France’s PFAS ban on cosmetics, clothing, and footwear: what applies in 2026

Last Updated: April 29, 2026
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If you manufacture cosmetics, clothing, shoes, or ski wax in France or import these products there, you are now subject to one of the world’s strictest PFAS bans.

Law No. 2025-188, signed on 27 February 2025 and implemented by Decree No. 2025-1376 on 28 December 2025, introduced hard product bans that took effect on 1 January 2026.

What are PFAS, and why is France banning them?

PFAS (per- and polyfluoroalkyl substances) are a group of over 10,000 synthetic chemicals used in non-stick coatings, waterproofing treatments, stain-resistant finishes, and cosmetic formulations. France is banning them because they do not break down in the environment or in the human body, accumulating in blood, organs, and drinking water supplies over time.
The scientific concern is well established. PFAS are linked to thyroid disruption, immune suppression, certain cancers, and developmental harm in children. France’s move predates an expected EU-wide restriction and positions the country as the first major European market to legislate broad consumer product bans.

Decree No. 2025-1376 defines PFAS as any substance containing at least one fully fluorinated methyl group (CF3-) or methylene group (-CF2-), with no hydrogen, chlorine, bromine, or iodine atoms attached.

Does the French PFAS ban affect my products?

The ban applies to any manufacturer, importer, or distributor placing cosmetics, ski wax, clothing, footwear, or consumer waterproofing sprays on the French market from 1 January 2026, regardless of where those products are made. If your products contain PFAS above the legal thresholds, you cannot legally sell them in France.
Under Article L.524-1 of the French Environmental Code (as amended by Law 2025-188), the ban covers the following product categories containing any PFAS substance above threshold:

  • Cosmetics
  • Ski wax
  • Clothing
  • Footwear

  • Waterproofing sprays for clothing and shoes

The ban applies to products sold commercially and those distributed free of charge.

What PFAS levels are actually illegal in France?

Products are banned if their PFAS content exceeds specific residual concentration thresholds set in Decree 2025-1376; below these thresholds, products may still be sold. The most restrictive limit is 25 parts per billion (ppb) for any single PFAS compound measured by targeted analysis, not including fluoropolymer polymers.
The thresholds set in Article D.525-4 are:

PFAS ban threshold table

For the polymer threshold: if total fluorine measurement exceeds 50 mg F/kg, the manufacturer or importer must be able to demonstrate to authorities that the fluorine originates from PFAS or non-PFAS sources.
These thresholds will be revised if EU measurement standards under REACH (Regulation (EC) No 1907/2006) or the POPs Regulation (EU) 2019/1021 are updated.

Are there any exemptions to the French PFAS ban?

Yes. Decree No. 2025-1376 exempts personal protective equipment (PPE) regulated under EU Regulation 2016/425, military and civil protection clothing, and clothing or footwear made with at least 20% post-consumer recycled content, where PFAS is confined to the recycled fraction only. These exemptions are narrow and carry specific conditions.

Which clothing and footwear categories are exempt from the PFAS ban?

  • PPE covered by EU Regulation 2016/425 (such as protective gloves, safety boots, and high-visibility jackets).

  • PPE and combat equipment for armed forces, internal security forces, and civil protection agencies.

  • Waterproofing sprays used specifically to re-waterproof the PPE listed above.

  • Clothing and footwear incorporating at least 20% post-consumer recycled content, where PFAS presence is limited to the recycled fraction only, with the permitted level proportional to the share of recycled material in the finished product.

Is there a sell-through period for existing stock with PFAS?

Yes. Products that were manufactured before 1 January 2026 and contain PFAS can still be sold or exported during a 12-month transition period, up to 31 December 2026. After that date, any remaining stock containing PFAS above the thresholds must be withdrawn.

Timeline graph deadlines PFAS ban

What does the French PFAS ban mean for clothing and footwear brands?

For clothing and footwear brands not selling PPE, France’s PFAS ban applies, and the practical challenge is that PFAS can be present in fabrics, dyes, finishes, interlining materials, padding, button coatings, adhesives, soles, and the inks used on labels. Every component of a finished garment or shoe is potentially in scope.
Suggested steps:

  • 1

    Map every component: list the outer shell fabric, lining, padding, interlining, zips, buttons, adhesive bonding, rubber sole compounds, and care label inks separately.

  • 2

    Request PFAS test reports from every supplier for every component, not just the main shell fabric.

  • 3

    Commission product testing using targeted analysis of the finished product measuring individual PFAS at 25 ppb sensitivity and cumulative PFAS at 250 ppb sensitivity

  • 4

    Check waterproofing spray formulations separately: any spray sold to consumers for clothing or footwear must also comply, even if it is sold as an aftercare product rather than as part of the garment.

  • 5

    Document the recycled-content fraction if you are relying on the recycled-material exemption, as authorities may request proof of both the percentage of recycled content and PFAS concentration data limited to that fraction.

What does the French PFAS ban mean for cosmetics brands?

The French PFAS ban sets a 25 ppb threshold for any single PFAS compound in cosmetics, with no category-specific exemption available. Any cosmetic product exceeding that limit is banned from the French market from 1 January 2026.

Typical PFAS sources in cosmetics include fluorinated film-forming polymers in long-wear foundations and mascaras, perfluoroalkyl phosphate esters in moisturisers, and PTFE (polytetrafluoroethylene) powder used as a slip agent in lipsticks and eyeshadows.

In practice, this means:

  • 1

    Ingredient-level testing of every raw material used in manufacturing, including emulsifiers, film-forming agents, and fluorinated polymers used in long-wear foundations, mascaras, lipsticks, and sunscreens.

  • 2

    Machine and packaging review: industrial machinery membranes, seals, gaskets, and conveyor components made of PTFE or similar fluoropolymers can transfer PFAS to finished products. Each contact surface in the production line requires assessment.

  • 3

    Input/output water comparison: measuring fluorine in water entering and leaving your production site helps isolate whether PFAS in the final product originates from raw materials or from process contamination.

  • 4

    Supplier declarations: all ingredient and packaging suppliers, including those outside France, must confirm the PFAS status of their materials in writing.

What happens in 2030?

From 1 January 2030, France will extend its PFAS ban to all textiles, not just clothing and footwear, with limited exemptions only for products with no available PFAS-free alternative. This second phase, established in Article L.524-1 II of the Environmental Code, covers all textile products sold in France including upholstery fabric, curtains, and industrial textiles used in consumer applications.
Exemptions under the 2030 ban include:

  • Industrial technical textiles
  • PPE (Regulation 2016/425) where no substitute for PFAS exists
  • Military, internal security, and civil protection PPE with no available alternative
  • Combat system equipment and equipment for nuclear, radiological, biological, and chemical (NRBC) operations
  • Medical textiles for healthcare uses
  • Clothing and footwear with at least 20% post-consumer recycled content
The “no available alternative” condition carries a documentation requirement. Brands claiming this exemption must be able to show authorities that a PFAS-free alternative does not exist for their specific technical application.

How is France enforcing the PFAS ban?

Enforcement falls under Articles L.521-12 to L.521-20 of the French Environmental Code, giving inspectors the authority to take samples, enter premises, and seize non-compliant products. Inspectors can also require manufacturers, importers, and market operators to provide proof of PFAS concentration levels on demand.

The economic operator placing the product on the French market carries primary liability, even if the PFAS originates from a supplier outside of France.

Article L.524-2 explicitly extends these powers to the investigation and identification of violations under the PFAS chapter. Penalties for environmental code violations in France can include product withdrawal orders, sales bans, and criminal liability for responsible individuals.
France has been building its PFAS monitoring infrastructure progressively since 2023.
For industrial sites discharging PFAS into water, Article 4 of Law 2025-188 introduces a levy of €100 per 100 grams of PFAS discharged annually, with a minimum threshold of 100 grams before the levy applies.

What should you do now to comply with France’s PFAS ban?

The single most important action is to commission a PFAS targeted analysis of your finished products against the 25 ppb per compound and 250 ppb cumulative thresholds before placing any new stock in France. Without this data, you have no basis for confirming compliance and no defence against an inspector’s challenge.
Prioritise these steps:

  • 1

    Identify all PFAS-containing ingredients or materials across your full supply chain: raw materials, components, packaging, and production equipment contact surfaces

  • 2

    Commission certified laboratory testing using targeted PFAS analysis (not just AOF screening) of finished products to confirm compliance against the Decree thresholds

  • 3

    Request PFAS declarations from all suppliers, including those in Asia, North America, or other markets not directly subject to French law

  • 4

    Assess your stock plan: any stock manufactured before 1 January 2026 must be sold or exported before 31 December 2026

  • 5
    Begin planning for the 2030 total textiles ban now, particularly if you sell technical or performance textiles that currently rely on PTFE membranes or fluorinated coatings
Be aware that a supplier declaration does not transfer your legal liability: as the economic operator placing the product on the French market, you remain fully responsible if the finished product is found to exceed the thresholds.
If you import or distribute PFAS-containing products in France and are not established in the EU, you will need a legally designated responsible party established in France or the EU to handle regulatory inquiries on your behalf.

Conclusion

France’s PFAS ban is not a future risk to monitor. It is an active legal requirement that already restricts what you can sell, import, or export in one of Europe’s largest consumer markets. The January 2026 deadlines for cosmetics, clothing, footwear, and ski wax have passed. The December 2026 deadline for transitional stock is approaching. And the 2030 extension to all textiles is closer than most product development cycles allow for.
The law places liability directly on the economic operator placing the product on the French market. If you are the importer or distributor, you carry that responsibility regardless of what your suppliers tell you. The only defensible position is tested, documented compliance.
France is also not acting alone. An EU-wide PFAS restriction under REACH is under active development. What France has legislated today is likely to become the EU baseline in the years ahead. Brands that address PFAS compliance now will be better positioned when that broader restriction lands.
At 24hour-AR, we work with importers, manufacturers, and distributors navigating EU product compliance obligations, including market access questions connected to evolving chemical restrictions. If you need clarity on how France’s PFAS rules affect your specific product category, get in touch:

FAQs

Does France’s PFAS ban apply to products made outside France?2026-04-24T15:28:43+00:00

Yes. The ban applies to any product placed on the French market, regardless of where it was manufactured. If you are the importer or distributor bringing PFAS-containing clothing, footwear, or cosmetics into France, you are the responsible economic operator and subject to French law.

Are all PFAS banned, or only specific ones?2026-04-24T15:29:14+00:00

The ban covers any substance meeting the technical definition of a PFAS under Decree No. 2025-1376: any compound containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) group, with no hydrogen, chlorine, bromine, or iodine atoms attached. There is no approved list of specific compounds. If your product contains any substance meeting that definition above the concentration thresholds, it is in scope.

What is the difference between the 25 ppb and 250 ppb thresholds?2026-04-24T15:29:38+00:00

The 25 ppb limit applies to any single PFAS compound measured individually by targeted analysis, excluding fluoropolymer polymers. The 250 ppb limit applies to the total of all PFAS compounds added together from the same targeted analysis. A product must stay below both limits simultaneously to be compliant.

Can I still sell PFAS-containing clothing that was already manufactured?2026-04-24T15:30:06+00:00

es, but only until 31 December 2026. Products manufactured before 1 January 2026 benefit from a 12-month transition period. After that date, any stock exceeding the PFAS thresholds must be withdrawn from the French market, regardless of when it was produced.

Do I need an EU authorised representative to sell in France if I am based outside the EU?2026-04-24T15:31:34+00:00

If you are a non-EU manufacturer or importer with no legal presence in the EU, you will need a designated responsible party established within the EU to handle regulatory correspondence and market surveillance inquiries on your behalf. This is a separate requirement from PFAS compliance itself but becomes directly relevant when authorities exercise their inspection powers under Articles L.521-12 to L.521-20 of the French Environmental Code.

Is France’s PFAS ban the same as the EU REACH restriction on PFAS?2026-04-24T15:32:19+00:00

No. France has acted through national legislation ahead of any EU-wide measure. A separate PFAS restriction under REACH is under development at EU level but has not yet been adopted. France’s ban currently applies only to the French market, though the thresholds and product categories it covers are likely to influence the eventual EU-wide approach.

Will the PFAS thresholds change in the future?2026-04-24T15:32:40+00:00

Possibly. Decree No. 2025-1376 explicitly states that the thresholds will be revised if EU measurement standards under REACH (Regulation (EC) No 1907/2006) or the POPs Regulation (EU) 2019/1021 are updated. Brands should monitor regulatory developments at both French and EU level.

Inma Antequera Cntent Manager

Author Inma Antequera is Content Manager at 24hour-AR, responsible for producing the guides, articles and resources that help businesses understand and meet EU and UK regulatory obligations. She combines a sharp editorial instinct with a thorough understanding of the compliance landscape to make complex requirements accessible to a global audience.

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