ZeroPM Regulatory Watch

As the EU Green Deal roles out, the ZeroPM regulatory watch will announce upcoming initiatives related to persistent and mobile substances. Our most recent update was prepared on November 10th 2025.

Council conclusions on water resilience call for tackling PFAS (including TFA) pollution at source

EU environment ministers adopted at the Environment Council on 21 October Council conclusions on the European water resilience strategy, published by the Commission in June 2025. In the conclusions, ministers ‘underline the need to address and prevent water pollution at source, including excess nutrients and persistent and emerging pollutants, such as PFAS, including TFA’. They ‘urge the Commission to take the necessary measures […] to phase out the most harmful chemicals’ and stress ‘the urgency for the Union to tackle pollutants at the source that pose a risk to our vital sources of drinking water’. The conclusions invite the Commission to ‘report on the progress of the strategy’s implementation’ and to ‘undertake a mid-term review […] by 2027’.

Unclear timeline for legislative proposal on the revision of REACH following negative opinion on impact assessment

End of September the Commission confirmed that the impact assessment accompanying the revision of the REACH Regulation had received a negative opinion from the Regulatory Scrutiny Board, an independent body in the Commission providing quality control for the Commission’s impact assessments. Following the negative opinion, an amended impact assessment will need to be resubmitted to the Board, which will cause delays in the publication of the legislative proposal, until now planned for Q4 2025.

At the Environmental Council on 21 October, Sweden, Austria, Belgium, France, Spain, the Netherlands, Luxembourg, Lithuania, Hungary, and Slovakia called for clarification on the timeline for the proposal. They also underlined that the revision should not only be a simplification exercise but a real modernisation of REACH to make the legislation more efficient and protect better human health and the environment. In its response to Member States, the Commissioner for Environment, Jessica Roswall, confirmed that the main priorities for the revision have not changed and indicated that the Commission services are ‘fully engaged’ in strengthening the impact assessment underpinning the legislative proposal, without providing a timeline for resubmitting to the Regulatory Scrutiny Board.

Denmark bans the use of 8 more PPPs containing active substances degrading into TFA

The Danish Environmental Protection Agency withdrawn in July 2025 the approval of 25 plant protection products containing six active substances (fluazinam, fluopyram, diflufenican, mefentrifluconazole, tau-fluvalinate, and flonicamid) on the grounds that these six active substances degrade into TFA and leachate TFA to groundwater. On 30 September 2025, the Agency announced having withdrawn the approval of eight more plant protection products containing those six active substances, bringing the number of banned products to 33. Deadline for possession and use of these eight products are set in December 2025, August 2026 and November 2026 depending on the product.

Updates on legislative / regulatory procedures:

  • Restriction on PFAS in firefighting foams adopted: The REACH restriction on PFAS in firefighting foams was adopted on 3 October by the Commission and entered into force on 23 October. The restriction will take effect following transitional periods from one to ten years depending on the use.
  • Soil Monitoring Directive adopted by co-legislators: Following the adoption of the provisional agreement on the Soil Monitoring Directive by the Council on 29 September, the European Parliament formally adopted the act in plenary on 23 October. The act is now awaiting signature before publication in the Official Journal and entry into force.
  • Provisional agreement on the revision of water legislation published: the text of the provisional agreement reached by Council and Parliament on 23 September was published on 9 October. A full overview of the agreement is provided in the excel sheet; main points are summarised below:
    • PFAS and TFA: a surface water quality standard is created for the sum of 25 PFAS (Sum of 24 PFAS from the original Commission proposal + TFA) – 0,0044 µg/L in water and 0,077 µg/L in biota. The groundwater parameter for the Sum of PFAS is aligned with the Drinking Water Directive (PFAS 20 0,10 µg/L) and a quality standard for the Sum of 4 PFAS is created (0,0044 µg/L). In the next review of quality standards, the Commission should consider establishing quality standards for PFAS Total and TFA (separately) in surface waters and groundwater. The Commission is also tasked with supplementing the guidance on monitoring PFAS Total to cover surface and groundwater.
    • Pesticides: a surface water quality standard is created for the ‘Sum of active substances in pesticides’ for which an EQS is set in the Directive (0.2 µg/L). In the next review of quality standards, the Commission should consider the possible inclusion of a surface water quality standard for the ‘Sum of selected pesticides by ‘mode of action’’. A new groundwater quality standard is created for non-relevant metabolite of pesticides. Within two years of the entry into force of the Directive, the Commission must adopt a list of known pesticide metabolites indicating which are relevant and non-relevant (and update it every 6 years). In the next review of groundwater quality standards, the Commission should consider whether to revise the quality standards pesticides (individual and total) and for non-relevant metabolites.
    • Pharmaceuticals: At the next review of the surface and groundwater quality standards, the Commission should consider the introduction of a quality standard for the ‘sum of selected pharmaceuticals by mode of action’ in surface and groundwater.
    • Application and review of quality standards: new quality standards will take effect from 22 December 2027, with the aim of achieving good surface water chemical status in relation to those substances by 22 December 2039. The Commission is tasked with reviewing the surface and groundwater quality standards every six years and, where appropriate, to issue a legislative proposal for the revision of the standards. ECHA is tasked to prepare scientific reports to support the review, including proposals for quality standards or threshold values and analytical methods.
    • Surface and groundwater watchlists: the surface and groundwater watchlists have to be established two years after the entry into force of the Directive and then updated every three years. The groundwater watchlist is capped to five substances, the surface water watchlist to ten substances. Member States have to monitor each substance on the watchlists over a 24-month period. ECHA is tasked to prepare scientific reports to support the review of the watchlists, which will contain a list of candidate substances and indicative analysis methods and maximum acceptable limits of quantification for each substance.
    • Joint monitoring facility: the agreement tasks the Commission with publishing within 18 months of the entry into force of the Directive a report on options for the establishment, financing and functioning of a joint European monitoring facility and if appropriate, to put forward a legislative proposal in order to establish it.
    • Extended producer responsibility: the agreement tasks the Commission to publish a report within three years on the possibility to include an extended producer responsibility mechanism in the Water Framework Directive. The report should evaluate the feasibility of requiring producers that place on the EU market products containing any of the substances that have an EQS or a groundwater quality standard to contribute to the costs of monitoring programmes.

Upcoming consultation deadlines:

  • Deadline to provide feedback the proposed founding regulation for ECHA: 2 December 2025.

Gantt Chart of upcoming actions related to persistent and mobile substances

Gantt chart November 2025Download

Spreadsheet for further information

The ZeroPM regulatory watch itself is presented in this spreadsheet, which contains links for further information. This can be downloaded below.

The ZeroPM regulatory watch was last updated on 2025-11-10.

Regulatory watch – overview of regulatory initiatives-November 2025Download

ZeroPM Regulatory Watch Year in Review 2024

Need a recap of all the updates on EU policy initiatives contributing to the prevention, prioritisation and removal of PFAS and PMT/vPvM substances in 2024? We have compiled the biggest updates in 2024, as well as a list of issues we are looking towards in 2025 in the following document, which can be downloaded here.

ZeroPM Regulatory Watch Year in Review 2023

The recap of all the updates on EU policy initiatives contributing on PFAS and and PMT/vPvM substances can be found below.

Please see also our video explaining the ZeroPM regulatory watch!