PFAS-Free Apparel for the EU: The PFHxA Restriction on Clothing

The PFHxA restriction is narrower than the phrase "PFAS-free" suggests and stricter than many buyers assume. It covers one group of PFAS, PFHxA, its salts and substances that can degrade to it, and its limits are set in parts per billion. What counts is what a laboratory finds in each material of the garment, not what the finish was called on the mill's data sheet.

Check the product scope, market and application dates against the current legal text. Confirm project-specific obligations with a qualified adviser.

What the PFHxA restriction covers

The instrument is Commission Regulation (EU) 2024/2462 of 19 September 2024, which adds entry 79 to Annex XVII of REACH, Regulation (EC) No 1907/2006. It was published in the Official Journal on 20 September 2024 and entered into force on the twentieth day after publication, 10 October 2024. Its obligations then apply in stages, and the first stage that reaches clothing starts on 10 October 2026.

The substance group is defined by structure. Entry 79 covers PFHxA, its salts, and substances with a linear or branched perfluoropentyl group (C5F11-) directly attached to another carbon atom or a perfluorohexyl group (C6F13-), with listed exclusions. Paragraph 9 defines PFHxA-related substances as those that, based on their molecular structure, are considered to have the potential to degrade or be transformed to PFHxA.

Which products and which dates

The Regulation's recitals give outdoor clothing such as rain jackets, and accessories such as handbags, as examples of the clothing scope. For the later textile scope they name carpets, rugs, curtains, blinds, upholstery, textile wall coverings, tablecloths and bed linen.

What is outside the restriction

Paragraph 3 excludes personal protective equipment within risk category III, points (a), (c) to (f), (h) and (l) of Annex I to Regulation (EU) 2016/425, medical devices under Regulations (EU) 2017/745 and 2017/746, and construction textiles. Paragraph 7 excludes articles placed on the market before 10 October 2026. Both clothing paragraphs are limited to products "for the general public"; whether a particular programme falls outside that phrase is a legal question for the brand, and this guide does not answer it.

Who the rule binds and when a shipment is caught

The rule binds whoever places the garment on the EU market, and import counts. Article 3(12) of REACH defines placing on the market as supplying or making available to a third party, and states that import shall be deemed to be placing on the market. A garment made in Türkiye is therefore placed on the EU market when it is imported, and the EU importer carries the obligation.

For a production run the date that matters is the date the goods enter the EU, not the date they were sewn or ordered. Bulk production takes 4 to 5 weeks after sample approval, with transport on top, so an order approved in early September 2026 lands after the limit applies. Treat any order that will enter the EU on or after 10 October 2026 as caught.

Other PFAS limits that already apply to textiles

PFHxA is the third PFAS group with an EU limit relevant to textiles. The two earlier ones are already in force, so a test report that covers only PFHxA leaves gaps.

A broader restriction covering PFAS as a group was submitted to the European Chemicals Agency on 13 January 2023 by authorities in Denmark, Germany, the Netherlands, Norway and Sweden. It is still being evaluated by the Agency's scientific committees and has not been adopted. The Regulation adding entry 79 notes this pending dossier in its recitals.

France: a wider national ban

France bans PFAS in consumer clothing under national law. Article 1 of Law No. 2025-188 of 27 February 2025 prohibits, from 1 January 2026, the manufacture, import, export and placing on the market of clothing textile products, footwear and waterproofing agents for them intended for consumers and containing PFAS. Clothing and footwear designed for the protection and safety of people are excepted, and the ban extends to textile products generally from 1 January 2030, with further exceptions.

Decree No. 2025-1376 of 28 December 2025 sets the residual values below which the ban does not apply: 25 ppb for any single PFAS measured by targeted analysis, excluding polymers; 250 ppb for the sum of targeted PFAS, excluding polymers; and 50 ppm for PFAS including polymers. Products manufactured before 1 January 2026 may be placed on the market for up to twelve months after that date. A range sold in France needs these values in the order as well as the EU limits.

What evidence to ask a supplier for

Ask for a laboratory test report for each homogeneous material, with reporting limits below the legal limits, and a written declaration of the finish chemistry. A declaration alone describes what the supplier believes it bought; only a test at the right reporting limit shows what is in the material.

• One result per material, not per garment. The limit is measured in homogeneous material, so a shell fabric, a coated lining, a laminated trim and a printed area are separate test points. A report on "the jacket" does not show which material was tested.
• Reporting limits below the legal limits. "Not detected" means something only if the method's reporting limit is below 25 ppb for PFHxA and its salts, and low enough for the related substances to be summed against 1,000 ppb. Ask the laboratory to print the limits on the report.
• All three PFAS entries in one report. Ask for PFOA and C9-C14 PFCAs to be covered alongside PFHxA, because their limits already apply.
• A traceable sample. The report should name the roll, lot or batch and say who drew the sample. How to read an apparel chemical test report covers scope, accreditation and sample description.
• A declaration of the repellent finish. A statement from the fabric mill or finisher naming any water-, oil- or stain-repellent chemistry applied, or confirming that none was applied, with the chemical supplier's safety data sheet where a finish was used.
• Change control. A written commitment that the mill, finish, trim supplier or chemical supplier will not change for the style without notice, because a compliant first order says nothing about a reorder from a different lot.

How these limits sit alongside a brand's restricted substances list is covered in RSL and MRSL and in the overview of REACH restricted substances for apparel.

Order wording examples

Put the requirement in the purchase order or the product specification, not in an email thread. The lines below are examples of buyer wording to adapt with the brand's own adviser; they are not Voyager terms. Where they sit in the order is covered in the apparel purchase order guide.

• Legal limit. "All materials and components shall comply with REACH Annex XVII entry 79 (Commission Regulation (EU) 2024/2462): below 25 ppb for the sum of PFHxA and its salts and below 1,000 ppb for the sum of PFHxA-related substances, measured in each homogeneous material."
• Existing limits. "Materials shall also comply with the limits for PFOA under Regulation (EU) 2019/1021 and for C9-C14 PFCAs under REACH Annex XVII entry 68."
• No intentional use. "No per- and polyfluoroalkyl substances shall be intentionally used in any fabric finish, coating, membrane, print, trim or label for this style."
• Evidence before shipment. "Supplier shall provide, before shipment, a test report per homogeneous material from [named laboratory], stating reporting limits below the limits above, and a declaration of the repellent finish applied or of its absence."
• Change control. "Supplier shall notify Buyer in writing before any change of fabric mill, finish, trim supplier or chemical supplier for this style."
• France. "For goods placed on the market in France, materials shall not exceed the residual values set by Decree No. 2025-1376."

Where water repellency is part of the product, state the performance you need and expect it to be met with non-fluorinated chemistry. The balance between repellency and the chemical limits is agreed per project at the quotation stage. How a "PFAS-free" statement may be worded on the consumer-facing product is a separate question, covered in environmental claims on apparel.

Where Voyager stands

Voyager Textile makes garments to the buyer's specification and makes no PFAS-free claim beyond what that specification sets. Which materials and finishes the order uses, which tests it includes and which components they cover are confirmed per project at the quotation stage. Certified materials can be sourced where specified; that does not make Voyager or the garment certified.