Product Compliance

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

On 10 October 2026, Commission Regulation (EU) 2024/2462 starts restricting PFHxA, its salts and PFHxA-related substances in clothing, footwear and accessories sold to the general public in the EU, at 25 ppb and 1,000 ppb respectively, measured per homogeneous material rather than as a finished-product average. PFHxA is the short-chain PFAS much of the outerwear and footwear industry adopted to replace long-chain PFAS like PFOA and PFOS after the EU restricted those roughly a decade ago. Non-clothing textiles and leather get until 10 October 2027; firefighting foam was already covered from 10 April 2026.

Naomie HaliouaCDO and co-founder 4 September 2026 · 6 min read

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.

Three details behind the 10 October deadline

The limit applies per material, not per garment

Entry 79 measures PFHxA in the specific homogeneous material where it is found: a coated outer shell, a lining, a zipper pull. A finished-garment average that blends a treated fabric with untreated components does not answer the question the restriction actually asks.

PFHxA was the replacement, not the original target

Long-chain PFAS such as PFOA and PFOS were restricted roughly a decade ago. Much of the water-repellent finishing industry moved to shorter-chain compounds, PFHxA among them, specifically to keep selling treated products after that first restriction.

Stock already on the market before 10 October is not recalled

Entry 79 restricts what can be placed on the market from the deadline forward. It does not order the withdrawal of clothing or footwear already sold or already on shelves before the date, which shifts the compliance question to incoming production and inventory.

19 Sep 2024

The European Commission adopts Regulation (EU) 2024/2462, adding Entry 79 to REACH Annex XVII to restrict PFHxA, its salts and PFHxA-related substances.

10 Apr 2026

The restriction takes effect for firefighting foams used in training, testing and public fire services.

10 Oct 2026

The restriction takes effect for clothing, footwear and related accessories for the general public, food-contact paper and board, general-purpose mixtures, and cosmetic products.

10 Oct 2027

The restriction extends to textiles, leather, furs and hides used in products other than clothing and related accessories for the general public.

10 Oct 2029

The restriction extends to firefighting foam and foam concentrates for civil aviation, including civilian airports.

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.

parts per billion, the maximum concentration allowed for the sum of PFHxA and its salts in a homogeneous material of clothing, footwear or a related accessory from 10 October 2026

1,000

parts per billion, the maximum concentration allowed for the sum of PFHxA-related substances in that same homogeneous material, ten times looser than the limit on PFHxA itself

days between the publication date of this article and the 10 October 2026 deadline for clothing, footwear and related accessories placed on the EU market

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

The narrow read

The EU added one more PFAS chemical to its REACH restriction list, with a threshold that starts applying to clothing and footwear on 10 October 2026.

The structural read

The compound now being restricted is the one much of the industry switched to specifically to survive the EU's last PFAS restriction, and the new limit is tested per material inside a garment rather than as a finished-product average, which turns the compliance question from 'is this jacket PFAS-free' into 'can we prove, layer by layer, which chemical our supplier's coating actually contains.'

Sources & references

Frequently asked questions

What does the EU's PFHxA restriction ban starting 10 October 2026?

From 10 October 2026, Entry 79 of REACH Annex XVII (added by Commission Regulation (EU) 2024/2462) bans placing clothing, footwear or related accessories for the general public on the EU market if any homogeneous material inside them contains undecafluorohexanoic acid (PFHxA) and its salts above 25 parts per billion, or PFHxA-related substances above 1,000 parts per billion. Food-contact paper and board, general-purpose mixtures such as waterproofing sprays, and cosmetic products are restricted on the same date. Stock already placed on the market before 10 October is not affected.

Why does the PFHxA limit apply per material instead of per finished product?

Entry 79 sets its 25 ppb and 1,000 ppb thresholds against a 'homogeneous material,' a single, uniformly composed part of a product, such as a coated outer shell fabric, a lining or a zipper pull, rather than against the finished garment as a whole. A composite test that averages a treated and an untreated component together can pass even when the treated material alone exceeds the limit, which means brands need chemical data at the component level, not just a single certificate for the finished product.

Why was PFHxA used in clothing and footwear in the first place?

PFHxA is a short-chain per- and polyfluoroalkyl substance (PFAS) that the durable water-repellent and stain-resistant finishing industry adopted to replace long-chain PFAS, including PFOA and PFOS, after the EU restricted those substances roughly a decade earlier. Short-chain PFAS were marketed as a safer substitute at the time, which is why PFHxA is now common in the water-repellent coatings, waterproofing sprays and stain treatments used on outerwear, rainwear and waterproof footwear.

Sources

Note on verification: this session's network access allows search but blocks direct retrieval of eur-lex.europa.eu and echa.europa.eu pages. The regulation number, adoption date and Entry 79 text were confirmed through search-indexed excerpts of the Official Journal filing itself, then cross-checked against four independent professional testing and certification bodies (UL Solutions, TÜV SÜD, TÜV Rheinland, SATRA) that all report the same concentration limits and application dates.