In mid-March, ECHA will launch the 60-day consultation on the SEAC draft opinion for the proposed universal PFAS restriction.
This consultation is a critical point in the restriction process: it will directly inform the final SEAC opinion and, ultimately, the shape, scope and conditions of any adopted restriction.
The consultation has been carefully designed to ensure that every response matters — including those from individual companies, SMEs and suppliers of alternatives.
Why this consultation is different
For the first time, ECHA has published extensive advance guidance on both the structure and content of the consultation. Respondents will be required to engage with a highly structured, question-driven format, focused on:
- The availability, suitability and feasibility of alternatives
- Quantified socio-economic impacts of the restriction, including turnover, profits and employment
- The practicality and costs of new restriction options that are based on risk management measures rather than bans (called RO3s)
This is not a traditional free-text consultation:
- Responses must be entered directly into EUSurvey
- No attachments are allowed
- Strict character limits apply
- Inputs must align closely with SEAC’s evaluation logic and terminology
Targeted, practical support
Logika Group and Affinity Element are working together to offer bespoke, rapid-turnaround, support to help companies and associations participate effectively and credibly in the SEAC consultation. Together, we combine:
- In-depth experience with the REACH restriction process and the UPFAS proposal, and clear understanding of the needs of SEAC and decision-makers
- Proven socio-economic analysis capability, including assessment of alternatives
We can help to:
- Identify where and how to engage (sector-specific vs general surveys)
- Translate internal knowledge into SEAC-ready responses
- Develop robust, proportionate arguments within tight character limits
- Avoid common pitfalls that reduce the weight of submissions
Who this is for
- Companies directly affected by the PFAS restriction, including SMEs
- Suppliers and developers of PFAS alternatives
- Industry associations coordinating member input
- Organisations that have not yet prepared for the consultation
If you think it may already be too late to engage, it is not — but the window is closing quickly.
If you would like to discuss how to prepare an effective consultation response, now is the time to get in touch.
David Tyrer - davidtyrer@logikagroup.com
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