KontorBund — Note
The PFHxA limits from 10 October 2026Last checked 7 October 2026
kontorbund.com/notes/eu-pfhxa-restriction.html
The PFHxA limits from 10 October 2026: clothing, footwear, cosmetics and food packaging
The short version
From 10 October 2026 the REACH restriction on PFHxA, its salts and PFHxA-related substances reaches ordinary goods: clothing and related accessories in textiles, leather, furs and hides for the general public, footwear for the general public, paper and cardboard used as food-contact materials, mixtures for the general public and cosmetic products. At or above 25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material, they may not be placed on the market or used. The instrument is Commission Regulation (EU) 2024/2462 — entry 79 of Annex XVII to REACH — and not a general PFAS ban, which has not been adopted. Firefighting foams have applied since 10 April 2026, the rest of the textiles tranche follows on 10 October 2027 and civil-aviation foams on 10 October 2029. Articles and mixtures placed on the market before 10 October 2026 are carved out, so stock already in the Union is not the problem. The date is.
The entry that applies from 10 October 2026
The briefing we worked from described the measure only as "a new European regulation under a REACH-style PFAS restriction" and gave no number. It has one. Commission Regulation (EU) 2024/2462 of 19 September 2024, published in the Official Journal on 20 September 2024, amends Annex XVII to Regulation (EC) No 1907/2006 — REACH — as regards undecafluorohexanoic acid (PFHxA), its salts and PFHxA-related substances, and it does so by adding a single new entry: entry 79. The Regulation entered into force on the twentieth day after publication, which is 10 October 2024. The earliest date on which anything in the entry bites is 10 April 2026.
That is why "from 10 October" and "in force since April" are both defensible sentences about the same instrument, two years apart — and why the year matters in every one of them.
Entry 79, paragraph 1 — the limb that starts on 10 October 2026
"Shall not, from 10 October 2026 be placed on the market, or used, in a concentration equal to or greater than 25 ppb for the sum of PFHxA and its salts, or 1 000 ppb for the sum of PFHxA-related substances, measured in homogeneous material, in the following: (a) textiles, leather, furs and hides in clothing and related accessories for the general public; (b) footwear for the general public; (c) paper and cardboard used as food contact materials within the scope of Regulation (EC) No 1935/2004; (d) mixtures for the general public; (e) cosmetic products as defined in Article 2(1), point (a), of Regulation (EC) No 1223/2009."
- Two numbers, not one —
25 ppband1 000 ppb - 25 ppb is the sum of PFHxA and its salts. 1 000 ppb is the sum of PFHxA-related substances — a second, forty-times-higher bar for the substances that can turn into PFHxA. Both are written as "equal to or greater than", so the limit value itself is already too much.
Measured in homogeneous material- The words appear in paragraphs 1 and 2, the ones covering garments, footwear, food-contact paper and board, mixtures and cosmetics. They do not appear in paragraphs 4 and 5, which cover firefighting foams. That is a difference in how a sample is taken, and it is worth knowing before you compare two laboratory reports.
- Two verbs — placed on the market, or used
- The entry restricts placing on the market and use, not sale alone, and REACH's
Art. 67(1)frames every Annex XVII restriction the same way: no manufacture, placing on the market or use unless the conditions of the restriction are met. For a reseller, the first verb is the one that matters; see below. - What "PFHxA-related substances" means
- Paragraph 9: substances that, "based on their molecular structure, are considered to have the potential to degrade or be transformed to PFHxA". So the 1 000 ppb bar is not a list of named chemicals — and the substance definition itself is structural: a substance with a linear or branched perfluoropentyl group
C5F11-directly attached to another carbon atom, or a perfluorohexyl groupC6F13-. - Three exclusions from the definition
C6F14;C6F13-C(=O)OH,C6F13-C(=O)O-X′andC6F13-CF2-X′; and any substance with aC6F13-group attached directly to an oxygen atom at a non-terminal carbon. The last one is in the entry because it cannot degrade to PFHxA, as recital 23 records.- "Cosmetic products" and "food-contact materials" are borrowed definitions
- Cosmetics are read from Regulation (EC) No 1223/2009, Article 2(1), point (a). The paper and cardboard limb is limited to food-contact materials within the scope of Regulation (EC) No 1935/2004 — so the question "is this in food-contact scope at all" is asked first, and it is asked in another regulation's terms.
- The entry also excludes a group already banned elsewhere
- Paragraph 6: substances with a
C6F13-group attached directly to a sulphur atom that are prohibited in Annex I to the POPs Regulation (EU) 2019/1021 are outside paragraphs 1, 2, 4 and 5. That is PFHxS territory, already covered by a different instrument.
The staged dates, one by one
Five dates carry this restriction, and three of them are in the future from today's 7 October 2026. The Regulation's own recital 24 explains the staging as transition periods counted from entry into force: 18 months for the training, testing and public-service foams; 24 months for the goods in paragraph 1; 36 months for the rest of the textiles; and 5 years for civil-aviation foams. Our arithmetic from 10 October 2024 lands exactly on the dates in the entry.
| Date | What it covers | Where |
|---|---|---|
| 10 October 2024 | The Regulation entered into force — the twentieth day after publication on 20 September 2024. No product obligation starts here | Art. 2 |
| 10 April 2026 | Firefighting foams and concentrates for training and testing (except functional testing of the systems with all releases contained) and for public fire services (except where those services intervene at industrial fires at establishments covered by Directive 2012/18/EU and use the foams and equipment only for that) | para. 4 |
| 10 October 2026 | Clothing and related accessories in textiles, leather, furs and hides for the general public; footwear for the general public; paper and cardboard used as food-contact materials; mixtures for the general public; cosmetic products | para. 1 |
| 10 October 2027 | Textiles, leather, furs and hides other than in clothing and related accessories, for the general public — the tranche the recitals illustrate with carpets, rugs, curtains, blinds, upholstery, textile wall covers, tablecloths and bed linen | para. 2 |
| 10 October 2029 | Firefighting foams and concentrates for civil aviation, including in civilian airports | para. 5 |
What the entry names — and what the reporting adds
The report we worked from listed waterproof and outdoor clothing and footwear, cosmetics, treated leather and fur, carpets, upholstery and furniture, impregnating and polishing preparations, and food-contact packaging such as grease-proof wrappers. Some of that is the entry's own language, some is the recitals' illustrations, and some of it the text does not say. The line between the three is the useful part.
- In the entry
- Clothing and related accessories in textiles, leather, furs and hides for the general public; footwear for the general public; paper and cardboard as food-contact materials; mixtures for the general public; cosmetic products. Those five limbs are the whole of paragraph 1.
- In the recitals, as illustration
- Recital 15 gives "outdoor clothing like rain jackets" for the clothing limb and "handbags" for accessories, and names footwear. Recital 17 names the 2027 tranche's product types: carpets, rugs, curtains, blinds, upholstery, textile wall covers and other textile-based coverings such as tablecloths or bed linen — in transport, public places and offices included. These are the Commission's examples, not an exhaustive list, and they sit in recitals rather than in the operative text.
- Not in the text
- "Impregnating and polishing preparations" appears nowhere in the Regulation we read. The limb that would catch them is "mixtures for the general public" — a spray or a polish sold to consumers is a mixture, and that is the sentence to argue from. Furniture is not named either; the recitals say upholstery, and they say it about the 2027 tranche.
- The four article exemptions
- Paragraph 3 takes four groups of articles out of paragraphs 1 and 2 entirely: personal protective equipment intended to protect users against risks within risk category III, points (a), (c) to (f), (h) and (l) of Annex I to Regulation (EU) 2016/425; devices within the scope of Regulation (EU) 2017/745; devices within the scope of Regulation (EU) 2017/746; and textiles used as construction textiles — recital 18 gives membranes, reinforcement fabric, façade substructures, insulation and roofing systems as examples. These are exemptions, not delays: there is no date on them at all.
- Who "the general public" excludes
- The clothing and footwear limbs say for the general public, and so does the 2027 textiles limb. Read with paragraph 3, the restriction is aimed at what a consumer can buy, with the listed professional and medical articles outside it. If someone tells you the restriction covers workwear, ask which limb and which exemption they have read.
Does this reach my shop?
Entry 79 does not name a seller. It names three verbs — through
Art. 67(1) of REACH, manufacture, placing on the market
and use — and uses two of them. Who that is in your supply chain is
answered by REACH's own definitions, and the difference between buying inside
the Union and importing yourself is the whole of it.
- REACH defines the phrase for itself
Art. 3, point(12): "placing on the market: means supplying or making available, whether in return for payment or free of charge, to a third party. Import shall be deemed to be placing on the market." Point(11)makes the importer the natural or legal person established in the Union who is responsible for the import, and point(14)defines a distributor as someone who only stores and places on the market for third parties — "including a retailer".- You import the goods yourself
- The last sentence of point (12) disposes of the question: import is deemed to be placing on the market. If you buy clothing, footwear or greaseproof wrappers from outside the Union and bring them in, the placing on the market is yours, and 10 October 2026 is the date that attaches to it. Your supplier's own compliance paperwork does not move that verb onto them.
- You buy from a supplier inside the EU
- The goods already have a first placing on the Union market behind them, and entry 79's paragraph 7 is written on that event: articles and mixtures placed on the market before 10 October 2026 are outside paragraph 1. What paragraph 7 does not do is date the event for you — this is the point to take to your supplier rather than to a blog, because recital 25 ties the protection to a supplier who "can demonstrate" the earlier placing on the market.
- The case the text does not decide
- Point (12) is supply-based, while paragraph 7 is date-based, and the entry never says whose date counts. We are not going to pretend that resolves every resale in a retail chain. Two readings are visible on the face of the documents, no official guidance on this entry has been published that we could read, and the honest answer for a shop in the middle of a chain is: hold the evidence of when the goods were first placed on the market, and ask a lawyer about your own facts. This page is not legal advice.
- Your supplier's own first placing may be after 10 October 2026
- Then the goods are inside paragraph 1 whoever is holding them, and the date you bought them changes nothing. That is why the useful question to a supplier is not "are these PFAS-free" but "when were these articles first placed on the EU market, and can you show it?"
Stock already placed on the market
The paragraph that saves most small shops a stocktake is short enough to read in full, and the Regulation gives its reason.
Entry 79, paragraphs 7 and 8
"7. By way of derogation from paragraph 1, that paragraph shall not apply to articles and mixtures which were placed on the market before 10 October 2026." … "8. By way of derogation from paragraph 2, that paragraph shall not apply to articles which were placed on the market before 10 October 2027."
- Why the derogation exists
- Recital 25 says it in one line: the restriction "should not apply to articles and mixtures for which the supplier can demonstrate that such articles and mixtures were placed on the market prior to the respective date of application of the restriction, for practicality and enforceability reasons".
- It is the supplier who demonstrates, not you who argues
- The recital's condition is evidence, held by the party that did the placing. Practically: keep invoice, delivery and batch dates for stock you bought before 10 October 2026, so that the date is a document rather than a memory.
- Nothing in the entry asks anyone to destroy anything
- We found no recall, withdrawal or disposal obligation in entry 79, and no duty aimed at consumers. What the entry restricts is placing on the market and use, from the stated dates. Goods already placed on the market before 10 October 2026 are covered by paragraph 7 rather than by a hope.
- The stock protection does not reach the foams
- Paragraphs 7 and 8 are written "by way of derogation from paragraph 1" and "from paragraph 2". Paragraph 4, the foam ban that has applied since 10 April 2026, and paragraph 5 on civil aviation carry no equivalent sentence. We would not read the two derogations across to them.
No general PFAS ban — and a second rule for food packaging
The headline that travels furthest is the wrong one: this is not "the PFAS ban". It is a targeted restriction on one subgroup, and the Commission said so while adopting it.
- What the recitals say about the rest
- Recital 21: the uses of PFHxA, its salts and PFHxA-related substances "not covered by this targeted restriction, are also included in two other pending restriction dossiers, notably PFAS in firefighting foams and PFAS in all other uses", and the Commission "will further consider the need to restrict those uses based on the justification and information provided in those dossiers and the related opinions". Recital 19 records that the firefighting-foam dossier was submitted on 14 January 2022 — which is why the Commission restricted the foam uses where alternatives exist now, and left the rest to that dossier.
- So: no blanket ban
- No general PFAS ban has been adopted in the instruments we read. What exists is entry 79, with product limbs, concentration limits and dates. Whether the two pending dossiers had produced anything by October 2026 we did not verify for this note, and we say so in what we could not establish.
- The second rule already applies to food packaging
Art. 5(5)of the PPWR — Regulation (EU) 2025/40 — has applied since 12 August 2026 and limits PFAS in food-contact packaging at 25 ppb for any PFAS, 250 ppb for the sum of PFAS and 50 ppm including polymeric PFAS, with a duty to split PFAS fluorine from non-PFAS fluorine once total fluorine exceeds 50 mg/kg. That is a different instrument, different numbers and a different definition of the substance group. Our note on it sets out the paragraph in full.- One wrapper, two regimes
- A greaseproof paper wrapper sold to a consumer is inside entry 79's paragraph 1(c) as paper used as a food-contact material, and it is food-contact packaging under
Art. 5(5)of the PPWR at the same time — PFHxA limits from 10 October 2026, PFAS limits from 12 August 2026. If you sell food in it, both belong on your supplier questionnaire.
What we could not establish
Everything above comes from the two instruments' own text. This is where the reporting and the text part ways, and where the text simply stops.
- We could not read the report itself
- The report we were handed — Noviny.sk, 7 October 2026, itself relayed from Merkur and Netzwelt — came with no article address, and we did not find the article. Nothing on this page is sourced to it. Two of its claims we can check against the Regulation, and both hold: the 10 October date for consumer goods, and a firefighting-foam ban applying since April.
- The instrument the report does not name
- The briefing described "a new European regulation under a REACH-style PFAS restriction" and gave neither a number nor a paragraph. It is Commission Regulation (EU) 2024/2462, entry 79 of Annex XVII to REACH, and the limits are in its paragraphs 1, 2, 4 and 5. Nothing about this needed a new instrument: the restriction has existed in the Annex since October 2024.
- The limit values the report omits
- The report gave no numbers at all. The two that apply are 25 ppb for the sum of PFHxA and its salts and 1 000 ppb for the sum of PFHxA-related substances — not a single threshold, and not the same as the PPWR's 25 ppb / 250 ppb / 50 ppm for food-contact packaging.
- "Since April" has a year — and it is 2026
- The reporting left the year open. Paragraph 4 applies from 10 April 2026, and it is the earliest application date in the entry. Before that, there was no PFHxA product restriction at all, only a Regulation in force since 10 October 2024.
- "Professional protective clothing from 10 October 2027" does not match the text
- The briefing's staged-dates list put professional protective clothing in the 2027 tranche. The entry reads differently in both directions: PPE within risk category III, points (a), (c) to (f), (h) and (l) of Annex I to Regulation (EU) 2016/425 is exempt outright by paragraph 3(a), with no date at all; and the thing that starts on 10 October 2027 is paragraph 2's textiles, leather, furs and hides other than clothing and related accessories, for the general public — the carpets-and-upholstery group, not workwear.
- The product list in the reporting is partly the recitals, partly the category
- Waterproof and outdoor clothing, handbags and footwear are the recitals' own examples (recitals 15 and 17). "Impregnating and polishing preparations" and "furniture" are not in the Regulation's words: the operand is mixtures for the general public, and the furniture-adjacent word the recitals use is upholstery — in the 2027 tranche. We are not going to present either as a named product in the entry.
- The substitutes named in the reporting
- Polyurethane-, wax- or silicone-based textile finishes; water dispersions, PLA biopolymer or mechanical calendering for food packaging; natural waxes or minerals in cosmetics — none of those appear in the Regulation we read. The recitals say only that "alternatives for water repellent properties appear to be available" (recital 17) and record that alternatives were on the market for the foam uses restricted first. Treat the substitute list as reporting, not as text.
- Who is the placer, in your chain
- We can quote the definitions, and we do above, but entry 79 never says whose placing-on-the-market date the derogation in paragraph 7 turns on. That is the one place on this page where our answer is a question for your supplier — and, if the sums are large, for a lawyer.
- How a laboratory will measure it
- The entry fixes "measured in homogeneous material" for the goods in paragraphs 1 and 2 and names no analytical method. We did not find an official method reference for these matrices, and we cannot tell you how a laboratory will draw the "homogeneous material" line through a coated jacket, a laminated shoe or a greaseproof wrapper. Two reports on the same product can differ for that reason alone.
Known traps
"PFAS are banned in clothing from 10 October"
One subgroup, PFHxA and its relatives, against two concentration limits — and only for the limbs in paragraph 1 and only for the general public. The general PFAS restriction is a proposal in a dossier, not an adopted ban, and the Regulation says so in recital 21.
"My carpets and upholstery are caught in October"
They are paragraph 2 goods: 10 October 2027, on 36 months of transition rather than 24. Reading the two dates as one is the most common mistake in the coverage we saw.
"Professional protective clothing gets until 2027"
PPE in the listed risk category III points is exempt by paragraph 3(a), with no date on it. A transition period and an exemption are different things; 2027 is the date for the general public's other textiles, not for workwear.
"I bought it before 10 October, so it's fine"
Paragraph 7 is written on the goods being placed on the market before that date, not on your purchase order, and recital 25 puts the proof on the supplier. If your supplier imported the goods in November, your early purchase changes nothing.
"The limit is 25 ppb of PFHxA"
Two sums: 25 ppb for PFHxA and its salts, 1 000 ppb for PFHxA-related substances, both "equal to or greater than" and both measured in homogeneous material. A single substance result answers neither sum.
"It's only about textiles"
Paragraph 1 also covers footwear, paper and cardboard used as food-contact materials, mixtures for the general public and cosmetics. A shop that sells candles, a polish and a lip balm has three different limbs to think about, not one.
"Food packaging is one rule now"
Two rules, two dates, two definitions of the substance group: PPWR Art. 5(5) on PFAS in food-contact packaging since 12 August 2026, and entry 79 on PFHxA in paper and cardboard food-contact materials from 10 October 2026.
"Someone must have published guidance for small sellers by now"
We looked for guidance on this entry for the placer question and did not find any we could read. Where there is no official reading, the safe move is the dated document — before the date, not after it.
Sources
Two legal texts do all the work here, and we name the passage each claim comes from rather than citing either as a lump.
-
Commission Regulation (EU) 2024/2462 of 19 September 2024 (OJ L, 2024/2462, 20.9.2024) — EUR-Lex, English text Official, and the source of every date and number on this page. Read in full for this note: recital 15 for the exemplification of clothing and accessories with rain jackets and handbags, recital 17 for the 2027 product types and the water-repellent point, recital 18 for the exemptions, recital 19 for the firefighting-foam dossier of 14 January 2022, recital 21 for the two pending dossiers and the absence of a general PFAS ban, recital 24 for the 18-, 24-, 36-month and 5-year transitions, recital 25 for the stock derogation and its evidential condition; Article 2 for entry into force on the twentieth day after publication; and the Annex, entry 79, paragraphs 1 to 9, quoted or paraphrased throughout
-
Regulation (EC) No 1907/2006 (REACH) — EUR-Lex, consolidated text as in force 22 June 2026 Official. Source for
Art. 3, point(11)(importer), point(12)(placing on the market, and import deemed to be placing on the market), point(13)(downstream user) and point(14)(distributor, including a retailer), and forArt. 67(1)on restrictions applying to manufacture, placing on the market and use. We also used this consolidated text to confirm that entry 79 stands unchanged in the Annex as of that date -
Regulation (EU) 2025/40 (PPWR) — EUR-Lex, English text (OJ L, 2025/40, 22.1.2025) Official. Read here for
Art. 5(5)— the PFAS limits for food-contact packaging applying from 12 August 2026 and the 50 mg/kg total-fluorine duty — which is the second regime that reaches the same wrapper. The full treatment is in our note on Article 5(5) -
Noviny.sk — report on the PFHxA limits, 7 October 2026, relayed from Merkur and Netzwelt Secondary, and the report that prompted this note. We could not read it — no article address was supplied and we did not find the article, so nothing on this page is sourced to it. Its 10 October date for the consumer goods and its April date for firefighting foams match entry 79; its product list, its missing instrument number, its missing limit values and its placement of professional protective clothing in 2027 do not match the text as we read it
Help us keep this page honest
The most useful thing anyone could send us is a real supplier document — a declaration of when a garment or a wrapper was first placed on the EU market, or a PFHxA laboratory report with the method named on it and the price you were quoted. If a market surveillance authority has already asked you for one of these two numbers, we would rather report that than the text of the paragraph.