From 1 January 2026, France will enforce new restrictions on PFAS (per- and polyfluoroalkyl substances), with direct impact on textiles/apparel, footwear, and cosmetics, as well as ski waxes and waterproofing agents for consumer products. The framework stems from Law No. 2025-188 of 27 February 2025 and is made fully enforceable by Decree No. 2025-1376 of 28 December 2025, which sets measurable thresholds, exemptions and stock-management rules.
What is prohibited (and who is concerned)
From 1 January 2026, France prohibits the manufacture, import, export and placing on the market (including free supply) of:
cosmetic products containing PFAS;
ski waxes containing PFAS;
apparel textiles, footwear, and waterproofing agents for apparel and footwear intended for consumers that contain PFAS, with exemptions for products intended for protection and safety (PPE and specific dedicated equipment).
In addition, the law provides that from 1 January 2030 the ban will extend to all textile products, with specific exemptions for essential uses, national sovereignty needs and industrial technical textiles, to be defined by decree.
The decree translates the ban into measurable compliance thresholds
The key element of the decree is the introduction of a “valeur résiduelle” (residual value) above which the prohibitions apply. In practice, it is not sufficient to state “PFAS yes/no”: operators must verify whether levels exceed defined thresholds, using different analytical approaches.
1) 25 ppb per individual PFAS (target analysis; polymers excluded). For each PFAS measured by targeted (compound-specific) analysis, excluding polymers, the limit is 25 ppb.
2) 250 ppb for the sum of PFAS (target + potential precursor degradation; polymers excluded) For the sum of PFAS, calculated as the sum of target analyses and, where applicable, including a prior degradation step for precursors, excluding polymers, the limit is 250 ppb.
3) 50 ppm including polymers (total fluorine approach). For PFAS including polymers, the limit is 50 ppm. The decree adds a highly relevant operational requirement: if total fluorine exceeds 50 mg F/kg, the operator (manufacturer/importer/exporter/placer on the market) must be able, upon request by the authorities, to provide evidence showing whether the fluorine originates from PFAS or non-PFAS substances.
Timeline and stock management: a 12-month sell-through window
The provisions apply from 1 January 2026. However, products covered by the ban that were manufactured before 1 January 2026 may still be placed on the market or exported for up to 12 months (after which placing on the market/export becomes prohibited).
Exemptions and post-consumer recycled content: the 20% case
The decree clarifies the main exemptions applicable in 2026 (PPE and dedicated equipment) and introduces an important circularity provision: apparel textiles and footwear incorporating at least 20% post-consumer recycled material may fall under an exemption regime in which PFAS presence in the final product is limited to the recycled fraction, and the admissible residual amount is proportional to the percentage of recycled content incorporated.
Operational supply-chain implications
For companies exporting to France or manufacturing for the French market, PFAS compliance becomes a market-access requirement that calls for a structured approach:
mapping high-risk materials/finishes (DWR, coatings, membranes, waterproofing treatments, accessory components);
designing a testing plan aligned with the decree’s three approaches (target, sum with precursors, total fluorine/polymers);
managing stock and ensuring traceability of manufacturing dates (pre-2026 vs post-2026);
preparing a technical file to handle borderline cases (e.g., total fluorine > 50 mg F/kg) and potential exemptions (PPE, recycled content share).
How to set up a PFAS compliance plan for the French market
If you sell or export to France (fashion, footwear, consumer PPE, cosmetics) and want to reduce the risk of non-compliance, market blocks or recalls, we can support you with:
defining a PFAS verification plan aligned with French thresholds,
laboratory testing and technical interpretation of results,
regulatory support and the development of a documentation package for the supply chain and inspections.
Contact us for a rapid review of your France-bound products and to implement an effective PFAS compliance plan for 2026.