding SEAC evaluation levels you intend to comment on.
  • Start drafting concise evidence per evaluation level on: alternatives (existence and sufficiency), technical/economic feasibility, safety aspects of substitution, PFAS tonnages used/imported, substitution timelines, and the likely operational/employment/product‑availability impacts if PFAS cannot be used.
  • Review implementation costs where relevant (e.g., reporting requirements; site‑specific PFAS management plans; monitoring of emissions at industrial sites) so you can indicate magnitude where the survey asks for it.
  • Set up your EU Login early and plan to copy/paste prepared responses into EUSurvey (attachments and external links won’t be accepted).

The Global Electronics Association will also submit consolidated answers on behalf of members across the entire electronics value chain. To get involved, contact me at DianaRadovan@electronics.org.