Socio-Economic Analysis for a Reach Restriction Proposal on PFAS in the Upstream Oil & Gas, Oil Refining and Fuel Distribution Sectors, and in Carbon Capture and Storage

This study has been commissioned by Concawe and IOGP to provide an independent Socio-Economic Analysis (SEA for the potential EU REACH restriction of Per- and polyfluoroalkyl substances (PFAS).

This analysis focuses on upstream Oil & Gas (O&G), carbon capture and storage (CCS), refinery operations, renewable fuels and fuel distribution sectors.

This study served as the basis of IOGP Europe's response to the European Chemical Agency’s (ECHA) Socio-Economic Committee (SEAC) draft Opinion of the proposed ‘Universal-PFAS Restriction’.

Building on IOGP Europe’s PFAS Restriction Position Statement of January 2026, and underpinned by this independent socio-economic analysis of the potential impacts of a Universal PFAS Restriction on the oil, gas, and carbon capture and storage (CCS) sectors IOGP Europe’s response:

• acknowledges that certain PFAS compounds are persistent, bioaccumulative / mobile and toxic, widely distributed in the environment, and justify further control;
• describes how not all PFAS are alike: ranging from liquid/ aqueous fluorosurfactants to F-gases, to solid fluoropolymers and elastomers, the hazard properties vary greatly amongst the PFAS family;
• explains that use of fluoropolymers in industrial components and composite materials are unlikely to generate significant environmental emissions or risks;
• outlines how the oil and gas sector already uses PFAS-free alternatives for certain uses (including some hydrocarbon reservoir tracers, anti-foam agents), but notes that there are no known alternatives for the fluoropolymers and fluoroelastomers that are needed to meet the challenging requirements  (high temperature stability,  chemical corrosion resistant, low-friction and material flexibility) to maintain safe and reliable operations;
• demonstrates that the costs of a restriction on polymeric-PFAS outweigh the environmental and social benefits that would be derived;
• advocates to exclude fluoropolymers and fluoroelastomers from the proposed Restriction, whilst recognising that stronger controls on fluoropolymer production (under the EU Industrial Emissions Directive) and end-of-life materials management may be required;

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