Fluoroelastomers such as FKM and FEPM, and the fluoropolymers used to make them, contain carbon-fluorine bonds. Several regulators treat per- and polyfluoroalkyl substances (PFAS) as a group of persistent chemicals. The EU proposal that has attracted most attention would restrict PFAS under REACH.
What has been reported
The proposal was submitted in January 2023 by authorities in Denmark, Germany, the Netherlands, Norway and Sweden, and the European Chemicals Agency's committees have been evaluating it since. According to law-firm and trade reports published in March and April 2026:
- The Risk Assessment Committee (RAC) adopted its opinion in March 2026.
- The Socio-Economic Analysis Committee (SEAC) published a draft opinion in March 2026, followed by a 60-day consultation ending in May 2026, and was expected to finalise its opinion by the end of 2026.
- After that, the European Commission would prepare a legislative proposal, with scrutiny by member states, Parliament and Council.
- The reports describe sealing applications as one of the sectors where SEAC could not complete a use-specific assessment and recommended a time-limited derogation while the evaluation continues. They do not discuss fluoroelastomers by name.
This summary is a snapshot from secondary sources. Scope, derogations and dates are changing, so check ECHA and your trade body for the current position.
What it could mean for FKM and FEPM
- Possible restrictions on placing on the market, with transition periods.
- Documentation and essential-use arguments: buyers may ask suppliers where a fluoro-rubber is critical and no substitute exists.
- Supply risk: some polymer producers have announced exits or changes in fluoropolymer production for their own reasons, which can affect availability and prices.
- Pressure to find alternatives for non-critical uses, such as HNBR in place of FKM where the conditions allow.
What you can do now
- Keep the fluoro-rubber and non-fluorinated options in your qualification plans. For each application, document why the performance is needed.
- Ask suppliers for their regulatory position and for substance and polymer information.
- Track supply of polymer grades and have a second source or a second approved polymer.
- Keep records of the use, volumes and customers so that you can respond to information requests.
Sources and further reading
- Linklaters: EU universal PFAS restriction process enters its decisive phase (9 April 2026).
- European Rubber Journal: ECHA committee concludes PFAS restriction evaluation (6 March 2026).
- ECHA website, for the current status.
About this guide. It is an original summary written from public sources and standards. It is not a copy of any standard or book, and it is not engineering advice. Confirm values against the current edition of the standard and test in your own application.