On 10 October, the EU enforces a PFAS limit in clothing and footwear for the first time: the same restriction sets two different concentration thresholds, not one, and waits a full year before reaching everything else cut from the same fabric

What actually changes, and on which date

Entry 79 of REACH Annex XVII does not set one limit for one substance. It sets two. The first, 25 ppb, applies to the sum of PFHxA and its salts, the chemical itself. The second, 1,000 ppb, forty times higher, applies separately to the sum of PFHxA-related substances, which the regulation defines by molecular structure: substances considered to have the potential to degrade or transform into PFHxA over time, even if they are not PFHxA at the point of sale. A supplier declaration or a lab test that checks only one of the two groups does not demonstrate compliance with the other. Both thresholds are measured 'in homogeneous material,' REACH's standard term for a single material that cannot be mechanically separated into different materials, not in the finished article as a whole. A jacket is not one homogeneous material; its outer shell fabric, its waterproof membrane, its durable water repellent (DWR) finish, and its lining or trim are each tested on their own.

The same entry also assigns different transition periods to different product categories, rather than one date for 'textiles.' Firefighting foam placed on the market for the general public got the shortest runway, 18 months, ending 10 April 2026, already passed. Clothing, related accessories and footwear got 24 months, ending 10 October 2026. Every other textile, leather, fur or hide article for the general public, the categories that do not fit 'clothing,' got 36 months, ending 10 October 2027. A brand that sells both apparel and home textiles, a common combination in retail, is reading two different deadlines for materials that can be chemically identical.

The numbers behind the date

One number is how soon the headline date arrives. One is the gap between the two chemical thresholds inside the same restriction. The third is the gap between the two product-category deadlines inside that same restriction.

The real subject: a marketing claim is not a lab result, and a garment is not one material

Most coverage compresses entry 79 into a single line: the EU bans a PFAS chemical in clothing from 10 October 2026. That line hides two separate compliance questions behind one date. The first is chemical: PFHxA itself, capped at 25 ppb, is a distinct question from PFHxA-related substances, capped at 1,000 ppb and defined by their potential to degrade into PFHxA later. A brand that moved years ago from long-chain PFAS (C8 chemistry) to PFHxA-based finishes, marketed at the time as a safer, shorter-chain alternative, can still be out of compliance with entry 79 on 10 October, because PFHxA was never the chemical those earlier 'PFAS-free' or 'C6 DWR' claims were written to address. The second question is structural: both thresholds apply 'in homogeneous material,' so a finished-product certificate that says 'the garment passed' does not say which of its components passed. A compliant outer shell paired with a non-compliant DWR coating still fails entry 79, because the regulation never tested the garment as a whole in the first place.

Why it matters for brands

Three groups selling into the EU are reading entry 79 against different deadlines, and all three need data entry 79's headline date does not supply. First, apparel, footwear and accessory brands, particularly outerwear, rainwear, sportswear and workwear where DWR finishes are common, need per-component lab results against both thresholds by 10 October 2026, not a single supplier declaration covering the finished SKU; a declaration that says 'PFAS-free' without naming which chemistry family it tested for does not answer whether PFHxA itself, or its related substances, clear entry 79's limits. Second, any brand selling both clothing lines and home-textile lines, upholstery fabric, cushions, outdoor furniture textiles, under the same supplier relationships needs to classify each SKU correctly, because a fabric qualifying as a 'related accessory' faces the 2026 deadline while the identical fabric sold as a cushion cover faces 2027; the regulation reads the end use of the article, not the roll of fabric it was cut from. Third, every brand needs its product data to go down to the 'homogeneous material' level the regulation actually tests at, shell fabric, membrane, coating and trim recorded as separate materials with separate test results, because a single finished-garment pass/fail label cannot show a regulator, or a customs authority, which specific layer the result applies to.

Two ways to read the 10 October date

Sources & references

1. Regulation (EC) No 1907/2006: REACH
2. Regulation (EU) 2023/1114: Markets in Crypto-Assets (MiCA)

Frequently asked questions

Sources

1. EUR-Lex: Commission Regulation (EU) 2024/2462 of 19 September 2024 amending Annex XVII to Regulation (EC) No 1907/2006 (REACH) as regards PFHxA, its salts and PFHxA-related substances, the primary legal text, cited here for independent verification
2. UL Solutions: "PFHxA and Related Substances: Commission Regulation (EU) 2024/2462," corroborating the adoption date, the 25 ppb / 1,000 ppb thresholds and the homogeneous-material measurement basis
3. TÜV SÜD: "EU REACH Annex XVII restriction on PFHxA was published," corroborating the entry-into-force date and the 18-, 24- and 36-month transition periods by product category
4. Bureau Veritas (CPS): "EU REACH: Restriction of PFHxA," independently corroborating the concentration limits and the clothing/footwear/accessories deadline of 10 October 2026
5. Intertek: "EU Commission adopt a Union-wide restriction on PFHxA, its salts and PFHxA-related substances," corroborating the product scope, including textiles, food packaging, consumer mixtures, cosmetics and firefighting foam

Note on verification: this session's network access allows search but blocks direct page retrieval from eur-lex.europa.eu, ul.com, tuvsud.com, bureauveritas.com and intertek.com, among other official and compliance-vendor domains. The regulation's identity, Commission Regulation (EU) 2024/2462, its 19 September 2024 adoption date, its 10 October 2024 entry into force, the two concentration thresholds (25 ppb for PFHxA and its salts, 1,000 ppb for PFHxA-related substances), the homogeneous-material measurement basis, and the 18-, 24- and 36-month transition periods were confirmed through search-indexed excerpts of the official text and cross-checked against independent summaries from UL Solutions, TÜV SÜD, TÜV Rheinland/TÜV.com, Bureau Veritas, Intertek, SGS and Eurofins, all of which state the same dates and thresholds. Where a figure or claim could not be cross-checked across at least two independent sources, it has been left out of this article.