EU REACH Compliance in 2026: SVHC List and REACH Annex XVII PFAS Restrictions

EU REACH compliance in 2026 requires more than tracking updates. The European Union (EU) is tightening chemical controls under the Registration, Evaluation, and Authorization of Chemicals (REACH) framework, and having reliable supplier data and automated compliance processes is necessary to reduce risk.  For compliance teams, 2026 is a transition year. New documentation, labeling, and risk management obligations begin before the first PFAS prohibition in firefighting foams takes effect in 2030. This blog explains what is changing, who is affected, and which EU PFAS deadlines to prioritize. 

Changes to EU REACH compliance in 2026 

The pace of EU REACH updates is accelerating. Candidate List additions, expanding Annex XVII restrictions, and overlapping PFAS and global regulations are increasing data demands across supply chains. At the same time, regulators have identified widespread non-compliance in registration dossiers and inconsistent enforcement across Member States, increasing the risk of inspections and corrective actions.  

Two REACH developments matter most for compliance teams this year: continued SVHC oversight and new Annex XVII PFAS restrictions with enforceable milestones.

Ongoing SVHC list obligations

Substances of Very High Concern (SVHCs) remain a core REACH obligation. The European Chemicals Agency typically updates the REACH Candidate List in January and June. Each update can immediately trigger new article assessment, SCIP notification, and customer disclosure obligations. While the firefighting foam restriction is the headline update, companies must still: 

• Monitor Candidate List additions (2 new substances in February 2026) 
• Maintain supplier-backed substance data 
• Respond to customer communication duties 
• Update SCIP submissions when new SVHCs are added 

SVHC compliance continues to require accurate part-level visibility and defensible documentation. Manual or spreadsheet-based tracking makes it difficult to respond quickly to mid-year REACH updates. If that foundation is weak, new restrictions become harder to manage. 

EU REACH Annex XVII restrictions in 2026

The major 2026 update is the addition of an Annex XVII entry restricting PFAS in firefighting foams across the EU. Annex XVII of the REACH regulation continues to expand with new substance restrictions, lower concentration thresholds, and sector-specific bans affecting textiles, electronics, and consumer products.  

The addition to Commission Regulation (EU) 2025/1988: 

• Applies the OECD structural definition of PFAS 
• Sets a concentration-based restriction 
• Establishes transition periods through 2030 and 2035 
• Introduces operational, labeling, and management plan requirements 

The result is a structured PFAS firefighting foam phase-out with clearly defined compliance milestones. 

In parallel, ECHA is preparing a second public consultation on its broader PFAS restriction proposal under REACH. The consultation, expected to open in March 2026, will use a new survey-based format and focus on 14 original use sectors. Additionally, the proposed definition of PFAS is broader than the one used for the firefighting foam restriction. Outcomes will inform the final opinion of SEAC, then allowing RAC and SEAC to submit their opinions to the European Commission in late 2026, in view of a final decision.  

For a deeper understanding of EU REACH, read our blog on the differences between REACH, RoHS and CE markings.

Key REACH Annex XVII PFAS deadlines

The full prohibition for PFAS in firefighting foams (above the threshold of 1mg/L) begins in 2030, but October 23, 2026 is the first major compliance trigger in the phase out.  

October 23, 2026: Operational and labeling obligations begin

As of this date: 

• PFAS foams may only be used for Class B fires involving flammable liquids 
• Emissions and exposure must be reduced as low as technically and practically possible 
• Separate collection of unused stock and PFAS-containing waste is required 
• Labeling begins for PFAS-containing firefighting foams placed on the market, excluding portable extinguishers 
• Labeling begins for unused stock and PFAS-containing waste 

This marks the shift from awareness to documented control. 

April 23, 2027: End of most training and testing uses

By this date: 

• PFAS use ends for most training and testing 
• PFAS use ends for public fire services, with limited exceptions 
• Deadline to place alcohol-resistant PFAS foams on the market for portable extinguishers 

2030 prohibition milestones

• December 31, 2030: PFAS use ends in portable fire extinguishers 
• October 23, 2030: Placing on the market and use are broadly prohibited

October 23, 2035: Expiration of extended derogations

Certain high-risk sectors benefit from longer transition periods. These expire in 2035 under defined conditions. 

PFAS management plan requirements

2026 introduces enforceable operational expectations for PFAS management plan requirements. Users, excluding portable fire extinguishers, must establish a site-specific management plan that includes: 

• Use conditions and volumes 
• Collection and adequate treatment of unused stock and waste 
• Equipment cleaning and maintenance procedures 
• Spill response documentation 
• A substitution strategy toward fluorine-free foams 

The plan must be reviewed annually and retained for at least 15 years. 

PFAS labeling and waste handling obligations

As of October 23, 2026, labeling is required in all cases except for portable fire extinguishers.  

The label must state: 

“WARNING: Contains per- and polyfluoroalkyl substances (PFAS) with a concentration equal to or greater than 1 mg/L for the sum of all PFAS”. 

Users must also ensure separate collection, adequate treatment, and labeling of PFAS-containing waste, including wastewater. 

What companies should do now

EU REACH compliance in 2026 requires moving from update tracking to structured program management. Companies should strengthen their compliance infrastructure now and focus on:

• Creating a unified view of substance exposure across all products and markets, not just firefighting foams. 
• Aligning compliance, EHS, procurement, and product teams around shared REACH deadlines and responsibilities. 
• Building scalable processes to respond to biannual Candidate List updates without restarting data collection each time. 
• Preparing for broader PFAS restrictions (and a broader definition) under consultation in 2026. 
• Ensuring documentation is inspection-ready across Member States. 
• Companies that shift from reactive updates to continuous, audit-ready compliance will be better positioned as REACH enforcement intensifies. 

Streamline EU REACH compliance with centralized audit-ready data

EU REACH compliance in 2026 demands validated supplier data, structured documentation, and fast response to regulatory and customer requests. Manual tracking and fragmented records increase risk, especially as SVHC updates and Annex XVII restrictions expand. 

Source Intelligence’s Global REACH solution helps compliance teams reduce risk and maintain market access through automation and expert-built workflows. Our platform equips your team with tools designed to improve visibility, efficiency, and defensibility: 

• Centralize critical compliance data by aggregating supplier declarations, FMDs, lab reports, and certificates in one traceable system. 
• Standardize and automate supplier outreach to improve response rates and reduce manual follow-up. 
• Identify gaps and regulatory risk early with AI-driven validation aligned to SVHC updates and REACH Annex XVII PFAS restrictions. 
• Generate REACH compliance statements on demand to meet audit and customer deadlines with confidence. 

With structured data, automated workflows, and regulatory expertise, Source Intelligence helps teams strengthen REACH compliance and reduce operational risk. Explore how Source Intelligence helps teams manage Global REACH compliance.