From 10 October 2026, EU law caps PFHxA at 25 parts per billion in clothing, footwear and accessories: the same short-chain PFAS that suppliers adopted to replace the long-chain chemicals Brussels restricted a decade earlier

One restriction, five different start dates

Entry 79 of REACH Annex XVII does not turn on for every covered product at once. The Commission staggered its application by product category, giving industries more or less time to reformulate depending on how readily a substitute exists. Firefighting foam for training, testing and public fire services was the first category caught, from 10 April 2026. Clothing, footwear and related accessories for the general public follow on 10 October 2026, alongside food-contact paper and board, general-purpose mixtures sold to consumers (waterproofing sprays among them) and cosmetic products. Textiles, leather, furs and hides used in products other than clothing and accessories, upholstery and non-apparel goods, get until 10 October 2027. Firefighting foam for civil aviation is the last category caught, not until 10 October 2029. Because the regulation is a directly applicable EU regulation rather than a directive, none of these dates require national transposition: the same threshold and the same calendar apply in every member state at once.

The numbers behind Entry 79

Two numbers are the concentration limits the restriction actually sets. The third is how little time remains, from today, to reach the deadline that matters most for apparel and footwear brands.

The real subject: a threshold that a finished-product test can miss

Most coverage of PFAS restrictions reads them as a chemistry question: is the treatment PFAS-free or not. Entry 79 is built to be answered at a finer grain than that. The 25 ppb and 1,000 ppb limits apply to a homogeneous material, a single, uniformly composed part of the product, not to the garment or shoe as a whole. A rain jacket has several homogeneous materials: the outer shell fabric, its durable water-repellent coating, the lining, the seam tape, the zipper and its pull. A brand that tests only a composite sample of the finished jacket, or that relies on a single supplier declaration covering the whole product, can pass a test that never actually isolates the coating where PFHxA is most likely to sit. The compliance question this deadline poses is not just chemical, it is a data question: does the brand know, material by material, which finisher supplied which coating, and does it hold a test result or a substantiated declaration for that specific material, rather than an aggregate figure or a generic 'PFAS-free' claim that does not say which PFAS was checked for and where.

Why it matters for brands

The direct exposure sits with outerwear, rainwear, waterproof footwear and sportswear brands selling into the EU, along with any bag, accessory or general-purpose waterproofing product marketed to consumers, since durable water-repellent and stain-resistant finishes are exactly where PFHxA was adopted as a substitute a decade ago. Before 10 October, a compliance team sourcing these categories needs material-level chemical data for every water-repellent, oil-resistant or stain-resistant finish in its EU-bound range, not a blanket supplier attestation: which finisher applied the treatment, which specific fluorochemical formulation it used, and whether that formulation was re-tested after the mill's own reformulation rather than assumed unchanged. Brands that also sell non-clothing textile or leather goods, luggage, upholstery, accessories not tied to an outfit, get an extra year on those lines, to 10 October 2027, which means the classification of a given product as 'accessory for the general public' versus a non-clothing textile item is itself a decision worth documenting now, since it decides which of two deadlines applies. Because the restriction only bites on what is placed on the market from the deadline, not on stock already sold, the practical cutoff for incoming production is earlier than 10 October once shipping and customs lead times for goods entering the EU are factored in.

Two ways to read 10 October