In January 2023, the regulatory authorities of five European nations—Denmark, Germany, the Netherlands, Norway, and Sweden—submitted a joint restriction proposal to ECHA under the EU REACH regulation that would, if adopted, become the most comprehensive chemical restriction in history. These five countries, now commonly referred to as the “PFAS Five,” have not only driven the EU-level process but have simultaneously implemented national measures that demonstrate both the feasibility and the political will to regulate PFAS at scale.
Norway: National Action Plan and Groundwater Standards
Norway is not an EU member state but participates in ECHA processes as an EEA country and has been a forceful advocate for class-based PFAS regulation. The Norwegian Environment Agency (Miljødirektoratet) published an updated national PFAS action plan in 2025 covering contaminated site investigation, drinking water monitoring, product restrictions, and industrial discharge limits. Norway enforces drinking water quality guidelines for PFAS aligned with EU standards—100 ng/L for the sum of 20 PFAS—and has established investigation trigger levels for PFAS in soil and groundwater at contaminated sites including former military installations and airports where AFFF was used. Norwegian authorities have been particularly active in prosecuting PFAS contamination cases against industrial operators.
Sweden: National Contamination Prevention Plan
Sweden’s Swedish Environmental Protection Agency (Naturvårdsverket) is developing a comprehensive national plan to prevent PFAS contamination in water bodies and natural areas. Sweden has some of Europe’s most documented PFAS contamination problems, with surveys identifying PFAS above guideline values in a significant proportion of drinking water wells in areas near AFFF-contaminated sites. Sweden’s national drinking water guideline follows EU Drinking Water Directive requirements and enforces 100 ng/L for the sum of 20 PFAS. Sweden has also been active in documenting PFAS in Arctic environments—a priority issue given Sweden’s Arctic territory and the risk of long-range atmospheric transport of PFAS to pristine polar regions.
The Netherlands: Contamination Hotspots and Industrial Liability
The Netherlands has some of Europe’s most severe PFAS groundwater contamination, concentrated primarily in the vicinity of 3M’s former manufacturing facility in Zwijndrecht (Antwerp region, just across the Belgian border) and the Amsterdam–Rhine canal industrial corridor. The Dutch Environment Ministry enforces the EU Drinking Water Directive’s 100 ng/L standard and has established a soil remediation framework for PFAS-contaminated land under the Dutch Soil Protection Act. Several Dutch municipalities have issued precautionary advice to avoid consuming locally grown vegetables near contaminated sites, acknowledging the risk of PFAS uptake through irrigation water. In 2024 and 2025, Dutch courts heard cases brought by residents and municipalities against PFAS manufacturers, with several significant liability rulings expected to set precedents for contamination compensation across the EU.
Germany: Federal Action Plan and Groundwater Monitoring
Germany’s Federal Environment Agency (Umweltbundesamt, UBA) has implemented a national PFAS action plan that includes mandatory groundwater monitoring at over 1,000 sites with historical PFAS use, drinking water quality requirements aligned with EU standards, and technical guidance for water utilities on PFAS treatment technologies. Germany has also been active in implementing restrictions on PFAS in firefighting foams ahead of the EU restriction, and several German states (Länder) have imposed stricter controls than federal requirements on PFAS discharges from industrial facilities into waterways. Baden-Württemberg, which experienced one of Europe’s earliest and largest documented PFAS groundwater contamination events in the Rhine valley, has operated an extensive monitoring and treatment program for municipal water supplies affected by agricultural application of PFAS-contaminated sewage sludge.
The Coordinated EU REACH Strategy
The strategic importance of the “PFAS Five” coalition goes beyond their individual national measures. By jointly submitting the REACH restriction proposal, these five countries pooled scientific resources, legal expertise, and political capital to advance a measure that no single country could have driven through the EU system alone. Their August 2025 updated proposal—which refined the scope of derogations based on more than 5,600 stakeholder comments—demonstrates the iterative nature of their regulatory strategy. Each national measure implemented unilaterally by one of the five countries simultaneously creates demonstration evidence of PFAS-free alternatives that strengthens the case for EU-wide implementation.
Market Implications for Water Treatment Suppliers
The “PFAS Five” countries collectively represent major markets for advanced water treatment technology, with hundreds of documented contaminated sites requiring active remediation and thousands of municipal water utilities monitoring PFAS concentrations. OEM filter media manufacturers with demonstrated performance under EU Drinking Water Directive standards—and with the capacity to supply at the scale required for both point-of-use and large-scale municipal treatment—should prioritize commercial relationships in these five markets as regulatory implementation accelerates through 2026 and beyond.