EU REACH Restriction on PFHxA Takes Effect for Consumer Clothing, Accessories and Footwear

The PFHxA restriction under REACH applies to consumer clothing, related accessories and footwear from 10 October 2026, following the 24-month transition period set by Commission Regulation (EU) 2024/2462. The restriction prohibits placing those products on the EU market where any homogeneous material contains PFHxA and its salts at 25 ppb or more, or PFHxA-related substances at 1 000 ppb or more. Other consumer textiles, leather, furs and hides follow a longer transition, with the same limits applying from 10 October 2027.

Undecafluorohexanoic acid (PFHxA) is a short-chain, C6 perfluoroalkyl carboxylic acid used historically in treatments that give textiles, leather and footwear resistance to water, oil and stains. It sits inside the broader per- and polyfluoroalkyl substances (PFAS) family, and some substances in that family are highly persistent in the environment.

The European Commission adopted Regulation (EU) 2024/2462 on 19 September 2024, amending Annex XVII to Regulation (EC) No 1907/2006 (REACH) as regards undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances. The restriction was developed through the standard REACH restriction route, with opinions from the Committee for Risk Assessment (RAC) and the Committee for Socio-economic Analysis (SEAC) forming the basis of the Commission's final scoping decisions.

The critical point for anyone scoping a compliance programme: this is a targeted restriction on PFHxA, its salts and substances that can degrade into PFHxA. It is not a ban on PFAS as a class. The separate universal PFAS restriction proposal remains in progress under REACH and has not been adopted. Treating the two as the same obligation produces both over-compliance and missed scope.

Regulation (EU) 2024/2462 inserts a new entry into Annex XVII of REACH covering PFHxA, its salts and PFHxA-related substances, and sets two distinct concentration limits with staggered application dates by product category.

For clothing, related accessories and footwear intended for the general public, the restriction applies after a 24-month transition period, from 10 October 2026. The limits are 25 ppb for the sum of PFHxA and its salts, and 1 000 ppb for the sum of PFHxA-related substances. Both are measured at the homogeneous material level — individual materials within an article, not the finished article as a whole.

Other consumer textiles, leather, furs and hides receive a longer transition and are caught from 10 October 2027. The same entry also addresses further uses with their own application dates; verify the specific use against the Official Journal text rather than assuming a single date covers your portfolio.

The obligation is a placing-on-the-market prohibition. From the applicable date, a restricted article may not be placed on the EU market if any homogeneous material within it exceeds the limits. For goods manufactured outside the EU, import constitutes placing on the market, which means the importer carries the obligation at the point of customs clearance, not at the point of retail sale.

Two chemically distinct thresholds operate inside one entry: 25 ppb for the sum of PFHxA and its salts, and 1 000 ppb for the sum of PFHxA-related substances. The forty-fold difference between the two is not an error — it reflects that related substances are precursors that may transform into PFHxA rather than PFHxA itself.

The measurement basis is the decisive technical detail. A 25 ppb limit on homogeneous material is far stricter in practice than the same number applied to a finished garment, because dilution across components does not help you. A durable water repellent finish applied to a shell fabric is assessed on that shell fabric. A coated membrane, a leather upper, a textile lining, a zip tape, a printed label and an elastic binding are each separate homogeneous materials.

For the purposes of the restriction, PFHxA-related substances are those that, on the basis of their molecular structure, are liable to degrade or transform into PFHxA. The restriction therefore captures precursor chemistries used in repellent formulations, not only residual PFHxA itself.

The Commission narrowed the scope on scientific grounds. Recital 23 of Regulation (EU) 2024/2462 records that the Commission agrees with RAC and SEAC that substances having a perfluoroalkyl group C6F13- directly attached to an oxygen atom at one of the non-terminal carbons should be excluded from the scope of substances subject to the restriction, since those substances cannot be transformed into PFHxA — their chemical structure is such that degradation to a carboxylic acid or carboxylate would form two separate shorter fluoroalkyl chains, the hazards and risks of which were not assessed. If a supplier's chemistry falls into that structural class, it is out of scope, and that argument should be documented in the technical file rather than asserted verbally.

The 10 October 2026 tranche covers textiles, leather, furs and hides used in clothing and related accessories for the general public, and footwear for the general public. Footwear is addressed as a product category in its own right, so uppers, linings and textile or leather components used in consumer footwear are in scope from the 2026 date — they do not wait for the 2027 tranche that covers other consumer textiles, leather, furs and hides.

Articles placed on the EU market before the applicable date are not caught by the restriction, which operates on placing on the market rather than on continued possession or use. Secondary practitioner sources also describe derogations covering certain Category III personal protective equipment under Regulation (EU) 2016/425, medical devices under Regulations (EU) 2017/745 and (EU) 2017/746, and construction textiles. Those derogations have not been verified word-for-word against the Official Journal text in the sources compiled here — read the entry directly before relying on any exemption, because derogation wording in Annex XVII is typically use-specific and narrowly drafted.

EU manufacturers, importers and brand owners placing consumer clothing, related accessories and footwear on the EU market are directly affected from 10 October 2026. Suppliers outside the EU are affected commercially rather than legally — the obligation lands on whoever places the product on the EU market, but the data needed to demonstrate compliance sits upstream in the finishing mill and the chemical formulator.

The operational burden concentrates in three places. First, water, oil and stain repellent finishes — the durable water repellent chemistries that have historically used C6 fluorotelomer products. Second, coated and laminated fabrics, where the coating is a separate homogeneous material. Third, leather and footwear components, where tanning, finishing and waterproofing chemistries are applied by different tiers of the supply chain and are rarely visible in a brand's bill of materials.

Second-order effect worth planning for: a brand with both apparel and home textile lines is running two calendars for the same chemical family. The same shell fabric used in a jacket is restricted from 10 October 2026 and in a curtain from 10 October 2027. Material-level qualification programmes should be built to the earlier date to avoid maintaining two specifications for one article.

The practical requirement is to demonstrate that no homogeneous material in a restricted article reaches 25 ppb for PFHxA and its salts or 1 000 ppb for PFHxA-related substances. REACH does not prescribe a specific conformity route for Annex XVII restrictions, so the evidence base is built from supplier declarations, chemical formulation data and analytical test reports held against each material.

Supplier declaration requirements under this PFHxA REACH restriction should be framed at the chemistry level, not the article level. A declaration stating "PFAS-free" is not evidence; a declaration naming the repellent system used, confirming it contains no PFHxA, PFHxA salts or structurally related precursors, and supported by a formulation-level statement from the chemical supplier, is.

Two dates matter for textile and footwear portfolios. 10 October 2026 closes the 24-month transition for clothing, related accessories and footwear intended for the general public. 10 October 2027 closes the longer transition for other consumer textiles, leather, furs and hides.

Enforcement sits with Member State market surveillance and customs authorities, exercised under the national REACH enforcement regimes established under Title XIV of Regulation (EC) No 1907/2006. The sources compiled here contain no published enforcement statistics, inspection targets or campaign announcements for this entry, and none should be assumed. What is predictable is the mechanism: Annex XVII textile restrictions are typically enforced through sampling at import and at retail, with non-compliant articles withdrawn from the market.

Secondary practitioner sources report that France and Denmark implemented broader national PFAS restrictions on certain consumer clothing, footwear and waterproofing products during 2026, applying total fluorine screening thresholds rather than substance-specific limits. Those measures have not been verified against national official journals in the sources compiled here and are flagged as unverified practitioner intelligence.

The structural point still holds and should be reflected in your market access matrix: a product that satisfies the PFHxA limits in Regulation (EU) 2024/2462 is not automatically compliant with a national total-fluorine measure, because the two use different analytical endpoints. Confirm each national requirement directly with the relevant Member State authority before relying on EU-level compliance alone.

Start from the bill of materials, not the SKU. List every homogeneous material in each in-scope article — shell, lining, membrane, coating, interlining, trims, leather components, footwear uppers and soles — and map each one to a named supplier and a named finishing chemistry. Articles without a complete material map cannot be cleared.

Prioritise materials carrying water, oil or stain repellent claims. Any article marketed as water-repellent, waterproof, stain-resistant or easy-care is the first testing cohort. Request from each finishing supplier the identity of the repellent system in use and a written statement addressing PFHxA, PFHxA salts and PFHxA-related substances by reference to Regulation (EU) 2024/2462, not by reference to a generic PFAS claim.

Commission analytical testing against the 25 ppb and 1 000 ppb limits on homogeneous material for every repellent-treated material and every coated or laminated construction, and keep a dated test report on file per material rather than per season. Where a supplier asserts that its chemistry is out of scope because the perfluoroalkyl group C6F13- is directly attached to an oxygen atom at a non-terminal carbon, obtain that structural justification in writing and retain it alongside the recital 23 reference.

Finally, separate the 2026 and 2027 cohorts in your product master data. Apparel, accessories and footwear must be clear by 10 October 2026; home textiles and other consumer textiles, leather, furs and hides by 10 October 2027. Inventory placed on the EU market before the applicable date is not retrospectively caught, so document placing-on-market dates for transitional stock — that record is the only defence if a retailer's shelf stock is sampled after the date.

10 October 2027 is the next fixed date in this entry: the same 25 ppb and 1 000 ppb limits extend to other consumer textiles, leather, furs and hides. Beyond that, the universal PFAS restriction proposal remains under consideration in the REACH restriction process, and the Commission will ultimately decide on it in consultation with the Member States in the REACH Committee. No adoption date has been set, and no scope should be planned against it until a draft regulation is published in the Official Journal.

Next milestone: 10 October 2027. 10 October 2027 is the next fixed date in this entry: the same 25 ppb and 1 000 ppb limits extend to other consumer textiles, leather, furs and hides. Beyond that, the universal PFAS restriction proposal remains under consideration in the REACH restriction process, with no adoption date set.