PFAS in Anti-Graffiti Coatings: The EU Restriction Timeline and What Formulators Need to Know 

A note on claim language: throughout this article, the phrase "does not contain intentionally added PFAS" is used when referring to product formulations. This is Evonik's own confirmed language for Protectosil® ECO-TRETE ANTIGRAFFITI and the precise regulatory language recommended under the current REACH framework. It reflects a documented formulation decision, no PFAS has been deliberately introduced for functional purposes. It does not constitute a guarantee that the product contains zero PFAS at trace levels, which cannot be substantiated given the widespread presence of PFAS in the environment and in some raw material supply chains. Formulators and suppliers should apply the same precision in their own claims.

The EU PFAS restriction creates a formulation challenge that the coatings industry is actively working through. If you are developing or maintaining anti-graffiti coatings or water-repellent surface treatments, the fluorinated chemistry used to achieve oil-repellency performance is within scope of the universal restriction proposal. This article explains the regulatory timeline, identifies which formulation types are affected, and outlines the technical pathway that is available today.

Understanding the challenge requires understanding why fluorinated chemistry entered anti-graffiti formulations in the first place. Water repellency and oil repellency are different problems. Water repellency, making liquid water bead up and run off a surface, is achievable with silane and siloxane chemistry. Oil repellency, the property that allows spray paint and marker ink to be removed without solvent, has historically relied on the low surface energy of the carbon-fluorine bond. That dual function is what the restriction now requires the industry to replicate through different chemistry.

What are PFAS, and how do they function in anti-graffiti formulations?

PFAS (per- and polyfluoroalkyl substances) is a class of man-made chemicals defined by the presence of at least one fully fluorinated carbon atom. The OECD published a universal definition in 2021 covering more than 10,000 individual substances, from legacy compounds such as PFOA and PFOS to short-chain fluorinated alternatives that were later developed as replacements.

In coating chemistry, the carbon-fluorine bond creates very low surface energy, meaning both water and oil-based liquids are repelled by the treated surface. For anti-graffiti applications, this dual effect, water and oil repellency together, makes the surface easy to clean: spray paint and marker residues can be removed with water or mild detergent rather than solvents. This combination of properties is what made fluorinated chemistry standard in anti-graffiti formulations.

Silane-based chemistry provides the water-repellent component of this performance profile but does not, on its own, deliver the same oil repellency. The formulation challenge created by the restriction is to find an alternative route to the combined performance, not simply to remove fluorinated ingredients.

The EU regulatory timeline

The restriction process has developed over several decades and across multiple regulatory instruments. The current universal restriction proposal is the most significant step to date.

2009: PFOS restricted in the EU under the Persistent Organic Pollutants Regulation, following its listing under the Stockholm Convention. First major PFAS substance addressed at EU level.

2020: PFOA and related compounds restricted under the EU POPs Regulation (Commission Delegated Regulation 2020/784), covering surface treatments and coatings. Long-chain PFAS specifically.

13 January 2023: regulatory authorities from Germany, Denmark, the Netherlands, Norway and Sweden submitted a universal PFAS restriction proposal to ECHA. Scope: approximately 10,000 PFAS substances under a single restriction, including short-chain alternatives. Coatings and surface treatment applications are explicitly listed as a use category. Over 5,600 responses were received during the public consultation.

3 March 2026: ECHA's Risk Assessment Committee (RAC) adopted its final opinion supporting an EU-wide restriction with targeted derogations.

26 March 2026: ECHA published RAC's final opinion alongside the Socio-Economic Analysis Committee's (SEAC) draft opinion, and opened a 60-day public consultation on SEAC's draft opinion, running until 25 May 2026. Both committees concluded that existing measures are insufficient and that further EU-wide action is needed.

Next steps: once SEAC finalises its opinion, expected by the end of 2026, the European Commission and EU Member States will decide on the restriction. Specific transitional periods by use category will be set at that stage. A restriction entering into force before 2027 is unlikely. The direction of travel is confirmed.

Important for formulators: the universal restriction covers short-chain fluorinated compounds. Reformulating from C8 to C4 or C6 chemistry did not resolve the regulatory exposure. Any intentionally added PFAS, regardless of chain length, is within scope.

Which coating formulation types are affected?

The restriction targets intentionally added PFAS, those introduced to achieve a functional performance benefit. The following coating categories fall within scope:

• Coatings where fluorinated polymers, co-monomers or additives are used to achieve oil repellency or graffiti resistance
• Water-repellent masonry treatments that use fluorinated components for enhanced easy-clean performance
• Surface treatments for prefabricated construction products where anti-pollution or anti-graffiti performance is delivered through fluorinated surface modification

Coatings and treatments based exclusively on silane or siloxane chemistry, without fluorinated components, are not affected by the universal restriction. This applies to the majority of the Protectosil® range from Evonik, which is silane-based. The PFAS formulation challenge is specific to grades requiring oil repellency alongside water repellency.

Industry context: many coating suppliers and raw material manufacturers are working through the same formulation challenge. The restriction creates a transition period for the sector as a whole. This article does not position any currently available product as non-compliant, the restriction is not yet in force, and many suppliers are actively developing alternatives. The purpose is to help formulators understand their timeline and available options.

What the restriction means for formulators

For a formulator developing or maintaining an anti-graffiti coating, the restriction creates three immediate questions.

1. Does my current formulation contain intentionally added PFAS?

Review your raw material safety data sheets and request written PFAS status statements from your suppliers. Apply the OECD universal PFAS definition: any substance containing at least one fully fluorinated methyl or methylene carbon atom is within scope. Fluorinated surfactants, fluorinated polymers and fluorinated co-monomers introduced for oil repellency or surface modification are all within scope.

2. What is the performance target I need to match?

The commercial benchmark for anti-graffiti performance is the German TL/TP AGS Beton standard from the Federal Highway Research Institute (BASt), combined with the requirements of the Gütegemeinschaft Anti-Graffiti e.V. (Quality Association Anti-Graffiti). Not ISO 11998, which measures wet-scrub resistance for paints and varnishes rather than the cleanability of an impregnation system. Under TL/TP AGS Beton, graffiti-protected substrates are coated with three defined paint systems; the paint is removed with an approved graffiti cleaner; cleaning is repeated ten times on the same location; and performance is expressed as a Ci value reflecting the degree of paint removal. For a permanent system, the requirement is ten cleaning cycles after artificial weathering equivalent to ten years of outdoor exposure (3,000 hours of QUV). Semi-permanent systems are designed for a lower number of cycles.

Any reformulation must demonstrate equivalent performance under TL/TP AGS Beton and the Gütegemeinschaft requirements. This is the benchmark that specifiers reference and that customers will require before accepting a reformulated product.

3. What formulation pathway is available?

The challenge is to match the combined water and oil repellency of fluorinated systems using alternative chemistry. Silane-based systems achieve durable water repellency through chemical bonding with the mineral substrate. The oil-repellency component requires specific system design: chemistry selection, concentration, application method and substrate type all affect graffiti-removal performance. Validated systems are now available; the technical comparison is covered in here.

The silane-siloxane formulation pathway

Silane chemistry achieves water repellency by penetrating mineral substrates, concrete, brick, stone, tile, and reacting chemically with surface silanol groups to form covalent bonds. The result is a hydrophobic zone within the material, not a surface film. Because the treatment is integrated into the substrate, penetrating silane water repellents offer significantly longer service life than film-forming treatments.

Protectosil® ECO-TRETE ANTIGRAFFITI from Evonik is a silane-based system formulated to deliver anti-graffiti performance that does not contain intentionally added PFAS. It is a surface-applied, non-penetrating system, distinct from Evonik's deep-penetrating water-repellent range, and is the specific product in scope for this campaign and the reference point for formulators and material manufacturers assessing their options in this category.

Reformulation checklist

Before the restriction enters into force, formulators should work through the following steps:

1. Audit current formulations. Identify any raw materials containing intentionally added PFAS against the OECD universal definition.
2. Request PFAS status statements from all relevant suppliers. Retain written confirmation.
3. Establish your TL/TP AGS Beton baseline. Document current performance under TL/TP AGS Beton and the Gütegemeinschaft Anti-Graffiti requirements before beginning reformulation.
4. Run reformulation trials with candidate systems. Test against TL/TP AGS Beton, the Gütegemeinschaft requirements, and DIN 52617 water absorption benchmarks.
5. Align claim language. Use "does not contain intentionally added PFAS" consistently. Update safety data sheets and technical data sheets. Do not use "PFAS-free" as a product claim.
6. Communicate with customers on specification equivalence and transition timeline. If your customers are writing public tender specifications, the clause wording they'll need is covered separately.

Frequently asked questions

What is the legal definition of PFAS under EU law?

The most widely applied reference is the OECD definition (2021): a substance is a PFAS if it contains at least one fully fluorinated methyl or methylene carbon atom. The universal PFAS restriction dossier submitted to ECHA in January 2023 adopts this definition and covers approximately 10,000 individual substances.

Are all PFAS being restricted at the same time?

ECHA's scientific committees have confirmed support for an EU-wide restriction with targeted derogations. The final restriction will include use-category-specific transitional periods, set by the European Commission following adoption. Some substances, PFOA and PFOS, are already restricted under existing EU regulations.

Does reformulating from long-chain to short-chain chemistry resolve the regulatory exposure?

No. The universal restriction covers short-chain compounds (C4, C6) as well as long-chain compounds (C8 and above). Any intentionally added substance containing at least one fully fluorinated carbon atom is within scope, regardless of chain length.

What performance test is used to validate anti-graffiti coatings?

Not ISO 11998, which is a wet-scrub resistance test for paints and varnishes. Anti-graffiti performance is tested under the German TL/TP AGS Beton standard (BASt) together with the Gütegemeinschaft Anti-Graffiti e.V. requirements: three defined paint systems, an approved graffiti cleaner, ten cleaning cycles on the same spot, and a Ci value recording the degree of paint removal. Complementary tests include DIN 52617 (water absorption) and EN ISO 7783 (vapour permeability, Sd value).

What does "does not contain intentionally added PFAS" mean, and why is it used instead of "PFAS-free"?

It indicates that no PFAS compound has been deliberately introduced into the formulation for functional purposes. It is the correct claim language under the current regulatory framework, and the wording Evonik itself uses for Protectosil® ECO-TRETE ANTIGRAFFITI, because it reflects a documented formulation decision and is legally defensible under REACH. The broader claim "PFAS-free" implies a zero-detection guarantee across all possible sources, including raw material supply chains and environmental background levels. That guarantee cannot be substantiated for most formulated products and should not be used as a product claim.

Where can I access the ECHA PFAS restriction dossier and committee opinions?

The restriction dossier, RAC final opinion, and SEAC draft opinion are publicly available at echa.europa.eu, under Hot Topics, PFAS, for the most current timeline and status.

Does the restriction affect the full Protectosil® range?

No. The majority of the Protectosil® range from Evonik is silane-based and does not contain intentionally added PFAS. The formulation challenge is specific to grades requiring oil repellency alongside water repellency, the anti-graffiti segment specifically. Protectosil® ECO-TRETE ANTIGRAFFITI is the relevant product for that segment.

Download the PFAS Transition Guide. A 16-page reference covering the restriction timeline, affected formulation types, the technical pathway, and a specification clause template for specifiers. Free download.

Sources

• European Chemicals Agency (ECHA). ECHA supports PFAS restriction with targeted derogations. March 2026.
• European Chemicals Agency (ECHA). Universal PFAS restriction proposal. February 2023.
• European Chemicals Agency (ECHA). Per- and polyfluoroalkyl substances (PFAS), hot topics.
• OECD (2021). Reconciling terminology of the universe of per- and polyfluoroalkyl substances. Series on Risk Management No. 61.
• Commission Delegated Regulation (EU) 2020/784 of 8 April 2020, listing of PFOA under the POPs Regulation. EUR-Lex.
• Regulation (EU) 2019/1021 on persistent organic pollutants. EUR-Lex.
• TL/TP AGS Beton (BASt) and Gütegemeinschaft Anti-Graffiti e.V. (ReGG) performance requirements. German technical regulations, no public URL.