Eurofins Softlines & Leather Monthly Bulletin (December 2025)
New European requirements for textile waste
On 16 October 2025, Directive (EU) 2025/1982 amending Directive 2008/98/EC in relation to food waste and extended producer responsibility (EPR) for textiles came into force.
With this new Directive, the European Union amends the Waste Framework Directive and introduces stricter waste management requirements for resource-intensive sectors, notably textiles and food.
Under the new legislation, Member States must transpose the directive into national law by 17 June 2027 and ensure Extended Producer Responsibility (EPR) systems for textiles are fully operational within 30 months of its entry into force.
The framework imposes significant obligations on producers, including manufacturers, importers, distributors, and online sellers, requiring them to finance the collection, sorting, recycling, and reuse of textile waste. Additional requirements include:
- Registration in national producer registers.
- Eco-design standards to improve product durability and recyclability.
- Prohibition on destroying unsold goods.
Micro-enterprises will benefit from an additional year to comply with these obligations.
Furthermore, Member States must guarantee that producers of textiles, textile-related products, and footwear cover the costs associated with used and waste items deposited at designated collection points. This includes products collected through private take-back schemes and textiles collected under national systems, provided these items were first placed on the market after 16 October 2025, in jurisdictions where an EPR scheme for textiles and footwear is already established.
ECHA releases draft PFAS use mapping ahead of SEAC consultation
On 5 November 2025, the European Chemicals Agency (ECHA) published a preliminary mapping of PFAS uses across 14 sectors, including textiles, cosmetics, medical devices, and electronics. This draft aims to help stakeholders prepare for the upcoming consultation on the SEAC draft opinion regarding PFAS restrictions, expected in March 2026. Updated mappings will follow after SEAC finalises its evaluations later this year. Stakeholders are encouraged to review sector-specific details and provide input during the consultation phase.
For more details and to access the draft mapping, visit ECHA’s official website here.
The table below summarises the most recent standard updates and upcoming dates of withdrawal (non-exhaustive):
(*) Date of availability: The latest date by which national standards conflicting with a European Norm (EN) (and Harmonisation Document (HD) for the European Committee for Electrotechnical Standardisation (CENELEC)) must be withdrawn.
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The European Committee for Standardisation (CEN)/CENELEC |
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Reference |
Title |
Date of withdrawal(*) |
Supersedes |
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Leather - Physical and mechanical tests - Determination of the static absorption of water (ISO 2417:2025) |
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Nonwovens - Test methods - Part 8: Determination of liquid strike-through time (simulated urine) for nonwoven coverstocks (ISO 9073-8:2025) |
30 April 2026 |
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Textile floor coverings - Determination of sensitivity to spilled water |
30 April 2026 |
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Chemical disinfectants and antiseptics - Chemical-thermal textile disinfection - Test method and requirements (phase 2, step 2) |
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Washington state adopts new PFAS restrictions and reporting requirements under updated Safer Products rule
On 20 November 2025, the Washington State Department of Ecology finalised amendments to Chapter 173-337 WAC – Safer Products Restrictions and Reporting, significantly expanding regulatory requirements related to per- and polyfluoroalkyl substances (PFAS) in consumer products. These updates introduce new restrictions, broaden reporting obligations, and clarify several key definitions as part of the state’s ongoing effort to reduce toxic chemicals in consumer goods.
Earlier PFAS restrictions and reporting requirements adopted in prior rulemakings remain in place, such as the restrictions on aftermarket stain- and water-resistance treatments, carpets, and rugs (for both indoor and outdoor use), which took effect on 1 January 2025, and the restrictions on leather and textile furniture and furnishings intended for indoor use which are due to take effect 1 January 2026. Reporting requirements for leather and textile furniture and furnishings intended for outdoor use came into force on 1 January 2024, with the first report due on 31 January 2025, with ongoing annual submissions thereafter.
New restrictions on products containing intentionally added PFAS
Under the revised rule, Washington adds three new product categories to the existing list of PFAS-restricted products. For these newly covered categories, manufacturers, suppliers, and retailers are prohibited from manufacturing, selling, or distributing certain consumer products in Washington if they contain intentionally added PFAS. These restrictions apply to the following product categories:
- Apparel and accessories, excluding certain speciality PPE and extreme-use categories.
- Automotive washes
- Cleaning products
For these categories, the PFAS restrictions apply to products manufactured on or after 1 January 2027; products manufactured before that date may continue to be sold.
Expanded PFAS reporting requirements
In addition to the new restrictions, manufacturers must also report the intentional use of PFAS in nine additional product categories:
- Apparel designed for extreme or long-term use
- Footwear
- Recreation and travel gear
- Automotive waxes
- Cookware and kitchen tools
- Firefighting personal protective equipment
- Floor waxes and polishes
- Hard-surface sealers
- Ski waxes
For these categories, manufacturers must file annual reports with the Washington State Department of Ecology detailing products manufactured on or after 1 January 2026, wherein PFAS are intentionally added. The first report is due on 31 January 2027, and thereafter annually.
Key revisions between the proposed and final rule
Following further analysis and consideration of feedback gathered during the public comment period, the Washington State Department of Ecology incorporated several necessary refinements before finalising the regulation:
- De minimis threshold added: a total fluorine concentration above 50 ppm now triggers the presumption of intentionally added PFAS across all 12 regulated product categories.
- Updated definitions: clarifications were made to the definitions of extreme and extended use apparel, cookware and kitchen supplies, and recreation and travel gear.
- Clarified applicability for cleaning products: revisions were made to how restrictions apply to cleaning products, and exemptions were further refined by:
- Defining the scope of “industrial” use, and
- Excluding pesticidal products that are not marketed as cleaning products.
Who is affected?
The amended rule applies to all entities that manufacture, distribute, or sell the covered products in the state of Washington, including online and brick-and-mortar retailers. Businesses will need to evaluate their product lines to determine which items fall under the new restrictions or reporting requirements.
Important timeline for compliance
Existing PFAS obligations (unchanged):
- 1 January 2024: reporting began for leather and textile furniture and furnishings intended for outdoor use; first report due 31 January 2025, then annually by 31 January.
- 1 January 2025: restrictions on aftermarket stain- and water-resistance treatments and on carpets and rugs (indoor and outdoor) took effect for products manufactured on or after this date.
- 1 January 2026: restrictions on leather and textile furniture and furnishings intended for indoor use take effect on products manufactured on or after this date.
New PFAS reporting obligations:
Companies should be aware of the following implementation deadlines:
- 20 November 2025: rule officially adopted
- 21 December 2025: rule becomes effective
- 1 January 2026: coverage period begins for new PFAS reporting categories (extreme/extended-use apparel, footwear, gear for recreation and travel, automotive waxes, cookware and kitchen supplies, firefighting PPE, floor waxes and polishes, hard surface sealers, ski waxes).
- 31 January 2027: first PFAS reporting submissions for these new categories due; thereafter, reports must be filed annually by 31 January.
New PFAS restrictions:
- 1 January 2027: PFAS restrictions take effect (for products manufactured on or after this date) for:
- Apparel and accessories
- Automotive washes
- Cleaning products
Adopted Rule: 337_C1-5_c_RDS-6288-3ForFiling.pdf
EPA proposes significant revisions to PFAS reporting rule under TSCA Section 8(a)(7)
On 13 November 2025, the U.S. Environmental Protection Agency (EPA) published a Proposed Rule to revise its October 2023 PFAS reporting and recordkeeping requirements under TSCA Section 8(a)(7) (40 CFR Part 705).
The proposal responds to extensive stakeholder concerns and implementation challenges and would significantly reduce reporting obligations, particularly for article importers, small businesses, and entities handling PFAS at low concentrations.
EPA estimates industrywide cost savings of $786–$843 million if the proposed changes are finalised.
Key proposed revisions:
|
Provision |
Current (2023 Final Rule) |
Proposed Amendment (Nov 2025) |
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Imported Articles |
Reporting required for PFAS in imported articles (2011–2022). |
Full exemption for PFAS contained in imported articles. |
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De Minimis Threshold |
No threshold; any PFAS triggers reporting. |
0.1% de minimis exemption for PFAS in mixtures or articles. |
|
R&D Activities |
Not exempt. |
PFAS manufactured/imported solely for research & development are exempted. |
|
Impurities & Byproducts |
Impurities and certain byproducts are required to be reported. |
Exemption for impurities, non-isolated intermediates, and certain byproducts. |
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Submission Deadline |
April 13–October 13, 2026 (with a small article importer deadline of 13 April 2027). |
Removes the small importer deadline due to the article exemption. New reporting window opens 60 days after final rule → remains open 3 months. |
EPA states that these changes better align the rule with the TSCA standard requiring reporting of information that is “known to or reasonably ascertainable by” the manufacturer or importer.
Impact on industry
- ~127,000 article importers would be relieved of reporting obligations.
- Companies would no longer need to obtain retrospective PFAS composition data from suppliers for the 2011–2022 lookback period.
- Reduced need for testing, documentation review, and historical supply chain reconstruction.
- Domestic PFAS manufacturers still must report processing and use information, including incorporation of PFAS into articles.
Public comment opportunities
EPA is seeking comment on:
- The scope and legal basis of the imported article exemption.
- Whether the proposed 1% de minimis threshold is appropriate (EPA requests input on alternatives, including 1%).
- Whether EPA should add a production-volume threshold (e.g., 2,500 lbs/year), similar to TSCA Chemical Data Reporting (CDR).
Public comment deadline: 29 December 2025.
Next Steps for Regulated Entities
- Review whether your organisation may still have reporting obligations under the revised rule.
- Prepare and submit comments supporting or opposing specific exemptions.
- Monitor for EPA’s issuance of the Final Rule in 2026, which will trigger the 60-day countdown to the revised submission window.
- Ensure systems are ready to report via EPA’s Central Data Exchange (CDX) once the final rule is published.
Below is a table summarising some recent ASTM standards updates:
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Reference |
Title |
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Standard Performance Specification for Vinyl-Coated and Urethane-Coated Upholstery Fabrics |
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Standard Test Method for Tensile Strength and Elongation of Leather |
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Standard Test Method for Distortion of Yarn in Woven Fabrics |
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Standard Test Method for Bond Strength of Bonded, Fused, and Laminated Apparel Fabrics |
Brazil implements mandatory footwear labelling to strengthen consumer protection
The National Institute of Metrology, Quality and Technology (Inmetro) has announced new regulations requiring mandatory labelling for all footwear sold in Brazil. Published under Portaria No. 459 on 19 August 2025, the measure aims to enhance consumer protection and promote fair competition within the footwear industry.
- The regulation addresses a longstanding issue: the lack of standardised information on origin, composition, and traceability for footwear products. While retailers and distributors have until 31 December 2027 to ensure all footwear sold is appropriately labelled, manufacturers and importers must comply with the following new rules by 31 July 2026: Labels must include detailed composition information for each part of the shoe (upper, lining, insole, sole) and permanent markings for size, country of origin, and brand or CNPJ.
- Each product must carry a unique international identification code to facilitate traceability and prevent fraud.
The regulation also aligns Brazil with international standards, ensuring imported products meet the exact requirements as those produced locally.
For more details, please refer to the National Institute of Metrology, Quality and Technology website here.
Below you will find a monthly summary of product recalls and alerts in Europe (Source: “Safety Gate (RAPEX)”), the United Kingdom (Source: "OPSS"), and the United States (Source: “CPSC”).
Safety Gate (RAPEX) (European Commission Rapid Alert System for dangerous non-food products – Alerts reported by EU national authorities).
The following 11 alerts regarding clothing, textile, and fashion items were reported between week 40 and week 43 of 2025.
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Type of Risk |
Number of alerts |
Notes |
|
Chemical |
1 |
Leather sandals The leather in the product contains chromium VI.
The product does not comply with the REACH Regulation. |
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2 |
Children's slippers The plastic material of the product has an excessive concentration of bis(2-ethylhexyl) phthalate (DEHP) and dibutyl phthalate (DBP). Moreover, the product has an excessive concentration of lead.
The product does not comply with the General Product Safety Regulation or the REACH Regulation. |
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Environment |
1 |
Sandals with lights The solder in the product has an excessive lead concentration.
The product does not comply with the Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS 2 Directive). |
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1 |
Sport shoes with LEDs The product has an excessive concentration of lead. The cable insulation has an excessive concentration of dibutyl phthalate (DBP).
The product does not comply with the Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS 2 Directive). |
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Injuries |
1 |
Children's jacket The product has long drawstrings with free ends at the waist. These drawstrings can become trapped during a child's various activities.
The product does not comply with the General Product Safety Regulation or with EN 14682. |
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1 |
Children's gloves While wearing the product, long threads may wrap around the child's finger, causing swelling and reduced blood flow, leading to injuries.
The product does not comply with the General Product Safety Regulation. |
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Strangulation
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1 |
Children's clothes The product has long functional cords with free ends at the neck. These cords can become trapped during a child's various activities.
The product does not comply with the General Product Safety Regulation or EN 14682. |
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1 |
Children's jacket The product has long functional cords with free ends at the neck. These cords can become trapped during a child's various activities.
The product does not comply with the General Product Safety Regulation or EN 14682. |
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1 |
Children's jumpsuit The product has long cords in the neck area. These drawstrings can become trapped during a child's various activities.
The product does not comply with the General Product Safety Regulation or EN 14682. |
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1 |
Children's clothing set The product has long cords in the neck area. These drawstrings can become trapped during a child's various activities.
The product does not comply with the General Product Safety Regulation or EN 14682. |
Office for Product Safety and Standards (OPSS) issues Product Safety Alerts to the U.K. market. The following 2 alerts regarding clothing, textile and fashion items were issued between week 40 and week 44 of 2025.
|
Type of Risk |
Number of alerts |
Notes |
|
Choking |
1 |
Rompers (Various) and Trousers The poppers can detach or break off when worn, creating small parts. The product does not meet the General Product Safety Regulations 2005. |
|
Injuries |
1 |
Overalls/Bodysuits The poppers have rough edges, which could lead to cuts or scrapes in infants. The products do not meet the General Product Safety Regulations 2005. |
From 6 November 2025 to 26 November 2025, the Consumer Product Safety Commission (CPSC) published the following recalls: 4 recalls of textile & leather products
|
Hazard |
Number of alerts |
Notes |
|
Deadly entrapment and flammability |
1 |
Mattresses The aftermarket mattresses violate the mandatory standard for crib mattresses because they may not fit particular play yards or non-full-sized cribs, posing a deadly entrapment hazard. Babies can suffocate in gaps between an undersized mattress or extra padding and the side walls of a product, especially when the infant’s face becomes trapped against the side and the mattress, preventing the infant from breathing. The non-full-sized crib mattress also fails to meet the mandatory flammability standard for mattress sets. |
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Burn |
2 |
Children’s nightgowns The recalled nightgowns violate the mandatory flammability standards for children’s sleepwear, posing a risk of burn injuries to children. |
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Burn and serious injury |
1 |
Sleep sacks The recalled sleep sacks violate the mandatory flammability standard for children’s sleepwear, posing a burn hazard and risk of serious injury or death to children. |