EU PFAS ban: the PFAS rules in force for products you ship, and the universal ban still only proposed

No single EU law bans PFAS as a group. The EU rules are separate restrictions, each with its own products, limit and date, and the ban on all PFAS is still a proposal. A REACH restriction binds a substance “in an article” whoever sells it, and import counts as placing on the market (Art. 67(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 67, paragraph 1Click opens the article on EUR-Lex., Art. 3(12)Regulation (EC) No 1907/2006, REACH (chemicals)Article 3, point 12Click opens the article on EUR-Lex.). The POPs Regulation uses the same meaning of placing on the market. PFAS stands for per- and polyfluoroalkyl substances. REACH defines them 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)” (Annex XVII, entry 82).

Entry 68 is not PFOA. Entry 68 of Annex XVII first restricted PFOA, its salts and PFOA-related substances (Regulation (EU) 2017/1000). PFOA was then listed in the POPs Regulation, and Regulation (EU) 2021/1297 replaced entry 68 with the C9-C14 PFCAs. Its recital 10 says entry 68 “was effectively replaced” by the POPs amendment. PFOA is therefore a POPs rule today, not a REACH one.

Entry 68 exceptions. The 25 ppb and 260 ppb limits do not apply to articles placed on the market before 25 February 2023 (entry 68(6)). Entry 68 also carries use-specific exceptions. Those for protective textiles and PTFE membranes (entry 68(4), ended 4 July 2023), photolithography, photographic coatings, implantable medical devices and installed firefighting foam (entry 68(5), ended 4 July 2025) and semiconductors (entry 68(8), ended 31 December 2023) have ended. Still live: a 10 ppm limit for transported isolated intermediates (entry 68(3), no end date), can coating for pressurised metered-dose inhalers until 25 August 2028 (entry 68(7)), semiconductors in spare parts until 31 December 2030 (entry 68(9)), a 100 ppb limit for fluoroplastics and fluoroelastomers with perfluoroalkoxy groups (entry 68(10)) and a 1,000 ppb limit for PTFE micro powders (entry 68(11)).

Two PFAS definitions. REACH entry 82, the Toy Safety Regulation (Art. 3Regulation (EU) 2025/2509, Toy Safety RegulationArticle 3Click opens the article on EUR-Lex., point (42)) and the French decree define PFAS as any substance with a fully fluorinated methyl or methylene carbon atom. PPWR Art. 5(5)Regulation (EU) 2025/40, Packaging and Packaging Waste RegulationArticle 5, paragraph 5Click opens the article on EUR-Lex. adds exceptions for substances that contain only certain CF3-X or X-CF2-X’ structural elements, so a substance can count as PFAS under one rule and not under another.

A PFAS on the SVHC Candidate List is not a restricted PFAS. ECHA lists PFOA, the C9-C14 PFCAs, PFHxS, HFPO-DA (the substance known as GenX), PFBS and PFHpA among the PFAS on the Candidate List. That list sets information duties above 0.1% by weight of an article (Art. 33(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 1Click opens the article on EUR-Lex., Art. 33(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 33, paragraph 2Click opens the article on EUR-Lex.), not a limit. SVHC covers the duties.

What the text names. Recital 15 of Regulation (EU) 2024/2462 gives outdoor clothing such as rain jackets as an example of clothing and handbags as an example of related accessories. Recital 17 names carpets, rugs, curtains, blinds, upholstery, textile wall covers and textile-based coverings such as tablecloths or bed linen as the textiles in entry 79(2). Recital 24 gives that group 36 months, not 24, to comply.

Who is outside. Entry 79(1) and (2) do not apply to personal protective equipment against the category III risks the entry names (Regulation (EU) 2016/425Regulation (EU) 2016/425, Personal Protective Equipment RegulationThe whole regulationClick opens the law on the EU Publications Office.), to medical devices and in vitro diagnostic devices, or to construction textiles (entry 79(3)). They do not apply to substances with a C6F13 group attached directly to a sulphur atom that the POPs Regulation already prohibits (entry 79(6)).

Stock placed on the market earlier. Articles and mixtures placed on the market before 10 October 2026 are outside paragraph 1, and articles placed on the market before 10 October 2027 are outside paragraph 2 (entry 79(7), (8)). The firefighting foam limits in paragraphs 4 and 5 carry no such stock rule.

What is measured. Paragraphs 1 and 2 count PFHxA “in homogeneous material”, so each separable material of a garment or shoe is tested, not the whole product. The entry names no test method.

A portable fire extinguisher is one carried and operated by hand with a working mass of not more than 20 kg (standard EN 3-7), a mobile extinguisher of not more than 150 litres (EN 1866), or a spray can extinguisher (EN 16856) (entry 82(11)(a)). Entry 82(2) leaves out PFOS, PFOA and PFHxS, which the POPs Regulation covers, the C9-C14 PFCAs of entry 68, and PFHxA for the uses entry 79 restricts, but counts them in the sum of all PFAS (entry 82(3)). Recital 32 gives 12 months for placing on the market of portable extinguishers, and 18 months for alcohol-resistant foam.

Articles already in use. The ban does not apply to a substance in articles already in use before the date the Regulation, or Regulation (EC) No 850/2004, became applicable to that substance (Article 4(2)Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)The whole regulationClick opens the law on the EU Publications Office. of Regulation (EU) 2019/1021Regulation (EU) 2019/1021, POPs Regulation (persistent organic pollutants)The whole regulationClick opens the law on the EU Publications Office.). The entries repeat it with their own dates: for PFOA, articles already in use before 4 July 2020 may stay in use. The PFOA entry’s other limits, derogations and end dates are in Annex I, Part A of the consolidated text of 30 September 2026. Regulation (EU) 2025/1399 added limits for PFOA in firefighting foam already installed in systems and in fluorine-free foam from cleaned equipment.

What counts as a related compound. PFOA-related compounds are substances that degrade to PFOA, including those with a linear or branched perfluoroheptyl group with the (C7F15)C moiety as a structural element, with five listed exclusions. PFHxS-related compounds contain the C6F13S group and degrade to PFHxS. The entries name no test method.

What is coming. The ECHA PFAS page of 5 May 2026 reports that long-chain perfluorinated carboxylic acids (C9-C21 PFCAs) joined the Stockholm Convention in May 2025, with a global ban applying from December 2026, and that the Commission is preparing to add them to the POPs Regulation.

The Ministry’s FAQ of May 2026 gives the administration’s reading, and says only the law and the decree are authoritative. It reads the 2026 ban as covering consumer clothing, including clothing imitating leather, and all shoes, leather ones too, but not clothing made entirely of leather. Handbags, pouches and watch straps fall under the 2030 ban when they are textile, and ties, belts, scarves and shawls are inside the 2026 ban. Clothing and shoes meant for professionals are outside the 2026 ban and clothing for professionals is inside the 2030 ban. A stock-period product that holds PFAS above the limits of REACH or the POPs Regulation cannot be sold. The decree names no test method. The FAQ says any technically relevant method may be used and that a supplier’s documentation showing no PFAS can serve as evidence, and it names the standards NF EN 17681-1 and NF EN 17681-2 as an optional route for textiles. Article L. 524-2 gives the inspectors the powers of Articles L. 521-12 to L. 521-20 of the Environment Code.

The Agency’s FAQ says a Danish business that imports goods to a warehouse in Denmark after 1 July 2026 may not import PFAS-containing clothing or footwear meant for consumers, and that import is lawful where a purchase agreement or the like shows the goods are meant for export. Goods in a customs warehouse that have not officially entered the EU are not covered. A trader that sells to businesses must make sure the buyers are not private persons.

What the Regulation says happens next. The Commission prepares a draft amendment to Annex XVII within three months of receiving SEAC’s opinion, and takes the final decision by the committee procedure of Art. 133(4)Regulation (EC) No 1907/2006, REACH (chemicals)Article 133, paragraph 4Click opens the article on EUR-Lex., sending the draft to the Member States at least 45 days before the vote (Art. 73(1)Regulation (EC) No 1907/2006, REACH (chemicals)Article 73, paragraph 1Click opens the article on EUR-Lex., Art. 73(2)Regulation (EC) No 1907/2006, REACH (chemicals)Article 73, paragraph 2Click opens the article on EUR-Lex.). Where the draft departs from the proposal or the Agency’s opinions, the Commission explains why.

What the Danish Environmental Protection Agency expects. Its page, with a table updated on 17 April 2026, gives 2027 as the earliest expected entry into force of the restriction of all PFAS.

The firefighting foam restriction is separate. ECHA states that the PFAS restriction in firefighting foams, adopted in October 2025, is not part of the proposal of the five authorities. That is entry 82, covered above.

What you can skip

What the law leaves open

• How to test for PFAS. The French decree, the PFHxA entry and the POPs entries name no test method. Meanwhile, use a laboratory report that names the method and the limit it was measured against, so any laboratory can repeat it.
• Whether the Danish clothing ban reaches a parcel you send to a Danish consumer. Order No 464 bans import and sale to consumers, and the Agency’s FAQ answers a question about a consumer who buys outside Denmark with: it is for that consumer to ensure the product has no PFAS. The FAQ does not say how that applies to a non-EU seller who ships to Denmark. Meanwhile, treat the parcel as an import covered by the ban.
• When the universal restriction will apply. Nothing is dated. Annex XVII has no entry for it, and SEAC has not yet adopted its final opinion.