Eurofins Softlines & Leather Monthly Bulletin (August 2025)

EUROPE

New requirements for PFOS, UV-238 and PFAS in POP Regulation

In June and July 2025, the European Commission published several Delegated Regulations which amend Annexe I – Part A of Regulation (EU) 2019/1021 as regards persistent organic pollutants and substances as PFOS, EV-238 and PFAS.

Below is a summary table with relevant points related to these substances and their new requirements. It is not an exhaustive list.

European Initiative on unsold apparel and footwear

On 30 June 2025, the European Commission opened a consultation period related to exemptions from prohibiting the destruction of unsold apparel and footwear. The aim of this initiative is to specify these exemptions, supporting the implementation of the Ecodesign for Sustainable Products Regulation. It outlines criteria under which unsold products may still be destroyed, such as for safety, hygiene, irreparable damage, legal or technical unsuitability, or lack of viable donation options. It is open until 11 August 2025.

For more information, please visit the European Commission website here.

United States

Minnesota amends PFAS Law

In 2023, the State of Minnesota passed HF 2310 (Chapter 60) to regulate intentionally added PFAS in various consumer product categories. On 14 June 2025, Minnesota passed SF 3, amending its PFAS law to clarify exemptions in product scope and application.

Key provisions of the original law (HF 2310)

• Phase I (effective 1 January 2025): Bans products with intentionally added PFAS in 11 specified categories, including:
• carpets/rugs
• cleaning products
• cookware
• cosmetics
• dental floss
• fabric treatments
• juvenile products
• menstruation products
• textile furnishings
• ski wax
• upholstered furniture

• Phase II (starting 1 January 2026): Requires manufacturer disclosure of PFAS use:
• Including names, CAS numbers, purposes, and amounts

• Phase III (effective 1 January 2032): Extends PFAS ban to all products, except those deemed a “currently unavoidable use” by rule; certain exemptions apply (e.g., FDA-regulated medical devices, firefighting foam, reused products)

Amendments under SF 3

• Expanded exemptions for Phase I (2025):
• "Intentionally added PFAS located only in electronic components or internal components" are now exempt from the 2025 ban, to be phased in later by 2032 if deemed avoidable or phased out.
• Juvenile product definition clarified to exclude children’s motor vehicles (e‑bikes, snowmobiles, ATVs) and their replacement parts.

Minnesota expands exemptions to state lead & cadmium ban

In 2023, the State of Minnesota originally enacted HF 2310 (Chapter 60), which banned the import, manufacture, sale, or distribution of the following 15 product categories containing lead over 90 ppm or cadmium over 75 ppm:

• Chalk, crayons, paints and other art supplies

• Clothing, footwear, headwear and accessories
• Cosmetics and personal care products
• Costumes, costume accessories and children’s and seasonal party supplies
• Craft supplies and jewellery-making supplies
• Cups, bowls and other food containers
• Fidget spinners
• Jewelry
• Keys, key chains and key rings
• Outdoor games
• Play sets and play structures
• Pots and pans
• Puzzles, board games, card games and similar games
• School supplies
• Toys

On 14 June 2025, Minnesota approved HF 4, introducing important exemptions to its lead and cadmium law, effective 15 June 2025.

Key newly exempted items

• Ink pens and mechanical pencils are no longer classified as “school supplies” under the statute.
• The term “paints” in the art supplies category is restricted to children’s paints only.
• Professional artist materials—such as oil-based and water-based paints, pastels, pigments, ceramic glazes, markers, and encaustics—are now excluded.
• Products containing lead only in internal solder are exempt until 1 July 2028, but manufacturers must submit biennial reports about alternatives and phase-out plans thereafter.
• Keys, key chains, and key rings with lead content are exempt if available before 1 July 2028. Even after that date, keys with at least 1.5% lead content remain permitted.
• Cast iron or steel pots and pans are exempt if lead is ≤90 ppm and cadmium is in the enamel, so long as the enamel does not come into contact with food.

PRODUCT RECALLS / ALERTS

Below you will find a monthly summary of product recalls and alerts in Europe (Source “Safety Gate (RAPEX)”) and the United Kingdom (Source “OPSS”).

Europe

Safety Gate (RAPEX) (European Commission Rapid Alert System for dangerous non-food products – Alerts reported by EU national authorities)

The following 4 alerts regarding clothing, textile and fashion items were reported between week 24 and week 27 of 2025.

United Kingdom

Office for Product Safety and Standards (OPSS) issues Product Safety Alerts to the U.K. market. The following 6 alerts regarding clothing, textile, and fashion item was issued between week 24 and week 27 of 2025.