New EU PFHxA Limits Take Effect Amid Expanding PFAS Rules for Apparel and Textiles

• What Is Happening: Beginning October 10, 2026, a new restriction under the European Union’s (EU) Registration, Evaluation, Authorisation and Restriction of Chemicals Regulation (REACH) will prohibit certain concentrations of undecafluorohexanoic acid (PFHxA), its salts, and PFHxA-related substances in clothing, accessories, and footwear for the general public.
• What Else Is Changing: The PFHxA restriction is one of a growing number of measures targeting per- and polyfluoroalkyl substances (PFAS) in apparel and textiles. France and Denmark implemented broader PFAS restrictions in 2026; the European Chemicals Agency (ECHA) advanced its evaluation of a proposed EU-wide PFAS restriction; and additional U.S. states implemented or finalized requirements targeting PFAS in apparel and textiles.
• What Companies Should Do: Companies that manufacture, import, distribute, or sell apparel and textile products should evaluate the PFAS used throughout their supply chains, assess products against applicable jurisdiction-specific requirements, and review supplier specifications, testing protocols, and compliance documentation. These efforts are particularly important because expanding requirements differ significantly in the PFAS compounds and products they cover, applicable concentration thresholds, exemptions, and testing approaches.

EU PFHxA Restriction Takes Effect October 10

In September 2024, the European Commission adopted Regulation (EU) 2024/2462, amending Annex XVII of REACH to restrict PFHxA, its salts, and certain PFHxA-related substances. PFHxA belongs to the broader family of PFAS, which have been used in apparel and textiles for properties including water, oil, and stain repellency.

Beginning October 10, 2026, the restriction prohibits concentrations of 25 parts per billion (ppb) or more of PFHxA and its salts, or 1,000 ppb or more of PFHxA-related substances, in textiles, leather, furs, and hides used in clothing and related accessories, as well as in all footwear for the general public. The limits are measured in homogeneous material. REACH defines PFHxA-related substances for purposes of the restriction as substances that are likely to break down into PFHxA based on their molecular structure.

The restriction will expand further on October 10, 2027, when the same concentration limits will apply beyond clothing, accessories, and footwear for the general public to all other textiles, leather, furs, and hides.

The restriction provides several exclusions, including certain personal protective equipment and construction textiles. It also includes an important transition provision: the restriction does not apply to products placed on the market before the October 10, 2026, and October 10, 2027, application dates.

Although the restriction establishes numerical concentration limits, it does not prescribe a specific testing method, and analytical methods for detecting PFHxA-related substances continue to evolve. Companies should consider not only analytical testing but also upstream chemical controls, supplier information, and other compliance documentation when evaluating products against the new requirements.

The Restriction Applies Directly Across EU Member States

Notably, the PFHxA requirements differ from EU directives that require implementation through Member State legislation. Regulation (EU) 2024/2462 directly amended REACH, an EU regulation, and is “binding in its entirety and directly applicable in all Member States.” Enforcement does not depend on Member States enacting implementing legislation.

Enforcement, however, remains primarily national. REACH requires Member States to “maintain a system of official controls” and establish penalties for violations that are “effective, proportionate and dissuasive.” Accordingly, while the substantive PFHxA concentration limits apply across the EU, each Member State establishes its own enforcement mechanisms and penalties.

Broader European PFAS Restrictions Are Also Expanding

The October REACH deadline is part of a broader shift toward restrictions on PFAS in apparel and textiles across Europe. Since B&D's June 2025 overview of environmental issues affecting the apparel and textile industry, France’s and Denmark’s broader PFAS restrictions are now in effect, while the EU's proposed restriction on the broader PFAS class has advanced through the REACH restriction process.

Restrictions in France and Denmark

Beginning January 1, 2026, France prohibited the manufacture, import, export, and sale of clothing and footwear intended for consumers that contain PFAS, subject to specified exemptions and concentration thresholds.

France finalized those thresholds in December 2025. The implementing decree establishes limits of 25 ppb for PFAS measured through targeted analysis, excluding polymers; 250 ppb for the sum of PFAS measured through targeted analyses, potentially following degradation of precursors and excluding polymers; and 50 ppm for PFAS including polymers. Where total fluorine exceeds 50 mg F/kg, regulated entities may be required to demonstrate whether the measured fluorine originates from PFAS or non-PFAS substances. The French law also provides for a broader prohibition beginning January 1, 2030, covering textile products containing PFAS, subject to specified exceptions for essential uses.

Denmark's national PFAS restriction on certain consumer clothing, footwear, and waterproofing products became applicable on July 1, 2026. The measure prohibits the import and sale of covered products containing total fluorine at or above 50 mg F/kg, subject to specified exemptions. Existing business inventories may continue to be sold until January 1, 2027.

The French and Danish restrictions are broader in chemical scope than the EU restriction taking effect in October, which targets PFHxA, its salts, and certain substances that can degrade or transform into PFHxA. (Unlike the French law, the Danish law carves out an exception for PFAS that are regulated under REACH or the EU POPs Regulation.) The national measures instead address the broader PFAS class in covered products.

The Broader EU PFAS Restriction Continues to Advance

Meanwhile, ECHA continues to evaluate a much broader proposal to restrict PFAS under REACH. Authorities from Denmark, Germany, the Netherlands, Norway, and Sweden originally submitted the proposal in 2023, seeking restrictions on the manufacture, sale, and use of a broad range of PFAS across almost all sectors of the economy, including textiles, upholstery, leather, apparel, and carpets.

The proposal reached significant milestones in 2026. In March, ECHA's Committee for Risk Assessment adopted its final opinion, while ECHA's Committee for Socio-Economic Analysis (SEAC) issued its draft opinion and subsequently held a 60-day consultation. Both committees have supported an EU-wide restriction on PFAS while recommending specific derogations and other controls for certain uses.

SEAC should publish its final opinion by the end of 2026, completing ECHA’s scientific evaluation. The Commission said it intends to develop and present a restriction proposal as soon as possible thereafter, although in practice several months could pass before it releases its proposal. This proposal to amend REACH Annex XVII would then proceed to a vote in the REACH Committee followed by scrutiny by the European Parliament and Council. Final adoption is expected in late 2027 or in 2028.

Like the French and Danish PFAS restrictions, the EU-wide PFAS restriction is expected to be class-based and therefore cover a broader range of PFAS than the PFHxA restriction taking effect in October. Accordingly, compliance with the new PFHxA limits should not be viewed as the endpoint of PFAS regulation for apparel and textiles in the EU.

U.S. States Continue to Expand Apparel and Textile PFAS Requirements

PFAS regulation of apparel and textiles is also expanding in the United States. State requirements vary substantially in their scope and approach, with some states prohibiting “intentionally added PFAS,” others establishing concentration-based thresholds, and still others imposing labeling, notification, or reporting requirements.

Several significant requirements have taken effect or been finalized since B&D's June 2025 apparel and textile update:

• Maine: Beginning January 1, 2026, Maine prohibits the sale of textiles containing intentionally added PFAS, subject to specified exceptions. Outdoor apparel is treated separately and is subject to a later prohibition beginning in 2029 unless accompanied by a required PFAS disclosure. The disclosure requirement applies to all sales, including online sales.
• Vermont: Beginning January 1, 2026, Vermont prohibits manufacture, distribution, or sale of textiles containing intentionally added PFAS.
• Connecticut: Beginning July 1, 2026, apparel and textiles containing intentionally added PFAS became subject to detailed notification and labeling requirements. Connecticut is scheduled to prohibit them entirely beginning January 1, 2028.
• Washington: In November 2025, Washington finalized regulations restricting intentionally added PFAS in apparel and accessories beginning January 1, 2027. The regulations establish a rebuttable presumption that total fluorine above 50 ppm indicates intentionally added PFAS. Washington separately requires reporting for certain other PFAS-containing product categories, including footwear and apparel intended for extreme and extended use.

Several states with PFAS restrictions discussed in B&D’s June 2025 alert have additional compliance deadlines approaching. For example, California's total-organic-fluorine threshold will decrease from 100 ppm to 50 ppm beginning January 1, 2027; Rhode Island's prohibition on intentionally added PFAS in textile articles also takes effect on January 1, 2027; and Colorado's prohibition for textile articles and outdoor apparel for severe wet conditions takes effect January 1, 2028. New York is also developing regulations to implement an additional concentration-based restriction that must take effect no later than January 1, 2027.

Key Compliance Considerations

The patchwork of PFAS restrictions does not establish a uniform compliance standard for apparel and textile companies. The requirements differ not only in effective dates and covered products, but also in the substances regulated and how compliance is determined.

The EU restriction taking effect in October establishes concentration limits for a defined subset of PFAS, while other jurisdictions regulate a broader range of PFAS based on intentional addition, concentration thresholds, or both. Testing and compliance approaches vary and therefore are not necessarily interchangeable across jurisdictions. For example, documentation demonstrating that PFAS were not intentionally added may support compliance with restrictions on intentionally added PFAS, such as those in New York and Vermont. That documentation, however, would not establish compliance with the concentration-based restrictions, such as the EU’s, which apply whenever PFHxA or PFHxA-related substances meet the specified concentration limits, regardless of whether they were intentionally added. Similarly, testing used to assess fluorine thresholds under restrictions in France, Denmark, Washington, and California may support compliance with those requirements, but may not demonstrate compliance with the EU’s substantially lower, substance-specific limits for PFHxA and PFHxA-related substances. Conversely, targeted testing demonstrating compliance with the EU’s PFHxA limits would not necessarily establish compliance with broader French or Danish restrictions because those measures reach PFAS beyond the subset covered by the EU PFHxA restriction.

As a result, compliance with one jurisdiction’s requirements may not establish compliance elsewhere. Companies selling apparel and textile products across multiple jurisdictions should review the PFAS used throughout their supply chains against each jurisdiction’s applicable requirements and consider whether existing supplier specifications, certifications, and testing protocols adequately address differences among these regimes. Broader compliance efforts may include mapping chemicals used in products and production processes, identifying higher-risk treatments and materials, evaluating appropriate analytical testing, and maintaining documentation concerning product composition and when products are placed on the market.

These requirements also remain in flux. Additional state compliance deadlines are approaching, analytical methods continue to develop, and the EU is considering a substantially broader PFAS restriction under REACH. Companies should continue to monitor regulatory and technical developments while preparing for requirements already scheduled to take effect.

Beveridge & Diamond’s Consumer Apparel and Textiles, Products and Product Stewardship, Chemicals, and International practices help manufacturers, retailers, distributors, and importers assess product requirements, manage supply-chain compliance, and address a broad range of global environmental challenges. For more information, please contact the authors.