Per and polyfluoroalkyl substances (PFAS) remain at the center of regulatory activity worldwide, with glimmers of accelerated standards, enhanced enforcement, and more stringent product restrictions. While U.S. federal regulation remains fragmented and incremental, international frameworks are changing. This is particularly true across the European Union (EU), where the regulatory agenda is progressing toward a near-total class-based PFAS restriction. Plus, select Middle Eastern countries are advancing rapidly toward stricter standards, class-based restrictions, and enhanced enforcement.
For U.S. insurers underwriting multinational risks, these global developments signal a shift that warrants attention and raises critical questions: Are insureds operating within expanding compliance blind spots? And are carriers fully accounting for the downstream liability, remediation, and business interruption exposures created by divergent global PFAS regimes?
These questions are no longer theoretical. They are being answered first, and most decisively, outside the United States, beginning with the European Union.
European Union: Accelerating Toward Class-Based PFAS Restrictions
EU regulators are moving beyond incremental controls toward a precautionary, class-based PFAS framework that materially alters liability, remediation, and operational risks for insureds operating in or supplying the EU market. The following are key elements of this evolving regulatory landscape and their implications for multinational insurers:
1. PFAS Restriction Proposal
The European Chemicals Agency (ECHA) confirmed that its scientific committees resumed evaluation of the proposed universal PFAS restriction in September 2025, with a particular focus on sector-specific impacts across:
- Electronics and semiconductors
- Manufacturing and industrial processes
- Lubricants and specialty chemicals
- Energy and infrastructure systems
Final scientific opinions are anticipated in late 2026. This is a milestone expected to shape not only EU compliance obligations but also global supply chain expectations and product design standards. A near total class-based PFAS ban remains a central policy objective.
Insurance Implications: Broad class-based restrictions will increase the likelihood of legacy contamination claims, stranded assets, and accelerated substitution risks tied to insured product portfolios in the EU.
2. EU Chemicals Action Plan (July 2025)
The European Commission’s Chemicals Action Plan establishes a coordinated framework that includes:
- An EU-wide PFAS monitoring and reporting system
- Mapping of PFAS pollution “hot spots”
- Harmonized remediation strategies across member states
- Alignment with Safe and Sustainable by Design (SSbD) principles
The Plan explicitly encourages innovation in PFAS alternatives while increasing scrutiny of legacy contamination.
Insurance implications: Expansion of monitoring and hotspot mapping creates clearer pathways for identifying responsible parties, increasing litigation predictability and claim frequency.
3. Firefighting Foam Restrictions
As of October 2025, the European Commission formally restricted PFAS-containing firefighting foams following a multiyear scientific review process.
Insurance implications: Airports, industrial sites, ports, and municipal entities face heightened exposure for historical foam usage, with potential impacts on environmental liability, public entity coverage, and reinsurance assumptions.
Spotlight on France: Heightened PFAS Controls
France has emerged as one of the EU’s most proactive PFAS regulators, combining early product bans, import controls, and litigation activity that set it apart from broader EU initiatives, including the following:
- Statutory bans on PFAS in cosmetics, waxes, and textiles above defined thresholds beginning in 2026, with broader expansion by 2030
- Litigation against cookware manufacturers for allegedly misleading marketing of polytetrafluoroethylene (PTFE) based products as “safe”
- Introduction of a hazardous chemical import tax, targeting small, PFAS-containing consumer imports—particularly from China
Insurance implications: Product liability, false advertising, and import-related enforcement actions elevate both defense and indemnity risk for global manufacturers and distributors.
Developments Outside the EU: Emerging Regulatory Risk Hotspots
In jurisdictions beyond the EU, regulators are moving quickly toward class-based PFAS controls and stricter enforcement, creating emerging liability, operational, and compliance risks for insurers with multinational exposures.
United Arab Emirates (UAE): Stringent Drinking Water Standards in Force
The UAE has enacted one of the most restrictive national PFAS drinking water standards globally:
- Total PFAS limit: 0.0001 milligrams per liter (mg/L)/ 0.1 micrograms per liter (µg/L), effective January 2025
- Mandatory routine monitoring and inspections
- 24-hour notification requirement for exceedances, followed by corrective reporting within seven days
Failure to comply may result in administrative fines, license suspension or facility closure, and public disclosure in cases involving negligence.
Insurance implications: Strict thresholds and rapid response obligations heighten operational risk for insureds in water-intensive industries and create loss triggers tied to regulatory noncompliance.
Israel: Rapidly Expanding Multi-Agency PFAS Oversight
Israel is advancing PFAS governance through coordinated action across ministries:
- Establishment of an interministerial PFAS task force
- Environmental compliance mandates addressing PFAS emissions and use
- Nationwide PFAS monitoring of drinking water
- Development of human biomonitoring guidance, signaling future public health-based exposure thresholds
Insurance implications: Israel is trending toward EU-style chemical controls, increasing longtail environmental and bodily injury exposure for industrial and municipal insureds.
Egypt: Limited PFAS Controls Despite Treaty Commitments
Although Egypt has been a party to the Stockholm Convention since 2004, national implementation remains substantially outdated:
- No PFAS-specific environmental or drinking water standards
- National Implementation Plan last updated in 2005
- Perfluoro octane sulfonic acid (PFOS), perfluorooctanoic acid (PFOA), and newer PFAS not covered in domestic regulation
Insurance implications: The absence of current regulation creates uncertainty; however, future regulatory acceleration could substantially increase retroactive liability exposure for multinational operators.
Saudi Arabia: Expanding PFAS Controls and Remediation Demand
Saudi Arabia is strengthening environmental regulation as part of broader economic modernization initiatives, including:
- Development of PFAS discharge limits
- Expanded remediation requirements
- Alignment with international environmental best practices
Oversight responsibilities are shared among water and environmental authorities, and remediation services are expanding alongside infrastructure growth and ESG commitments.
Insurance implications: Growth in remediation activity increases contractor exposure and professional liability risk while signaling future tightening of regulatory enforcement.
Global Framework vs. the U.S. Regulatory Patchwork
Globally, PFAS regulation is accelerating through class-based bans, expanded monitoring, and aggressive enforcement. By contrast, the United States remains divided:
- Federal Environmental Protection Agency (EPA) initiatives have narrowed in scope and pace
- States are driving the most stringent—and fragmented—PFAS requirements worldwide
Insurance implications: For insurers, this divergence complicates portfolio risk modeling, claims forecasting, and underwriting consistency, particularly for insureds operating across borders.
A Structural and Risk Allocation Comparison
Core Philosophical Difference: Risk-Based vs. Precautionary Regulation
Regulatory philosophy is the most consequential difference between U.S. and global PFAS regimes, influencing how rules are set, enforced, and experienced by insureds worldwide. United States: Risk-Based, Chemical Specific Regulation
U.S. PFAS regulation is grounded in a risk-based, substance-specific framework, requiring:
- Demonstrated toxicity, exposure pathways, and dose response data
- Individual chemical evaluations rather than class-wide controls
- Extensive notice and comment rulemaking under statutes such as the Safe Drinking Water Act (SDWA) and Toxic Substances Control Act (TSCA)
As a result, federal rules develop slowly, are chemically narrow, and are vulnerable to legal challenge. Even where PFAS are regulated, compliance timelines are extended and enforcement is cautious.
Global (EU-Led): Precautionary, Class-Based Controls
By contrast, the European Union and several non-EU jurisdictions apply the precautionary principle, allowing restrictions based on persistence, bioaccumulation, or uncertainty—without requiring chemical-by-chemical proof of harm.
This has enabled:
- Broad PFAS class definitions that include thousands of compounds
- Proactive bans and use restrictions
- Faster regulatory escalation once hazard concerns are identified
This philosophical divide drives nearly all downstream risk implications for insurers.
Scope of Regulation: Narrow U.S. Federal Focus vs. Expansive Global Coverage
The philosophical differences between U.S. and global PFAS regulation are reflected in the scope and structure of rules themselves; from the narrowly defined federal standards in the United States to the broad, class-based restrictions and monitoring requirements abroad.United States (Federal Level)
At present, enforceable federal PFAS regulation focuses primarily on:
- Drinking water Maximum Contaminant Levels (MCLs) for six PFAS
- Targeted reporting and testing obligations
- Limited wastewater and biosolids studies still in progress
Notably, EPA has:
- Retained MCLs for PFOA and PFOS
- Delayed or reconsidered broader mixture-based regulations
- Extended compliance deadlines well into the next decade
This results in regulatory certainty for a small set of compounds, but little clarity for the thousands of PFAS still in commerce. Global (EU and Selected National Regimes)
Outside the U.S., regulators are proceeding with:
- Class-wide PFAS bans across product categories
- National monitoring systems
- Import restrictions and product labeling controls
- Firefighting foam bans and remediation mandates
The EU’s REACH Annex XVII proposal alone could eliminate most PFAS uses unless explicitly exempted, fundamentally reshaping global manufacturing and supply chains.
Federal vs. Subnational Fragmentation in the U.S.
A defining feature of U.S. PFAS regulation is state-driven escalation.
Federal Role: Ceiling, Not a Floor
Federal EPA standards frequently function as:
- Minimum requirements
- Reference points for states
- Litigation anchors rather than operational endpoints
EPA enforcement has been measured, emphasizing guidance, funding assistance, and phased compliance timelines. [epa.gov]
State Role: Aggressive and Divergent
U.S. states have adopted:
- Drinking water standards below federal levels
- Product bans (food packaging, textiles, cosmetics)
- Firefighting foam prohibitions
- PFAS reporting and disclosure regimes
The result is arguably the most fragmented PFAS regulatory environment in the world, creating compliance complexity even for domestically focused insureds.
Enforcement and Liability Posture
United States
- Enforcement is divided among federal agencies, states, and private litigant
- Liability often arises via toxic tort claims, public nuisance actions, or cost recovery suits
- Regulatory enforcement itself has been cautious, especially at the federal level
Insurance exposure is therefore driven more by litigation risk than regulatory penalties.
Global (EU and Middle East)
- Enforcement tools include product seizures, import controls, license suspension, and public disclosure
- Regulators increasingly map contamination locations and identify responsible parties proactively
- Administrative penalties and forced remediation are more common
This shifts exposure from speculative litigation to direct regulatory loss triggers, often with lower thresholds for enforcement action.
Key Takeaways for U.S. Insurance Carriers
- Global PFAS regulation is accelerating, regardless of slower U.S. federal action
- International developments increasingly drive liability, supply chain disruption, and product restrictions
- Insureds may unknowingly face compliance gaps outside the U.S., creating latent exposure
- Early identification of jurisdiction-specific PFAS risk is critical for underwriting, claims, and reinsurance strategy
U.S. carriers ensuring global operations should review PFAS exposure assumptions across environmental liability, product liability, and casualty lines—particularly where insureds operate in the EU, Middle East, or other rapidly evolving regulatory environments.
Do you have questions? Reach out to our insurance experts or our PFAS experts today!
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