Two PFAS stories that are easy to mix up
PFAS, the large family of per- and polyfluoroalkyl substances often called “forever chemicals”, are used in water-repellent clothing, stain-resistant textiles, food packaging and non-stick coatings. In the EU, two very different regulatory processes are running at the same time, and importers often treat them as one.
The first is the universal PFAS restriction: a proposal to restrict PFAS as a group under REACH. It is large, it is still under assessment, and it is not law.
The second is a set of narrower PFAS rules that are already adopted and start to apply in the second half of 2026. For importers of clothing and footwear, the most important one is the REACH restriction on PFHxA, which applies from 10 October 2026.
This article separates the two, as of July 2026, and suggests what an importer of textiles or cookware should do now.
Where the universal restriction stands
The universal restriction is going through the normal REACH procedure: two ECHA scientific committees give their opinions, and the Commission then decides whether and how to propose a restriction.
- Risk Assessment Committee (RAC). RAC adopted its opinion in March 2026.
- Socio-Economic Analysis Committee (SEAC). SEAC agreed its draft opinion in March 2026. The draft was open for public consultation from 26 March to 25 May 2026, so stakeholders could send further evidence, for example on alternatives and on the costs of phasing out PFAS.
- Next step. ECHA expects SEAC’s final opinion by the end of 2026. Only then do the opinions go to the Commission, which prepares a draft decision for the Member States in the REACH committee.
Nothing in this process creates obligations for companies today. The scope of the final restriction, the transition periods and the derogations for specific uses are still open. Any article that tells you the exact date when PFAS will be banned in a jacket or a frying pan is getting ahead of the procedure.
Textiles: the PFHxA restriction applies from 10 October 2026
While the universal restriction is still being discussed, several PFAS sub-groups are already restricted – PFOA under the POPs Regulation since 2020 and C9–C14 PFCAs under REACH since 2023 – and a further restriction, on PFHxA, has been adopted. Commission Regulation (EU) 2024/2462 of 19 September 2024 added a restriction on undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances to Annex XVII of REACH.
From 10 October 2026, these substances may not be placed on the market or used at or above 25 ppb for the sum of PFHxA and its salts, or 1,000 ppb for the sum of PFHxA-related substances, in:
- textiles, leather, furs and hides in clothing and related accessories for the general public;
- footwear for the general public;
- paper and cardboard used as food contact materials;
- mixtures for the general public;
- cosmetic products.
From 10 October 2027, the same limits apply to other textiles, leather, furs and hides for the general public, for example home textiles.
Two details matter for importers. First, the restriction does not apply to articles and mixtures placed on the market before 10 October 2026 (or before 10 October 2027 for the second group), so stock already placed on the market can be sold. Second, some uses are excluded, including certain personal protective equipment, medical devices and construction textiles.
If you import outdoor jackets, rainwear, school uniforms or shoes with water- or stain-repellent finishes, this is the rule to work to in 2026, not the universal proposal.
Cookware: no new PFAS rule in 2026
Cookware is in a different position. It is not on the list of products covered by the PFHxA restriction, and the PFAS limits in the Packaging and Packaging Waste Regulation apply to packaging, not to pans and baking trays. Older group rules do apply to cookware as to any article: PFOA, its salts and PFOA-related compounds have been restricted under the POPs Regulation since July 2020, and C9–C14 PFCAs under REACH since February 2023. What is still open is whether fluoropolymer coatings as such will be restricted.
For non-stick cookware, beyond the existing PFOA and C9–C14 PFCA limits, the question is what the universal restriction will eventually say about fluoropolymers and about food-contact articles. As of July 2026, that is not settled. A sensible strategy is to know today which of your products use a fluorinated coating, so you can respond quickly when the final scope and transition periods are published.
Food-contact packaging: PPWR from 12 August 2026
For companies that pack food, there is one more date in 2026. Under Article 5(5) of the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, food-contact packaging may not be placed on the market from 12 August 2026 if it contains PFAS at or above:
- 25 ppb for any PFAS measured with targeted analysis;
- 250 ppb for the sum of PFAS measured with targeted analysis;
- 50 ppm for PFAS including polymeric PFAS.
This covers the packaging, not the product inside it. A cookware importer that sells pans in a printed carton is not affected; a company selling packaged food or food-contact disposables is. Read more in our PPWR guide and the problem page on food-contact products.
What to ask suppliers now
The common thread is data. The binding rules work with concentration limits, and the universal restriction will almost certainly do the same. Practical steps for an importer:
- Map products by function. Which products have water-, oil- or stain-repellent finishes, non-stick coatings or fluorinated membranes?
- Ask suppliers a precise question. Not “is this PFAS-free?”, but whether PFHxA, its salts or related substances are used, and whether any PFAS are intentionally added.
- Ask for test reports for clothing and footwear placed on the market from 10 October 2026, against the 25 ppb and 1,000 ppb limits.
- Record the placing-on-the-market date of stock, so you can show which units fall under the transitional exemption.
- Keep the answers with the product, so you can update them when the universal restriction is decided.
Our REACH guide, the REACH glossary entry and the problem page on chemicals in clothing explain the wider REACH duties, and our earlier article on the REACH Regulation covers SVHC communication.
How Conphora helps
PFAS compliance is a supplier-data task that has to be ready before the rule applies. With Conphora you can:
- Collect supplier declarations and test reports per product and keep them versioned.
- Flag products with relevant finishes or coatings, so you know where PFHxA and future PFAS rules apply.
- Track the dates – 12 August 2026, 10 October 2026, 10 October 2027 – against each product range.
- Answer customer and authority questions from one up-to-date record instead of an email search.
See how Conphora works and how it keeps chemical data next to the product.
Preparing your textiles for 10 October? See plans and pricing →
Sources
- ECHA: Risk Assessment Committee adopts its opinion on the PFAS restriction proposal
- ECHA: Socio-Economic Analysis Committee agrees its draft opinion on the PFAS restriction proposal
- Commission Regulation (EU) 2024/2462 (PFHxA restriction), EUR-Lex
- Commission Delegated Regulation (EU) 2020/784 (PFOA under the POPs Regulation), EUR-Lex
- Commission Regulation (EU) 2021/1297 (C9–C14 PFCAs, REACH Annex XVII entry 68), EUR-Lex
- Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation), EUR-Lex