PFAS in France: What the December 2025 decree changes for the textile sector

Introduction

Per- and polyfluoroalkyl substances, commonly referred to as PFAS, have been the subject of extensive regulatory work at European level for several years, particularly within the framework of the REACH Regulation. While a comprehensive EU-wide restriction on PFAS is still under review, its adoption has been repeatedly postponed, leaving Member States to move forward at different paces.

In France, this situation has led to a national regulatory initiative. Following the adoption of a dedicated law in February 2025, a decree published at the end of December clarified how these rules would be implemented, effectively anticipating a European framework that is still under construction.

Since 1 January 2026, French regulations have therefore prohibited the manufacture, import, export and placing on the market of certain categories of products containing PFAS, including specific textile products.

For players in the textile and apparel sector, this decree represents a significant shift. Scope of application, regulatory thresholds, affected products, exemptions and timelines: this article provides a detailed breakdown of this landmark text, with a specific focus on its practical implications for the textile industry.

PFAS: What are we actually talking about?

Per- and polyfluoroalkyl substances (PFAS) encompass several thousand chemical substances developed for their specific technical properties: water repellency, resistance to grease and stains, thermal stability, and ease of maintenance. In the textile sector, they have been widely used in surface treatments, coatings and functional finishes, particularly to provide water- and stain-repellent properties.

These substances are now commonly referred to as “forever chemicals” due to their extreme persistence: they degrade very slowly, accumulate in the environment, and can build up in the human body. Biomonitoring data confirm widespread population exposure. A recent study indicates that 94% of the individuals tested carry residues of at least one PFAS, highlighting the scale of their presence in the environment and in everyday consumer products

In response to these findings, authorities have progressively strengthened regulatory oversight. In France, this culminated in 2025 with the adoption of a specific legislative framework, followed by an implementing decree published in December. This decree does not introduce a new ban: it makes existing restrictions effective, measurable and enforceable by translating them into immediately applicable rules.

A clear legal framework for PFAS, in force since 1 January 2026

The law of 27 February 2025 established the principle of a progressive ban on PFAS in certain product categories. The decree of 28 December 2025 sets out the practical implementation of this ban and incorporates these provisions into the Environmental Code.

A key point for textile brands is that the restriction is not limited to sales within France. It applies to four distinct operations involving products containing PFAS:

• Manufacturing,
• Importing,
• Exporting,
• Placing on the market.

A non-compliant product may therefore neither be manufactured in France, nor imported, nor exported, even if it is intended for a market outside the European Union.

The decree applies to all relevant economic operators (manufacturers, importers, exporters and entities placing products on the market) and relies on an enforcement framework involving environmental authorities, customs and market surveillance bodies, whose roles are detailed later in this article.

Products covered by the PFAS ban

The decree applies to several product categories, including:

• Textile products,
• Footwear,
• Cosmetic products,
• Ski waxes,
• Waterproofing agents.

While this article focuses on textile products, it is important to note that the scope of the decree extends well beyond the textile sector.

It should also be stressed that not all textile products are treated identically. Certain products may benefit from exemptions (see section 5). As a result, the ban does not apply uniformly across all textiles, but depends on specific criteria linked to product use or composition.

The concept of “placing on the market” is interpreted broadly and includes any supply to a third party, whether free of charge or for consideration.

PFAS thresholds set by decree

The decree introduces precise quantitative thresholds, which form the core of the compliance framework.

Three situations are distinguished:

• Individually measured PFAS, excluding polymers: the threshold is set at 25 ppb.
• Total PFAS, measured as the sum of targeted PFAS analyses (with prior degradation of precursors where applicable): the threshold is set at 250 ppb.
• PFAS including polymers: the threshold is set at 50 ppm.

The decree also introduces a specific mechanism relating to total fluorine content. Where total fluorine exceeds 50 mg F/kg, the operator must be able to demonstrate whether this fluorine originates from PFAS or from other substances.

These thresholds are not fixed indefinitely and may evolve, particularly in line with future changes to the European regulatory framework.

Products exempt from the PFAS ban under the decree

The ban introduced by the decree is not absolute. It is accompanied by strictly regulated exemptions.

Use-based exemptions

The following products are notably exempt:

• Personal protective equipment (PPE),
• Industrial technical textiles,
• Certain medical textiles,
• Equipment intended for the armed forces, internal security or civil protection.

These exemptions are justified either by the absence of technically viable substitutes or by critical safety requirements.

The specific case of textiles containing recycled materials

As a general principle, the decree aims to ban the presence of PFAS in textile products. However, it introduces a targeted exemption for certain apparel textiles and footwear containing at least 20% recycled material derived from post-consumer waste.

This exemption is based on an operational reality: some recycled materials may contain legacy PFAS residues from previous uses, which cannot yet be fully eliminated.

Under this regime:

• PFAS are not authorised as such, but tolerated on a residual basis,
• This tolerance applies only to the recycled fraction of the product,
• The allowable PFAS content in the finished product is strictly proportional to the percentage of recycled material incorporated.

PFAS may therefore never be intentionally added. Their presence is only accepted as an unavoidable technical residue linked to the use of recycled materials, within strictly defined limits.

This regime entails strong traceability requirements: operators must be able to demonstrate the origin of the recycled materials used and, where relevant, explain the source of any PFAS detected in the finished product.

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How does the French PFAS framework fit into the broader REACH regulatory process?

The French decree forms part of a broader European effort to regulate chemical substances. Ultimately, the stated objective is to achieve harmonised rules through the REACH Regulation.

However, at this stage, a comprehensive PFAS restriction under REACH has not yet been adopted. The dossier, supported by several Member States, has been subject to repeated delays, and its examination by the European Commission has been postponed until 2026.

In practical terms, this means that textile market players will still have to operate within a fragmented regulatory landscape for some time.

The French decree explicitly provides that the thresholds it sets may be revised in light of future European developments, notably under REACH and the POPs Regulation.

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Unsold goods and PFAS: how should stock be managed?

Although the decree has been applicable since 1 January 2026, a stock clearance period is is provided for. Products containing PFAS and manufactured before this date may continue to be placed on the market or exported for a maximum period of twelve months, i.e. until 31 December 2026.

After this deadline, any manufacture, import, export or placing on the market of non-compliant products will be strictly prohibited.

Controls and sanctions: who enforces the PFAS ban, and how?

The PFAS ban is enforced by authorities that already oversee product compliance, environmental protection and trade flows.

Which authorities may intervene?

• Environmental enforcement authorities and competent State services (DREAL, DRIEAT, DEAL, authorised inspectors) carry out market controls, verify compliance with regulatory thresholds and examine supporting documentation (tests, certificates, technical documents).
• Customs authorities play a key role in import and export operations, fully within the scope of the ban. A non-compliant product may be blocked both on entry to and exit from the European Union.
• The DGCCRF (consumer protection authority) monitors consumer products placed on the market and verifies regulatory compliance as well as the availability of supporting documentation held by economic operators.

What happens in the event of non-compliance?

The decree does not introduce a standalone sanctions regime. In practice, enforcement measures fall under general legal frameworks (environmental law and customs law), which may result in:

• A ban on placing the products on the market, importing or exporting them,
• Withdrawal and, where applicable, recall of products,
• Administrative or financial penalties, or more severe consequences depending on the nature and seriousness of the infringement.

⚠️ Beyond product composition, the ability to demonstrate compliance (tests, certificates, supplier evidence) becomes a decisive factor during inspections.

Implement PFAS compliance with Trace For Good

Trace For Good enables you to manage PFAS compliance across your collections, by clearly identifying compliant products, at-risk products and those requiring corrective action, across all markets and supply chains.

How?

• By centralising all your technical certificates and documentation related to materials, treatments and finishes, so your teams can access the necessary information without multiplying manual searches.
• By collecting and tracking supplier declarations of compliance, systematically supported by documented evidence, securing your products’ compliance without increasing operational burden.
• By automatically analysing your testing documents, using OCR features to quickly identify tested substances, applicable thresholds and potential non-compliances.
• By ensuring continuous compliance monitoring, without additional manual effort across your collections and as regulations evolve.

PFAS compliance thus becomes a streamlined, industrialised process, rather than a one-off, time-consuming and reactive task.

Conclusion

With the December 2025 decree, the expectations of French authorities are now explicit. Brands know exactly what is prohibited, in which cases, under which thresholds and with what consequences. This marks a turning point: compliance is no longer just about meeting a regulatory requirement, but about recognising that PFAS management will fundamentally change how textile products are designed, sourced and placed on the market.

In this context, the challenge is no longer to “do things as inexpensively as possible”, but to identify and deploy viable substitute solutions that meet regulatory, technical and industrial constraints. This transition will take time. But before redesigning products, an immediate priority emerges: being able to prove that things are being done properly.

PFAS compliance depends as much on thresholds as on the methodology used to demonstrate them: data quality, material traceability, testing reliability, and the ability to produce evidence during inspections.

This is also what allows brands to prepare for what comes next. The expected revision of the European framework under REACH in 2026 will reinforce this logic. Structuring a robust, scalable compliance methodology today helps avoid facing new obligations tomorrow without knowing how to respond.

PFAS management is therefore not a one-off issue. It represents a foundational step towards a more demanding, better documented and more sustainable approach to chemical compliance in the textile sector.