We started out believing the headlines. Then we read the restrictions, and the picture became both simpler and more awkward than it looked.
The universal restriction is not in force
The general REACH restriction on PFAS is still under consideration. The Committee for Risk Assessment adopted its final opinion on 2 March 2026 and supports a ban. The Socio-Economic Analysis Committee submitted its draft on 26 March, the consultation closed on 25 May, and a final opinion is expected towards the end of the year.
Entry into force is realistically 2027 or 2028, with transition periods of between eighteen months and twelve years depending on the use. The socio-economic committee has also said that a complete ban is probably not proportionate. Planning production around a headline about 2026 is therefore planning around the wrong year.
What does apply
| Rule | Content | Date |
|---|---|---|
| PFHxA, (EU) 2024/2462, Annex XVII entry 79 | Clothing and accessories for the general public: 25 ppb PFHxA and salts, 1 000 ppb related substances | 10 October 2026 |
| France, law 2025-188 | Ban in apparel textiles and footwear, extended to all textiles in 2030 | 1 January 2026 |
| Denmark, limit on total fluorine | Stated as 50 mg fluorine per kilo in clothing and footwear | 1 July 2026 |
| Sweden | No national textile rule | not applicable |
We have not been able to verify the French and Danish figures against the original texts. They stand here as what they are, information to be read in the source before it becomes a construction specification.
But the direction is clear. Since we sell to France and Denmark from day one, the strictest national limit becomes our specification, not the EU level. A brand that builds to the EU floor gets to rebuild.
The test method fells more suppliers than the limit does
EN 17681-1:2025 was published on 30 April 2025. It replaced extraction with methanol alone by methanol plus sodium hydroxide.
The difference sounds technical and is not. The old method measured free PFAS. The new one releases PFAS bound in side-chain fluoropolymers and reveals cross-contamination from the production line. A fabric that passed as free under the old method can fail under the new one.
What replaces it
Fluorine-free water repellency works. It performs worse against oil than against water, and that is the honest limitation that belongs in the product copy rather than hidden behind the word sustainable.
For a garment that has to handle rain on the way to work, it is enough. For a garment that has to resist oil in a workshop it is not, and then the garment should not be sold as though it did.
Why we write out the uncertainty
It would be easier to write that our garments are free of PFAS and move on. The problem is that the claim would rest on supplier certificates we have not yet read, tested by a method we do not know.
The directive against greenwashing, which member states apply from 27 September 2026, requires an environmental claim to be specific and substantiated. An unsubstantiated claim is therefore two faults: one against the customer and one against the law.
Sources
- Slutligt yttrande om universell PFAS-restriktion. Riskbedömningskommittén, Echa, 2026-03-02.
- Kommissionens förordning (EU) 2024/2462 om PFHxA. Europeiska unionen, 2024.
- EN 17681-1:2025, bestämning av fluorerade ämnen i textil. CEN, 2025-04-30.
- Direktiv (EU) 2024/825 om konsumentens roll i den gröna omställningen. Europeiska unionen, 2024.