PFHxA in clothing and footwear – 25/1,000 ppb, test reports and old stock
PFHxA restrictions for clothing and footwear apply from 10 October 2026. Learn the 25/1,000 ppb material limits, laboratory evidence and the existing-EU-stock exception.
Do you import or sell waterproof jackets, shoes or coated textiles? Since 10 October 2026, REACH Annex XVII entry 79 restricts PFHxA, its salts and related substances in certain consumer articles. The two independent limits are 25 ppb for the sum of PFHxA and salts, and 1,000 ppb for PFHxA-related substances, measured in homogeneous material. A concentration equal to the limit is restricted. Products genuinely placed on the EU market before 10 October 2026 are expressly exempt from the provision that took effect on that date. This guide explains how to document both analysis and stock history.
Which clothes and shoes are covered from 10 October 2026?
The 2026 rules cover textiles, leather, fur and hides in consumer clothing and related accessories, and footwear for the general public. Separate categories include consumer mixtures, cosmetics, and food-contact paper and cardboard. Other consumer textiles such as carpets or curtains come under a separate entry 79 rule from 10 October 2027. Verify classification and intended market: do not apply the 2027 date to shoes that were already within the 2026 category.
25 ppb, 1,000 ppb and homogeneous materials
The sum of PFHxA and salts and the sum of PFHxA-related substances are different analytical groups. Related substances include compounds that can degrade or transform to PFHxA. A homogeneous material can be a membrane, coating, woven textile or another component rather than the total weight of a jacket. A generic total-fluorine screening or a 'PFAS free' claim does not automatically establish the values required by entry 79.
| Analysis | Legal criterion | Evidence |
|---|---|---|
| PFHxA and salts | Restricted at ≥25 ppb (≥25 µg/kg) | Exact analytes, summed result, homogeneous component, test method, units and quantification limit |
| PFHxA-related substances | Restricted at ≥1,000 ppb (≥1,000 µg/kg) | Included related compounds, sum method and linkage to the sample component |
| Generic 'PFAS-free' statement | Not automatically proof of either legal sum | Underlying test data, analyte list, batch and colour/SKU traceability |
| Exactly 25 or 1,000 ppb | A value equal to the threshold is within the prohibition | Review rounding and uncertainty; do not automatically release the lot |
The exception for stock placed on the EU market before October 2026
Entry 79 paragraph 7 expressly excludes articles and mixtures already placed on the EU market before 10 October 2026 from paragraph 1. Purchase, manufacturing or warehousing dates alone do not necessarily prove first placement on the Union market. Link the first actual marketing event to the precise article version and batch. This exception itself does not impose a separate universal last sell-through date for such previously placed goods; assess any other applicable chemical rules. Paragraph 8 provides a separate pre-10 October 2027 exception for other consumer textiles under paragraph 2.
| Stock case | Question | Control |
|---|---|---|
| Jackets ordered before 10 October 2026 | When were these particular articles first placed on the EU market? | Request dated supply-chain evidence linked to batch and revision |
| Shoes first marketed in the EU after 10 October | Are both substance sums below their thresholds in each relevant homogeneous material? | Check laboratory results; block release if required evidence is missing |
| New colour or water-repellent finish | Is the material version still the same as the tested product? | Request batch-specific testing or a justified equivalence assessment |
| Curtains and other non-clothing textiles | Does paragraph 2 and the 10 October 2027 start apply? | Use a separate timeline; do not import the 2026 footwear rule |
Are protective work clothes exempt?
Entry 79 paragraph 3 has narrowly specified exemptions for certain category III personal protective equipment hazards, medical devices, in-vitro diagnostic devices and construction textiles. The term 'workwear', a professional customer or business-to-business sales alone do not establish the personal-protection exception. Keep the genuine product classification and applicable risk-category evidence.
Three practical cases for textile businesses
Rain jacket with a membrane and multiple coatings
A laboratory tested only the outer fabric, while a separate membrane or finish may also be relevant. Determine whether all legally relevant homogeneous components were assessed. One passing sample does not automatically validate the entire garment.
Shoe with a measured 25 ppb
A shoe to be first placed on the EU market after 10 October 2026 shows exactly 25 ppb PFHxA plus salts in a relevant homogeneous material. The legal text prohibits concentrations equal to or greater than 25 ppb. Review rounding, method and uncertainty rather than accepting the incorrect 'not over 25' rationale.
Documented old stock held by a Swedish wholesaler
The same article batch can be proven to have been first placed on the EU market on 2 October 2026 and is sold again in November. If paragraph 7 applies, paragraph 1 does not apply to these goods. Retain evidence and separately review other PFAS/POPs legislation.
Seven steps to assess test reports and stock
- Inventory SKU, model, colour, supplier, materials, treatments, versions and batches.
- Classify consumer clothing or footwear for 2026, other textiles for 2027, and any precisely defined exemption.
- Document the real first EU market-placement event and assess paragraph 7 or 8.
- Request lab reports covering the relevant homogeneous components, analytes, both sums, methods and LOQ.
- Compare values against ≥25 and ≥1,000 ppb; do not approve automatically at the limit.
- Record a justified stock hold or authorised decision, with traceable evidence references.
- Reassess when coating, material, supplier, test method, colour or legal provisions change.
Frequently asked questions about PFHxA
Can clothing bought before 10 October 2026 still be sold?
The purchase date by itself is insufficient. Paragraph 7 concerns goods that were genuinely placed on the EU market before the specified date; preserve the market-placement records.
Does the 2027 date also apply to shoes?
No. Consumer shoes and clothing fall under paragraph 1 from 10 October 2026. Paragraph 2 covers other consumer textiles from 10 October 2027.
Is exactly 25 ppb permitted?
No. Within the restricted category, a concentration equal to or higher than 25 ppb or 1,000 ppb for the respective group is prohibited; check analytical precision.
Does 'PFAS-free' prove compliance?
Not without examining the analyte list, material sample, method, reporting limits and both legal substance-group sums.
Is all workwear exempt?
No. The personal protective equipment exception applies only to specified category III risks and needs supporting classification evidence.
Optional documentation templates and official sources
PFHxA in clothing and footwear 2026 – supplier reports, 25/1,000 ppb and stock control | Word/PDF/Excel. The optional digital template pack supports supplier requests, laboratory report checks, deviations and stock registers. It neither performs laboratory testing nor issues legal release certificates. You can use this guide without buying it.
- EU 2024/2462 – REACH Annex XVII entry 79
- Swedish Chemicals Agency – PFHxA guidance
- European Commission – REACH restrictions
- REACH Regulation (EC) 1907/2006
- ECHA – restricted substances
Editorial legal review: 12 November 2026. General information, not a laboratory result, independent lawyer certification or product-specific authority decision.
