Footwear Regulatory Updates 2026: Compliance Timelines Brands Must Know

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First published: March 2026

Fulfilling footwear compliance requirements in 2026 means addressing additional elements, including more restricted substances, higher sustainability duties, greater traceability expectations, and heightened due diligence for natural materials.

With major deadlines landing across the EU, UK, US, and China, from PFAS restrictions and packaging requirements to EUDR readiness, eco-design obligations, and evolving footwear testing standards, brands need a clear understanding of the latest footwear regulations.

This article maps the most important footwear regulatory updates in 2026 and timelines, explains their practical implications for product development and sourcing, and shows how an expert footwear testing lab can help mitigate non-compliance risk while protecting market access and brand reputation.

If you are looking for footwear testing services, please contact us here directly.

Understanding the footwear regulatory landscape in 2026

Footwear regulation in 2026 converges around four pressure points:

Chemical safety and restricted substances across materials, finishes and components
Sustainability obligations, including eco-design and extended producer responsibility
Traceability, product safety and footwear labelling for physical and online sales
Heightened due-diligence expectations for materials such as leather and natural rubber entering the EU

Timelines for the 2026 major footwear regulatory requirements in the EU, UK, US, and China

January 2026: PFAS ban in France (textiles and footwear)
1 July 2026: PFAS ban in Denmark (clothing and footwear)
1 July 2026: California SB 707 PRO membership deadline (textile EPR including footwear)
19 July 2026: EU bans on destruction of unsold footwear (large companies, ESPR)
12 August 2026: EU PPWR general application date
October 2026: Third-party environmental scoring permitted in France
13 October 2026: US EPA TSCA Section 8(a)(7) PFAS reporting deadline
1 December 2026: End of transition period for China's general safety requirements for footwear standards GB 25038-2024
30 December 2026: EUDR application for large and medium operators

Contact us today to ensure your footwear products comply with regulations.

Key footwear regulations in the European Union

EU footwear regulations in 2026 continue to rely on a long‑standing framework covering labelling, product safety, chemical restrictions, circular economy and PPE (safety footwear) requirements. These obligations apply to all footwear placed on the EU market, whether manufactured within or imported into the EU.

Ecodesign for Sustainable Products Regulation (ESPR)

The Regulation (EU) 2024/1781 establishes a framework to set ecodesign requirements for products placed on the EU market, with the objective of making sustainable products the norm and improving circularity, durability, energy and resource efficiency, and overall environmental performance across product life cycles. Under the ESPR, the destruction of unsold textiles and footwear is directly regulated by the Regulation itself.

From 19 July 2026, large companies are prohibited from destroying unsold textiles and footwear placed on the EU market. The ban will apply to medium-sized companies from 19 July 2030, while micro and small enterprises are exempt.

In addition, companies subject to the obligation must annually disclose the quantity and weight of unsold products discarded, the reasons for discarding them, and the treatment applied (e.g. recycling, recovery, destruction).

Under the Commission’s first ESPR Working Plan, textiles are prioritised for the development of product-specific ecodesign requirements. Footwear was assessed together with textiles in the preparatory study but is not separately prioritised in the first wave of delegated acts. Nevertheless, the destruction ban applies equally to footwear.

The ESPR also establishes the framework for the Digital Product Passport (DPP). The DPP will become mandatory only once a delegated act sets specific requirements for a given product group. Textiles are expected to be among the first categories subject to DPP requirements. There is currently no fixed legal date for footwear-specific DPP obligations; timing will depend on future delegated acts.

Companies placing textiles or footwear on the EU market should therefore ensure compliance with the upcoming destruction ban, implement internal monitoring systems for mandatory disclosures, and prepare for future product-specific ecodesign and Digital Product Passport requirements.

EU Deforestation Regulation (EUDR)

Effective 30 December 2026 for large and medium operators and traders, and 30 June 2027 for micro and small undertakings, Regulation (EU) 2023/1115 (EU Deforestation Regulation), as amended by Regulation (EU) 2025/2650, requires that relevant products listed in Annex I that are placed on the Union market or exported are deforestation-free, produced in accordance with the relevant legislation of the country of production, and covered by a due diligence statement or, where applicable, a simplified declaration.

The Regulation applies to relevant products that contain, have been fed with, or have been made using the commodities cattle, rubber, and wood, among others. In the context of footwear, regulatory exposure most commonly arises through leather derived from cattle, natural rubber components, and wood-based materials incorporated into finished products. However, only products whose HS codes are explicitly listed in Annex I fall within scope. The presence of leather, rubber, or wood in a footwear product does not automatically trigger applicability unless the specific product code is covered.

Operators placing in-scope products on the Union market or exporting them must demonstrate compliance with Article 3. This requires proving that the relevant commodities were not produced on land subject to deforestation after 31 December 2020 and that they were produced in accordance with the applicable legislation of the country of production. Operators must collect the information specified in Article 9, including geolocation data identifying the plots of land where the commodities were produced.

Prior to placing products on the market or exporting them, operators must exercise due diligence in accordance with Articles 8 to 11. This includes (i) systematic information collection, (ii) a risk assessment tailored to the specific product and supply chain, taking into account the criteria set out in Article 10, and (iii) risk mitigation measures where the risk of non-compliance is more than negligible. A due diligence statement must be submitted through the Commission Information System before the product is placed on the market or exported. Operators must retain all due diligence documentation and records for a minimum of five years.

Laboratory material composition analysis may support internal supply chain verification and validation of declared inputs. However, such testing does not replace the legal requirements for geolocation, legality verification, risk assessment, and formal submission of due diligence statements as mandated by the Regulation.

PFAS restrictions in key European markets

Stricter national bans on PFAS (per- and polyfluoroalkyl substances) in consumer products come into force in 2026, directly affecting water-resistant and stain-resistant footwear.

In France, a ban on the manufacture, import, sale and offering for free of PFAS-containing textiles, clothing and footwear took effect on 1 January 2026. In Denmark, it is prohibited to import or sell clothing and footwear containing PFAS for private consumer use from 1 July 2026. These national measures run ahead of a broader EU-wide PFAS restriction proposal under REACH, which remains under assessment. Brands sourcing water-repellent or stain-resistant treatments should verify supply-chain PFAS status through dedicated footwear chemical testing, including Total Organic Fluorine (TOF) screening and targeted PFAS analysis.

On the other hand, the European Chemicals Agency (ECHA) is progressing with the PFAS restriction proposal. The initiative aims to substantially reduce PFAS emissions and may enter into force between 2026 and 2027, subject to adoption by the European Commission. ECHA’s scientific committees (the Committee for Risk Assessment (RAC) and the Committee for Socio‑Economic Analysis (SEAC)) are currently evaluating the proposal and are expected to issue their final opinions in 2026 following the completion of technical assessments and public consultation procedures.

In parallel, the European Union continues to strengthen PFAS controls through updates to the Persistent Organic Pollutants (POPs) Regulation (Regulation (EU) 2019/1021). Amendments adopted in 2025, particularly those addressing PFOS and PFOA, will apply directly throughout 2026 and further reinforce the regulatory framework governing persistent PFAS substances.

EU Packaging and Packaging Waste Regulation (PPWR)

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and applies from 12 August 2026, subject to specific transitional periods for certain obligations.

From 12 August 2026, packaging placed on the EU market must comply with the general sustainability requirements laid down in the Regulation, including requirements relating to substances in packaging.

The recyclability requirements will apply from 1 January 2030. From that date, packaging must comply with harmonised design-for-recycling criteria and meet at least recyclability performance grades A, B or C. From 1 January 2038, only packaging meeting grades A or B may be placed on the market.

Minimum recycled content requirements for plastic packaging will apply from 1 January 2030 with differentiated thresholds depending on packaging type and format.

The Regulation also introduces packaging minimisation requirements, including obligations to reduce weight and volume to the minimum necessary for functionality. For grouped, transport and e-commerce packaging, the empty space ratio must not exceed 50%, subject to specific conditions.

Footwear brands placing packaging on the EU market, whether through direct-to-consumer sales or via retailers, should assess compliance with design-for-recycling criteria, future recycled content thresholds, packaging minimisation rules (including e-commerce empty space limits), and upcoming harmonised labelling obligations.

Environmental cost for textiles in France

The French government published requirements on the environmental costs of textiles in September 2025. By October 2026, third parties such as NGOs or retailers will be permitted to publish an Environmental Cost based on life-cycle assessments for footwear brands that have not published their own. This mechanism is designed to highlight potential greenwashing and incentivise transparency. If a brand makes any environmental claims, it will be mandatory to display an official Environmental Cost label. Brands selling into France should assess their readiness to produce or respond to third-party environmental scoring, backed by credible footwear product testing data to substantiate claims.

Technical standards for work footwear (EN ISO 20345:2022)

For professional safety footwear, 2026 will see full enforcement of the updated EN ISO 20345:2022, one of the most important footwear testing standards for the European PPE market. The old SRA, SRB and SRC slip-resistance designations are replaced by a single new "SR" marking. Products must be tested against the new slip-resistance requirements and labelled accordingly. Manufacturers of safety and work footwear should ensure that their current product lines are retested and certified under the updated standard by an accredited footwear testing lab before placing goods on the EU market.

Manufacturers must retest products through accredited footwear testing laboratories to maintain certification and market access.

Have questions about addressing EU regulations for footwear? Contact us today, and our team will reply to you shortly.

Key footwear regulations in the United Kingdom

The UK regulatory framework continues to include:

Chemical safety under UK REACH
General product safety rules
Footwear labelling requirements
PPE certification for safety footwear

Businesses selling footwear in both the EU and the UK must account for regulatory differences between the two markets, particularly regarding chemical safety and marketing requirements.

UK REACH divergence and footwear chemical testing

Since Brexit, the UK has maintained its own chemicals regime under UK REACH, which initially mirrored the EU framework but is progressively diverging. The Health and Safety Executive (HSE) has confirmed it will consult on proposals to develop a UK REACH restriction on PFAS, running on a separate timeline from the EU's universal PFAS restriction proposal. Entry 72 of REACH Annex XVII, which restricts 33 CMR substances in clothing, textiles and footwear, continues to apply in the UK via retained EU law.

Footwear brands selling into both the EU and UK markets must now track two evolving restricted-substance regimes and ensure footwear chemical testing programmes cover any divergences in scope, thresholds or timelines.

Product safety and UKCA marking

Footwear sold in Great Britain must comply with general product safety requirements and UK REACH chemical restrictions. For safety and protective footwear, the UKCA (UK Conformity Assessed) marking applies, though the UK government has extended recognition of CE-marked products to reduce compliance costs for manufacturers. Brands should monitor the evolving transition timeline between CE and UKCA acceptance, particularly for PPE-category footwear, and ensure that labelling and technical documentation satisfy UK-specific footwear labelling regulations.

Questions on UK footwear regulations? Contact us now, and our team will be in touch with you shortly.

Key footwear regulations in the United States

State-level PFAS bans

The US does not have a single federal ban on PFAS in footwear, but state-level legislation is moving rapidly.

California's AB 1817, effective 1 January 2025, prohibits the manufacture, distribution or sale of any new textile articles, broadly defined to include footwear, that contain intentionally added PFAS or at or above 100 ppm as measured in total organic fluorine (50 ppm starting in 1 January 2027).

New York enacted a similar ban on PFAS in apparel, also effective from January 2025. Brands selling water-resistant or stain-resistant footwear into these states should already have reformulated or verified PFAS-free status through footwear chemical testing, including TOF screening and targeted analysis.

California SB 707 (textile EPR covering footwear)

California's Responsible Textile Recovery Act (SB 707), signed into law in September 2024, establishes the first extended producer responsibility system for textiles (including footwear) in the US.

Footwear brands must comply with California SB 707 footwear compliance requirements by joining a Producer Responsibility Organisation (PRO) approved by CalRecycle before 1 July 2026.

The programme will require producers to fund collection, sorting, reuse, and recycling infrastructure, with penalties of up to USD 50,000 per day for intentional non-compliance. Footwear brands with significant California sales volumes should engage with the PRO formation process now and prepare product-level data, supported by documented footwear product testing, for reporting.

Proposition 65 and federal PFAS reporting

California's Proposition 65 remains one of the most active enforcement mechanisms affecting footwear, with hundreds of sixty-day notices issued monthly, predominantly for lead, phthalates and other chemicals of concern.

At the federal level, the EPA's TSCA Section 8(a)(7) reporting rule requires all entities that have manufactured or imported PFAS in any year since 2011 to submit data by 13 October 2026. While this is a reporting obligation rather than a product ban, it signals increasing federal scrutiny of PFAS across supply chains. A proactive footwear testing programme aligned to both Prop 65 and TSCA requirements helps brands stay ahead of enforcement risk.

Struggling to keep up with US footwear regulations? Contact us today, and our team will reply to you shortly.

Key footwear regulations in China

China footwear safety standard GB 25038-2024 (General safety requirements for footwear)

China's revised mandatory footwear testing standard GB 25038-2024, effective 1 June 2025, represents a major expansion of the country's footwear safety regime. Formerly titled "Rubber shoes healthy and safe specification", the renamed standard now applies to footwear products made of all materials (excluding protective boots and children's footwear for those aged 14 and below).

Key changes include new requirements for hexavalent chromium (Cr VI) in leather and fur (≤10 mg/kg), dimethyl fumarate (≤0.1 mg/kg), chlorinated phenols, phthalates (total DEHP, DBP, BBP and DIBP <0.1%), short-chain chlorinated paraffins (<0.15%), and sharp nail tip and broken needle checks.

The transition period ends 1 December 2026, after which all products must comply with the new China footwear safety standard GB 25038-2024.

Brands should engage an experienced footwear testing lab with GB-standard capabilities to verify compliance before the deadline.

GB 30585-2024 (Children's footwear safety)

Published alongside GB 25038-2024 and also effective from 1 June 2025, GB 30585-2024 sets safety technical specifications for infants' and children's footwear (aged 14 and below). The standard introduces stricter limits tailored to children's vulnerability, including tighter restricted-substance thresholds and additional physical safety requirements.

Brands exporting children's footwear to China should align footwear chemical testing and RSL programmes with the updated substance limits and ensure products manufactured after June 2025 are fully compliant.

Proposed restrictions on PFAS and VOCs

China is also moving towards stricter controls on PFAS and volatile organic compounds (VOCs) in industrial and consumer products. In early 2026, the Standardization Administration of China solicited public comments on major revisions to mandatory national standards governing prohibited and restricted substances, including PFAS. While these proposals are not yet finalised, they signal China's increasing alignment with global trends and should be monitored closely by brands manufacturing in or exporting to the Chinese market. Forward-looking footwear product testing strategies should already factor in likely PFAS thresholds.

Contact us now to ensure your footwear products comply with the requirements in China.

Business risks of non-compliance for footwear brands

Failure to meet global footwear compliance requirements may result in:

Border holds and product seizures
Mandatory recalls
Financial penalties
Loss of retail distribution
Reputational damage and ESG credibility loss

Major retailers increasingly specify their own testing standards or reference recognised RSLs and performance benchmarks. Brands unable to supply current, independent test evidence may risk being deprioritised.

How does Eurofins Softlines and Hardlines support footwear compliance?

Eurofins Softlines & Hardlines supports footwear brands in translating regulatory requirements into practical, risk-based testing strategies. By auditing supply chains against upcoming rules and supporting the completeness of technical documentation, brands can move from reactive issue management to proactive compliance.

Our footwear testing and compliance services include:

Chemical testing: Comprehensive screening for restricted substances, including RSL and MRSL testing, to ensure compliance with international regulations such as REACH and Prop 65.
Performance Testing: Validation of physical properties and claims, ensuring your products meet consumer expectations for quality and function.
Durability testing and verification: Advanced testing protocols to prove product longevity, supporting eco-design goals and reducing returns.
Fault Diagnosis: Expert root-cause analysis to identify why a product failed and how to prevent it in future production runs.
ZDHC MRSL Conformance Services: Support for Level 1, 2 and 3 conformances to the ZDHC Manufacturing Restricted Substances List, demonstrating leadership in sustainable chemical management.
EUDR deforestation impact assessment: Strategic support to assess your supply chain’s exposure to the EU Deforestation Regulation requirements for leather and rubber.
Footwear environmental impact calculator: A specialised tool to estimate the environmental footprint of your footwear products, aiding in transparency and reporting.
PFAS testing and TOF testing: Dedicated solutions for detecting "forever chemicals," including Total Organic Fluorine (TOF) screening and targeted analysis.