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EU REACH PFHxA Restrictions: Compliance Timeline and Limits for 2026-2027

Beveridge & Diamond PC USA
Overview
The European Union is implementing new REACH restrictions on PFHxA and related substances in textiles and footwear starting October 10, 2026. These regulations establish strict concentration limits of 25 ppb for PFHxA and 1,000 ppb for related substances, signaling a broader regulatory shift toward PFAS elimination in the apparel industry.
In Depth

Key Findings

Regulation (EU) 2024/2462 amends Annex XVII of REACH to prohibit specific concentrations of undecafluorohexanoic acid (PFHxA), its salts, and PFHxA-related substances. The restriction first applies on October 10, 2026, to clothing, accessories, and footwear for the general public. This will expand on October 10, 2027, to cover all other textiles, leather, furs, and hides.

Technical Details

The regulation sets the following concentration limits measured in homogeneous material:

  • PFHxA and its salts: 25 parts per billion (ppb) or more.
  • PFHxA-related substances: 1,000 ppb or more.

PFHxA-related substances are defined as those likely to break down into PFHxA based on molecular structure. While numerical limits are established, the regulation does not prescribe a specific testing method. Exclusions apply to certain construction textiles and personal protective equipment. Products placed on the market before the respective 2026 and 2027 deadlines are not subject to these restrictions.

Background & Context

Unlike EU directives, this regulation is binding and directly applicable across all Member States without requiring national implementing legislation, though enforcement and penalties remain national responsibilities. This measure coincides with broader PFAS restrictions in Europe. France prohibited PFAS in consumer clothing and footwear on January 1, 2026, with limits of 25 ppb for targeted analysis (excluding polymers) and 50 ppm for PFAS including polymers. Denmark implemented a restriction on July 1, 2026, prohibiting products containing total fluorine at or above 50 mg F/kg.

Significance & Outlook

The shift toward stricter PFAS limits necessitates that manufacturers and importers evaluate supply chains and review supplier specifications. Because requirements differ across jurisdictions regarding covered compounds, concentration thresholds, and testing approaches, companies must combine analytical testing with upstream chemical controls and compliance documentation to ensure market access in the EU.

Source: https://natlawreview.com/article/new-eu-pfhxa-limits-take-effect-amid-expanding-pfas-rules-apparel-and-textiles

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