PFAS in Textiles: Recent Developments in the EU

This blog was originally posted on 5th June, 2024 and refreshed on October 26th, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY VALENTINA MARCHETTI, SENIOR REGULATORY COMPLIANCE SPECIALIST & TEAM LEAD, ADHERENT

---

Key Insight

PFAS restrictions affecting textiles and footwear are advancing at both national and EU levels. France and Denmark have introduced restrictions, Sweden is considering proposed measures, and the EU has adopted specific restrictions on PFHxA while progressing a proposed universal PFAS restriction under REACH. Businesses should assess applicable requirements, existing substance-specific restrictions and upcoming deadlines while monitoring proposals that may affect future compliance obligations.

Table of Contents

• Introduction
• France: National Restrictions on PFAS
• Denmark: PFAS Restrictions in Textiles and Footwear
• Sweden: Proposed National Restrictions
• EU Restriction on PFHxA and Related Substances
• Existing Restrictions on Legacy PFAS under REACH and the POPs Regulation
• EU-wide PFAS Restriction under REACH
• What’s Next?
• Frequently Asked Questions

Introduction

PFAS have long been used in textiles to provide water-, oil- and stain-repellent properties, making them valuable in applications ranging from outdoor clothing and footwear to home furnishings. However, their persistence in the environment and potential impacts on human health have made them a growing focus of regulatory action.

Regulatory action on PFAS is advancing at both national and EU levels. France and Denmark have introduced national restrictions affecting textiles and other consumer products, while Sweden is considering further measures. At EU level, the proposed universal PFAS restriction under the REACH Regulation continues to progress. In parallel, specific EU restrictions on PFHxA and related substances began applying to certain product categories on 10 October 2026, with further categories covered from October 2027.

For businesses, these developments make it increasingly important to understand which products and materials are in scope, distinguish between adopted requirements and pending proposals, and assess how changing restrictions may affect product composition, supply chains and market access.

France: National Restrictions on PFAS

France has introduced national restrictions on PFAS through Law No. 2025-188 and its implementing Decree No. 2025-1376. The measures entered into force on 1 January 2026.

The restrictions cover several product categories, including textile clothing, footwear, waterproofing products, cosmetics and ski wax. The scope is scheduled to expand to other textile products in 2030.

The French measures establish concentration thresholds for PFAS, including limits of 25 parts per billion (ppb) for individual PFAS and 250 ppb for the sum of PFAS, together with a total fluorine threshold of 50 parts per million (ppm). Where total fluorine levels exceed 50 ppm, the burden of proof shifts to the manufacturer or supplier to establish whether the fluorine originates from non-PFAS sources.

Certain products are exempt from the restrictions, including specified personal protective equipment (PPE), technical and medical textiles, and products containing at least 20% post-consumer recycled material, subject to the conditions set out in the legislation. Specific transitional provisions also apply to certain stock placed on the market before the relevant restrictions took effect.

Non-compliance may lead to measures such as product withdrawal or recall and prohibitions on import, production or sale. Administrative penalties may apply under Article L. 521-18 of the French Environmental Code, including fines of up to €15,000 and periodic penalty payments of up to €1,500 per day, where the relevant legal conditions are met. Criminal liability may also arise in certain aggravating circumstances.

Denmark: PFAS Restrictions in Textiles and Footwear

Denmark has introduced restrictions on PFAS in clothing, footwear and waterproofing or impregnation products under Order No. 464/2025, which took effect on 1 July 2026.

The Danish measures include a total fluorine threshold of 50 ppm, which acts as a screening trigger requiring suppliers to demonstrate that fluorine content exceeding this limit is not derived from intentional PFAS addition. Exemptions apply to certain products, including specified PPE, medical devices and used or recycled products, subject to the conditions set out in the legislation.

Transitional provisions also address products held in stock before the restrictions took effect, with a sell-through period potentially extending to 1 January 2027 where the applicable conditions are satisfied.

Sweden: Proposed National Restrictions

Sweden is also considering national measures to restrict PFAS in a range of consumer products. The proposal, set out in memorandum KN2026/01597, envisages restrictions from 1 January 2028.

The proposed scope includes clothing, footwear, waterproofing products, cosmetics, kitchenware and ski wax. The proposed concentration limits include 25 ppb for individual PFAS, 250 ppb for the sum of PFAS and 50 ppm for total fluorine.

The proposal includes exemptions for certain product categories, such as PPE and used products, as well as products containing at least 20% post-consumer recycled material, subject to specified conditions.

The consultation period is scheduled to close on 30 November 2026. As the measures are still proposed, companies should monitor the legislative process and avoid treating the proposed requirements as binding obligations at this stage.

EU Restriction on PFHxA and Related Substances

Separate from national laws and pending proposals, the EU has adopted specific restrictions on undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances under Commission Regulation (EU) 2024/2462, which amended Annex XVII to REACH.

The restrictions establish concentration limits of 25 ppb for the sum of PFHxA and its salts and 1,000 ppb for the sum of PFHxA-related substances. Crucially, testing and compliance must be evaluated at the level of the homogeneous material (e.g., individual functional layers, membranes, or surface coatings) rather than calculated across the gross weight of the finished textile article.

The first set of restrictions applies from 10 October 2026 to specified products intended for the general public, including clothing and related accessories, footwear, certain food-contact paper and cardboard materials, mixtures for the general public and cosmetics.

From 10 October 2027, the restrictions will also apply to other textiles, leather, fur and hides intended for the general public, other than those used in clothing and related accessories already covered by the 2026 deadline. Examples include carpets, rugs, curtains, blinds, upholstery, textile wall coverings, tablecloths and bed linen.

Certain exemptions apply, including for specified personal protective equipment, medical devices, in vitro diagnostic medical devices and construction textiles, subject to the conditions set out in the regulation. The regulation also provides for certain products placed on the market before the relevant application dates to benefit from transitional arrangements.

Existing Restrictions on Legacy PFAS under REACH and the POPs Regulation

The PFHxA restriction builds on existing substance-specific prohibitions that have applied across the EU for years under REACH and the POPs Regulation. These measures are not limited to textiles: they cover substances, mixtures and articles in general, with limited and time-bound derogations.

Restricted PFAS include perfluorooctane sulfonic acid (PFOS) and its derivatives, perfluorooctanoic acid (PFOA) and its related compounds, perfluorohexane sulfonic acid (PFHxS) and its related compounds, as well as certain long-chain perfluorocarboxylic acids (PFCAs), including C9–C14 PFCAs under REACH and C9–C21 PFCAs under the POPs framework.

EU-wide PFAS Restriction under REACH

In addition to adopted rules, work continues on a comprehensive restriction proposal covering all PFAS as a chemical class under REACH. 

The restriction proposal was originally submitted in January 2023 by Denmark, Germany, the Netherlands, Norway and Sweden. Following a public consultation held between March and September 2023, the proposal was updated in August 2025 to reflect further assessment and stakeholder input.

In March 2026, the European Chemicals Agency’s (ECHA) Committee for Risk Assessment (RAC) adopted its final opinion. The Committee for Socio-Economic Analysis (SEAC) subsequently issued its draft opinion, which was subject to a consultation that closed in May 2026 and received more than 3,500 comments. Final opinions are expected by the end of 2026, after which the European Commission is expected to continue its decision-making process from 2027 onward.

The proposed restriction covers PFAS in substances, mixtures and articles. If adopted as currently proposed, the general restriction would apply 18 months after its entry into force, subject to specific derogations and longer transition periods for certain uses. The proposal includes concentration limits of 25 ppb for individual PFAS, 250 ppb for the sum of PFAS and 50 ppm for total fluorine, including polymeric PFAS. Where total fluorine exceeds 50 mg/kg (50 ppm), technical documentation or testing information may be requested by enforcement authorities to verify whether the fluorine originates from PFAS or non-PFAS substances.

The proposal also envisages specific transition periods for certain applications, including recycled textiles, automotive technical textiles, reusable medical textiles and PPE. Depending on the application, some proposed transition periods could extend to 13.5 years, while automotive textiles are among the uses for which periods of approximately 6.5 to 13.5 years have been proposed.

These provisions remain part of the restriction proposal and should not be treated as final, binding requirements. The final scope, exemptions, concentration limits and transition periods will depend on the outcome of the EU decision-making process.

What’s Next?

The proposed universal PFAS restriction under REACH remains a key development to watch, with ECHA’s final opinions expected by the end of 2026, followed by the European Commission’s decision-making process. If finalised as currently proposed, the restriction would generally begin to apply 18 months after its entry into force, although specific uses may benefit from longer transition periods or derogations.

For textile businesses, the priority is to monitor the proposal while ensuring compliance with restrictions already in force. This includes assessing the use of PFAS in materials and finished products, checking applicable national requirements and existing EU substance-specific restrictions, and maintaining reliable information from suppliers to prepare for future requirements.

Frequently Asked Questions

1. Which countries have introduced or proposed national PFAS restrictions affecting textiles?

France and Denmark have introduced national restrictions affecting textiles and related products. Sweden is considering proposed national restrictions, with a consultation period scheduled to close on 30 November 2026.

2. When do the EU restrictions on PFHxA in textiles apply?

The first set of restrictions applies from 10 October 2026 to specified products intended for the general public, including clothing and related accessories and footwear. From 10 October 2027, the restrictions will also apply to other textiles, leather, fur and hides intended for the general public that are not already covered by the 2026 deadline.

3. What concentration limits apply under the EU restriction on PFHxA?

The restrictions establish limits of 25 ppb for the sum of PFHxA and its salts and 1,000 ppb for the sum of PFHxA-related substances. Testing and compliance must be evaluated at the level of the homogeneous material rather than across the gross weight of the finished textile article.

4. Is the proposed universal PFAS restriction under REACH already binding?

No. The universal PFAS restriction remains a proposal. Its final scope, exemptions, concentration limits and transition periods will depend on the outcome of the EU decision-making process.

5. What should textile businesses do to prepare for PFAS restrictions?

Companies should assess the use of PFAS in materials and finished products, check applicable national requirements and existing EU substance-specific restrictions, review relevant exemptions and transitional provisions, and maintain reliable information from suppliers to prepare for future requirements.