CHEMICALS GUIDE
PFAS in Fashion: What REACH Already Bans, and What’s Still Only a Proposal
Search "PFAS fashion EU ban" and most of what comes up is about a "universal" restriction that is still being written. What that coverage tends to miss: a REACH restriction on one specific PFAS substance, undecafluorohexanoic acid (PFHxA), is already adopted, already in force, and starts applying to clothing, related accessories and footwear sold in the EU from 10 October 2026 — twelve days from this guide's last verification date. This article separates what EU law already restricts today from what remains, as of today, only a Commission proposal in preparation, and sets out how both connect to the Digital Product Passport.
Sources: EU legal texts and European Commission publications, listed below.
1. What "PFAS" means in EU law — it depends which law
There is no single legal definition of "PFAS" that applies across all of EU law today. Annex XVII to the REACH Regulation, in the entry added for firefighting foams, defines PFAS for the purposes of that one entry as "any substance that contains at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom (without any H/Cl/Br/I attached to it)" — a broad, class-wide, structural definition (Regulation (EC) No 1907/2006, Annex XVII, entry 82, inserted by Commission Regulation (EU) 2025/1988).
The restriction that actually reaches clothing does not use that class-wide definition at all. It targets one specific substance: undecafluorohexanoic acid (PFHxA), its salts, and "PFHxA-related substances," defined by a narrower structural formula — substances "having a linear or branched perfluoropentyl group with the formula C5F11- directly attached to another carbon atom as one of the structural elements; or... having a linear or branched perfluorohexyl group with the formula C6F13-" (Annex XVII, entry 79). A handful of specific compounds are carved back out of that definition by name. A future EU-wide restriction covering PFAS as a class in consumer goods generally — discussed in section 4 — does not exist yet in law.
2. Already law: PFHxA in clothing and footwear, from 10 October 2026
The instrument is Commission Regulation (EU) 2024/2462 of 19 September 2024, amending Annex XVII to REACH under Article 68(1) "as regards undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances." It entered into force on the twentieth day after its publication in the Official Journal (OJ L, 2024/2462, 20 September 2024) — and it is the Commission's own reasoning, not a summary, that ties the restriction to fashion by name: recital 15 states that the Commission "considers it necessary to adopt a Union-wide restriction for the placing on the market and use of PFHxA, its salts and PFHxA-related substances in textiles, leather, furs and hides in clothing (such as outdoor clothing like rain jackets); related accessories (such as handbags) and footwear for the general public," alongside food-contact paper and board, general-public mixtures, cosmetics and some firefighting-foam uses.
The process behind it ran for five years. Germany submitted the underlying Annex XV restriction dossier to the European Chemicals Agency (ECHA) on 20 December 2019, proposing concentration limits of 25 ppb for PFHxA and its salts and 1,000 ppb for PFHxA-related substances, with an 18-month general transition period. ECHA's Committee for Risk Assessment (RAC) adopted its opinion on 3 June 2021, backing a restriction on "wide dispersive consumer uses in food contact materials, in textiles as well as in firefighting foams used for public firefighting, which comprise three major emission sources" (recital 5). Its Committee for Socio-Economic Analysis (SEAC) followed on 8 December 2021, concluding that restricting "the uses in consumer apparel textiles, firefighting foams in public and mobile firefighting, paper and cardboard as food contact materials and consumer mixtures is likely not an inappropriate measure, in terms of its socio-economic benefits and its costs" (recital 8). SEAC also rejected Germany's 18-month transition period as too short and proposed 36 months instead, "to ensure that producers, importers and users of substances, mixtures and articles are able to comply with the restriction and adapt their operations to allow for the phasing-out and substitution" (recital 9). Recital 17 notes that "alternatives for water repellent properties appear to be available," and separately references the loss of "oil and stain repellent properties" as a functional consideration — the properties PFHxA-related chemistry is used to provide.
| What | Threshold | Applies from |
|---|---|---|
| Textiles, leather, furs and hides in clothing (incl. outdoor clothing); related accessories (incl. handbags); footwear — for the general public | 25 ppb (PFHxA + salts) / 1,000 ppb (PFHxA-related substances), in homogeneous material | 10 October 2026 |
| Textiles, leather, furs and hides other than in clothing and related accessories, for the general public (e.g. carpets, curtains, upholstery, bed linen) | Same thresholds | 10 October 2027 |
| Paper and cardboard as food contact materials; general-public mixtures; cosmetic products | Same thresholds | 10 October 2026 |
| Personal protective equipment (risk category III, listed points); medical devices; IVD devices; construction textiles | — | Exempted |
Source: Regulation (EC) No 1907/2006, Annex XVII, entry 79, as inserted by Commission Regulation (EU) 2024/2462. Two further carve-outs apply regardless of product category: articles and mixtures already placed on the EU market before the relevant date do not have to be withdrawn (paragraphs 7 and 8 — existing stock is not recalled), and a short list of named compounds (including C6F14 and certain ether-linked C6F13- substances) is excluded from the "PFHxA-related substances" definition itself.
The Annex's own wording is precise about what triggers the duty: entities covered by the restriction "shall not, from 10 October 2026 be placed on the market, or used, in a concentration equal to or greater than 25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances" in the clothing, accessories, footwear, food-contact paper and board, mixtures and cosmetics categories listed above (entry 79, paragraph 1); the same wording applies from the later date, "shall not, from 10 October 2027 be placed on the market," for other textiles and leather goods (paragraph 2). The duty falls on placing on the market or use — it is not limited to manufacturing.
3. Also already law — but not primarily about fashion
Two other PFAS restrictions are already in force and worth knowing, even though neither is centred on apparel. First, Commission Regulation (EU) 2025/1988 of 2 October 2025 (OJ L, 2025/1988, 3.10.2025) restricts PFAS as a class — using the broad CF3/CF2 definition quoted in section 1 — in firefighting foams, "as of 23 October 2030," with derogations for PFOS-, PFOA- and PFHxA-related compounds already regulated elsewhere. Its own recital traces back to a dossier ECHA submitted on the Commission's behalf on 14 January 2022, separate from the five-country "universal" PFAS dossier described in section 4.
Second, three individual PFAS — perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS) and perfluorohexane sulfonic acid (PFHxS), together with their salts and related compounds — are listed in Annex I to the Persistent Organic Pollutants (POPs) Regulation (EU) 2019/1021, Article 3(1) of which provides: "The manufacturing, placing on the market and use of substances listed in Annex I, whether on their own, in mixtures or in articles, shall be prohibited, subject to Article 4." All three carry the same near-zero thresholds: 0.025 mg/kg (0.0000025% by weight) for the substance and its salts, and 1 mg/kg (0.0001% by weight) for the sum of related compounds, with narrow, largely technical exemptions. These are legacy substances, not new fashion-specific rules — but they matter for the Digital Product Passport, covered next.
Not yet law
What's still only a proposal: the "universal" PFAS restriction
The Commission's own Chemicals Industry Action Plan — COM(2025) 530 final, adopted in Strasbourg on 8 July 2025 — is explicit that this part isn't settled. Section 5.4, "Providing clarity on PFAS," states: "The scientific assessment of the Universal PFAS restriction by the ECHA's committees is ongoing and scheduled to conclude in 2026. The Commission is committed to presenting a proposal as soon as possible after receiving ECHA's opinion, with the overall objective of minimising PFAS emissions." A footnote records that "Five national authorities (Denmark, Germany, The Netherlands, Sweden and Norway) submitted to ECHA in January 2023 a restriction dossier for all PFAS." The Plan's own action list includes "Propose a PFAS restriction under REACH on the basis of ECHA's opinion on the 'universal' PFAS restriction dossier" — without a committed quarter or year, unlike most of the Plan's other action items.
Fashion is named directly, but only as something under consideration, not decided: "The Commission will consider PFAS ban in consumer uses such as cosmetics, food contact materials and outdoor clothing. Where adequate alternatives in terms of performance and safety are not available, the continued use of PFAS in industrial applications may be allowed for critical applications... under strict conditions until acceptable substitutes are found."
A Commission news item from 15 June 2026, after Commissioner Jessika Roswall's stakeholder dialogue on PFAS, confirms nothing has moved beyond that: "Work is ongoing towards a future universal PFAS restriction... Once [ECHA] delivers its final scientific assessment by the end of 2026, the Commission will present a restriction proposal aimed at minimising PFAS emissions. The Commission will also consider a ban on PFAS in consumer goods." A search of the Commission's Have Your Say register on 28 September 2026 turns up no published initiative yet for the universal restriction — meaning there is, as of this guide's last verification, no formal draft act, consultation or restriction dossier decision for the general public to review.
4. How PFAS reaches the Digital Product Passport
The ESPR defines a "substance of concern" (Article 2(27)) through four alternative descriptions, set out in full in our guide to substances of concern under the ESPR. Two of the three already-adopted PFAS restrictions above map directly onto that definition without needing any PFAS-specific ESPR rule at all. PFOA, PFOS and PFHxS meet point (c) — a substance that "is regulated under Regulation (EU) 2019/1021" — simply because they are POPs. Any PFAS individually identified as a substance of very high concern on the REACH Candidate List would meet point (a); any PFAS with a relevant harmonised CLP hazard classification would meet point (b). None of this requires a PFAS-specific rule under the ESPR — it follows automatically once a given PFAS substance is regulated under REACH or POPs, the same mechanism our substances-of-concern guide sets out for any substance of very high concern.
Point (d) — a substance that "negatively affects the reuse and recycling of materials in the product in which it is present," decided product group by product group — is where the still-pending universal restriction would matter most for textiles specifically. The JRC's preparatory study for the textile ecodesign delegated act flags this directly: "Particular attention should be given to the ongoing universal restriction process on PFAS, currently being developed by ECHA. Following a possible Commission Regulation issued under REACH defining a broad restriction for PFAS, including in textiles, such substances would, most likely, qualify as SoC (d) due to regulatory limitations. In such a case, it is advised that the Commission would consider whether the transition time that may be defined in the REACH restriction is sufficient to also allow for the information requirement to apply also to PFAS, or whether specific provisions would be required via a dedicated amendment of the Delegated Act" (Textile-Prep-Study_3rd-Milestone_20251212.pdf, section 12.3.14). In the JRC's own reading, a future PFAS restriction — not the ESPR itself — would be what pulls broader PFAS into the textile Digital Product Passport as a tracked substance of concern.
5. What already applies to a fashion brand, right now
Two duties apply today, independent of anything still in preparation. First, the PFHxA restriction covered in section 2: any clothing, accessory or footwear line using a durable water- or stain-repellent finish should be checked for PFHxA and PFHxA-related substances before 10 October 2026, since the restriction reaches placing on the market, not just manufacture — importers and private-label brands carry the same duty as manufacturers. Existing stock already placed on the EU market before the relevant date does not have to be pulled.
Second, REACH's standing information duty for substances of very high concern applies to any PFAS individually identified on the Candidate List, regardless of whether it is also subject to an Annex XVII restriction. Under Article 33(1) and (2) of REACH, a supplier of an article containing such a substance above 0.1% weight by weight must provide the recipient with "sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance," and must do the same for a consumer on request, "free of charge, within 45 days of receipt of the request." This duty is not new, is not PFAS-specific, and does not depend on the universal restriction being adopted.
6. Reading this together
The texts above justify a narrower, more confident claim than "PFAS is being banned in fashion": one specific PFAS substance, used in the industry for water- and stain-repellent finishes, is banned in clothing, accessories and footwear from a fixed date twelve days from this guide's last check. A second, broader restriction is genuinely in preparation, is discussed by name in relation to "outdoor clothing," and has a scientific-assessment deadline of the end of 2026 — but it has no proposal, no draft text and no application date yet, and the Commission's own framing ("as soon as possible after receiving ECHA's opinion") is deliberately open-ended.
The five-year gap between Germany's PFHxA dossier (December 2019) and PFHxA actually restricting placing-on-the-market activity (October 2026) is the closest available benchmark for how long a REACH restriction takes from dossier to application once it targets consumer textiles specifically. If the universal PFAS restriction follows a broadly similar path — ECHA opinion in 2026, a Commission proposal some time after, a RAC/SEAC-style scrutiny process, and a multi-year transition period once adopted — a comparably distant application date for consumer goods generally would not be surprising. That is inference from the pattern in the texts above, not a date stated anywhere in them; none of the sources cited here commits to a year.
Sources
- Commission Regulation (EU) 2024/2462 of 19 September 2024 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council as regards undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances (OJ L, 2024/2462, 20.9.2024). Cited: recitals 1, 2, 4–9, 15, 17–18; Articles 1–2; Annex, entry 79.
- Regulation (EC) No 1907/2006 (REACH), consolidated text of 22 June 2026. Cited: Article 33(1)–(2); Article 68(1); Annex XVII, entries 79 and 82.
- Commission Regulation (EU) 2025/1988 of 2 October 2025 amending Annex XVII to Regulation (EC) No 1907/2006 as regards per- and polyfluoroalkyl substances in firefighting foams (OJ L, 2025/1988, 3.10.2025).
- Regulation (EU) 2019/1021 on persistent organic pollutants (POPs), consolidated text of 1 January 2026. Cited: Article 3(1); Annex I entries for PFOA, PFOS and PFHxS and their concentration-limit provisions.
- European Commission, A European Chemicals Industry Action Plan, COM(2025) 530 final, Strasbourg, 8 July 2025. Cited: section 5.4 “Providing clarity on PFAS” and footnote 42; action-list item on the PFAS restriction proposal.
- European Commission, Commissioner Roswall holds talks on PFAS-related challenges, news item, 15 June 2026.
- European Commission, Have Your Say register, search for “PFAS”, checked 28 September 2026 (no published initiative for the universal PFAS restriction at time of writing).
- LG Fashion Labs, Substances of Concern in the Digital Product Passport: What the ESPR Definition Means for Fashion — for the ESPR Article 2(27) definition and its sourcing.
- Joint Research Centre (JRC), Product Bureau, textile products, Documents related to the Preparatory Study: Working document of the 3rd milestone (file Textile-Prep-Study_3rd-Milestone_20251212.pdf, listed with the date 2025-12-15; this is a draft document that has not been adopted or endorsed by the European Commission). Cited: section 12.3.14.
All sources were accessed and verified live on EUR-Lex and europa.eu on 28 September 2026, including an independent second pass re-confirming every quotation, article number and date against the live text before publication.
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