PFAS restrictions in footwear, clothing and cosmetics come into force in EU

The restrictions target undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances. They form part of the EU’s broader efforts to reduce the release of so-called ‘forever chemicals’ into the environment and limit human exposure to substances that are highly persistent and can accumulate over time.

The restrictions apply to PFHxA, its salts and PFHxA-related substances above specified concentration thresholds in textiles, leather, furs and hides used in clothing and related accessories for the general public, including outdoor clothing such as rain jackets, handbags and footwear. The measures also apply to paper and cardboard used as food contact materials, cosmetic products and mixtures supplied to the general public.

The new rules additionally restrict the presence of PFHxA substances in carpets, rugs, curtains, blinds, upholstery, textile wall coverings and other textile-based coverings such as tablecloths and bed linen.

Zoe Betts, product safety expert at Pinsent Masons, said: “For manufacturers, importers and retailers, the immediate challenge will be demonstrating compliance. Businesses placing affected products on the EU market must ensure that products falling within scope meet the relevant concentration thresholds and that testing, auditing, supplier assurance and verification processes are robust enough to identify and manage PFAS-related risks within increasingly complex global supply chains.”

For some categories of textile products, outside clothing and consumer accessories, an additional transitional period applies, with restrictions taking effect from October 2027. Certain firefighting foam applications are subject to longer transition periods extending to October 2029.

The restrictions do not amount to a blanket ban on PFHxA. A number of industrial and strategic applications remain outside their scope, including some uses in semiconductors, batteries and fuel cells for green hydrogen. Certain personal protective equipment (PPE) and construction textiles are also excluded.

Jacqueline Harris, an expert in product liability and regulation at Pinsent Masons, said: “Many manufacturers supplying into the EU will already be aware of the restrictions and have taken steps to ensure their products are compliant. With increasing pressure on governments and regulators both within the EU and elsewhere, including in the UK, to restrict or in some cases prohibit the use of PFAS, stakeholders cannot afford to fall behind on developments or miss the opportunity to have their voice heard in the debate.”

The restrictions arrive amid growing international scrutiny of PFAS substances. Regulators across multiple jurisdictions are considering whether additional controls are required for different PFAS compounds and applications, reflecting concerns over the substances’ persistence in the environment.

Betts said: “PFAS management should be treated as a strategic issue rather than a narrow regulatory compliance exercise. All businesses should be taking stock, if they haven’t already, of PFAS usage in their supply chain and seeking alternative products where possible.”

EU policymakers and regulators have increasingly focused on whether PFAS uses are essential and whether safer substitutes are commercially and technically viable. PFAS can provide heat resistance, chemical resistance, low friction, and water/oil repellence in one material. Alternatives may replicate one or two of these characteristics but rarely all of them. Identifying replacement materials remains a challenge in some sectors, particularly where PFAS provide performance characteristics that are difficult to replace in the short term.

While some regulators have adopted a precautionary approach favouring broad restrictions, other authorities have sought to balance environmental concerns against technological needs and the availability of alternatives.