Eurofins Softlines & Leather Monthly Bulletin (December 2025)

FRANCE

France adopts new decree to ban PFAS in consumer products

On 30 December 2025, the French government published Decree No. 2025-1376, introducing strict measures to prevent risks associated with perfluoroalkyl and polyfluoroalkyl substances (PFAS).

The decree applies to a wide range of products, including cosmetics, textiles, footwear, and waterproofing agents. Under this regulation, the manufacture, import, export, and marketing of products containing PFAS is prohibited as of 1 January 2026. A transitional period of 12 months is granted for the sale of existing stock produced before this date. The decree specifies residual concentration thresholds for PFAS as follows:

• 25 ppb for individual PFAS (excluding polymers)
• 250 ppb for the sum of PFAS (with prior degradation of precursors, excluding polymers)
• 50 ppm for total fluorine content (including polymers). If the total fluorine measurement exceeds 50 mg F/kg, the manufacturer, importer, exporter, or producer must provide, upon request from the competent authorities, proof that the fluorine content originates from PFAS or non-PFAS substances.

In line with the REACH Universal PFAS restriction proposal Annex XV dossier, it is understood that the above 3 limits described in the Decree should be applied concurrently, meaning that all three concentration limits apply to any product under scope, and a product should not contain PFAS over any of the indicated concentration limits unless it is covered by any of the specific exemptions.

Scope:

• From 1 Jan 2026, the requirements, under the framework Law No. 2025-188, apply to:
  • Any cosmetic product containing perfluoroalkyl and polyfluoroalkyl substances
  • Any wax product containing perfluoroalkyl and polyfluoroalkyl substances
  • All textile clothing products, all footwear and all waterproofing agents for textile clothing and footwear products intended for consumers containing perfluoroalkyl and polyfluoroalkyl substances
• From 1 Jan 2030, these will apply to:
  • Any textile product containing perfluoroalkyl and polyfluoroalkyl substances is prohibited

Certain exemptions are allowed, notably for:

• Personal protective equipment (PPE) under EU Regulation 2016/425
• Military and civil protection gear
• Textile clothing and footwear incorporating at least 20% recycled material, where PFAS presence is limited to the recycled fraction

This decree implements provisions of Law No. 2025-188, which was adopted earlier this year to protect public health and the environment from PFAS-related risks. The regulation aligns with EU standards and anticipates future technical updates under European chemical safety regulations. The Ministry of Ecological Transition emphasised that these measures aim to reduce PFAS exposure, which has been linked to environmental persistence and potential health hazards.

EUROPE

Standard updates

The table below summarises the most recent standard updates and upcoming dates of withdrawal (non-exhaustive):

(*) Date of withdrawal: the latest date by which national standards conflicting with an EN (and HD for CENELEC) have to be withdrawn.

Publications on the European Commission initiatives related to textiles

The table below summarises recent publications on European Commission initiatives related to sustainable and circular apparel textiles:

UNITED STATES

Connecticut Approves Official Wording for PFAS Labels

In a significant regulatory milestone under its PFAS in Products law (Connecticut General Statutes § 22a-903c), the Connecticut Department of Energy and Environmental Protection (DEEP) has published an approved list of consumer-facing labeling phrases that manufacturers, producers, wholesalers, and retailers must use to disclose the presence of intentionally added per- and polyfluoroalkyl substances (PFAS) in products sold in the state.

Connecticut’s PFAS in Products law, enacted as part of Public Act 24-59 in 2024, establishes a phased approach to disclosure and eventual prohibition of certain categories of products that contain intentionally added PFAS. This law is designed to give consumers clear, visible notice about PFAS content and to reduce exposure to “forever chemicals” in everyday products.

Beginning 1 July 2026, covered products containing intentionally added PFAS may only be sold or offered for sale in the state if they carry a label with terminology approved by DEEP that informs the purchaser of the presence of PFAS in the product.

Approved Labeling Phrases

On 1 December 2025, DEEP issued an order approving the following wording that satisfies the state’s PFAS labeling requirement:

• “Contains PFAS”
• “Made with PFAS”
• “Made with PFAS chemicals”
• “Made with intentionally added PFAS”
• “This product contains PFAS chemicals”

These phrases are now official and may be used on product labels to meet the disclosure requirement under the law.

DEEP has also clarified that other words or symbols may be approved on a case-by-case basis if a manufacturer petitions the agency and the proposed alternative satisfies the statutory criteria. Such petitions are submitted by email to DEEP’s PFAS in Products mailbox.

Which Products Are Covered

The PFAS labelling requirement applies to a broad range of consumer product categories that may contain intentionally added PFAS if manufactured on or after the compliance date. These include:

• Apparel
• Carpets or rugs
• Cleaning products
• Cookware
• Cosmetic products
• Dental floss
• Fabric treatments
• Juvenile products
• Menstruation products
• Textile furnishings
• Ski wax
• Upholstered furniture

The requirement also applies to any product category where PFAS-containing components are incorporated — meaning final assembled products containing covered components must also be labelled.

What the Labels Must Look Like

According to the statutory requirements and DEEP’s order:

• Labels must be clearly visible before the point of sale.
• They must inform the purchaser that PFAS are present using an approved phrase or symbol.
• Labels must be constructed of materials durable enough to remain legible for the product’s useful life.

The responsibility to apply the label lies with the manufacturer or producer unless the wholesaler or retailer agrees in writing to assume that responsibility.

THAILAND

Draft regulation on restricting the formaldehyde and Azo dyes on garments

On the 19^th December 2025, the Thai Industrial Standards Institute (TISI) and the Thailand Ministry of Industry notified (G/TBT/N/THA/792) the WTO Proposed draft mandatory regulation on garments that conform to TIS 2346-2566 (2023) regarding formaldehyde and Azo dyes restriction.

The draft regulation will enter into force after 270 days following the date of its publication in the Government Gazette.

The draft Regulation mandates clothing, apparel, and other textile products for infants to conform to the Thai Industrial Standard TIS 2346-2566 (2023).

This draft Ministerial Regulation applies to the following products:

• Clothing
• Hats
• Socks
• Diapers
• Mittens
• Scarves

Azo dyes: 24 kinds of aromatic amine, see Appendix A of TIS 2346-2566

ISO Standard:

• ISO 14184-1:2011 Textiles — Determination of formaldehyde — Part 1: Free and hydrolysed formaldehyde (water extraction method)
• ISO 14362-1:2017 Textiles — Methods for determination of certain aromatic amines derived from azo colourants — Part 1: Detection of the use of certain azo colourants accessible with and without extracting the fibres
• ISO 14362-3:2017 Textiles — Methods for determination of certain aromatic amines derived from azo colourants — Part 3: Detection of the use of certain azo colourants, which may release 4-aminoazobenzene

The proposed date on which the draft will be adopted is to be determined.

PRODUCT RECALLS/ALERTS

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

Europe

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

The following 20 alerts regarding clothing, textile and fashion items were reported between week 47 and week 51 of 2025.

United Kingdom

The Office for Product Safety and Standards (OPSS) issues Product Safety Alerts to the UK market. The following two alerts regarding clothing, textile and fashion items were issued between week 47 and week 51 of 2025.

United States

From 4 December 2025 to 18 December 2025, the CPSC (Consumer Product Safety Commission) published the following recalls: 1 recall of textile & leather products