Purpose & Scope

This document provides guidance for brands, manufacturers, and suppliers in the textile, footwear, and accessories industries to gradually phase out PFAS from their products and to support compliance with emerging national and international regulations.

What Are PFAS and Why Are They Restricted?

• PFAS (Per- and Polyfluoroalkyl Substances) are synthetic chemicals that contain at least one fully fluorinated group (–CF₂– or –CF₃).
• They are extremely persistent (“forever chemicals”) and potentially hazardous to human health, even in very small amounts.
• AFIRM adopts a broad definition of PFAS, aligned with regulatory approaches used in California, New York, and the EU.

Avoiding Misleading Product Claims

Terms such as “PFOA-free” or “PFOS-free” do not mean that a product is completely PFAS-free.

• Other PFAS substances or cross-contamination may still be present.
• Therefore, clear, transparent, and substantiated communication is strongly recommended.

Testing & Communication Protocols

For Brands:

• Inform suppliers early about planned PFAS phaseout, including a clear timeline.
• Identify materials likely to contain PFAS, such as water-repellent, stain-resistant, or quick-drying products.
• Request updated Safety Data Sheets (SDS), Technical Data Sheets (TDS), and written PFAS declarations.
• Require testing protocols and verify that they comply with AFIRM standards.

For Material Suppliers:

• Provide PFAS-free alternatives for treatments (e.g., DWR – Durable Water Repellent).
• Submit current SDS/TDS and clarify whether PFAS or PTFE-based components are present.
• Use a two-tiered testing system.

Testing Strategies

• Total Fluorine Testing: According to EN 14582:2016 or ASTM D7359:2018. Threshold: 100 ppm (dropping to 50 ppm from 2027, e.g., in California).
• Organic Extraction & PFAS Screening: e.g., ISO 23702-1 or EN 17681-1/2. Sensitivity: 10–100 ppb.
  
  

→ Failing either test requires corrective actions or material rejection.

Preventing Cross-Contamination

• PFAS-based and PFAS-free production processes should be strictly separated.
• Use dedicated tools and equipment for PFAS-related processes.
• If separation is not possible, apply the following cleaning procedures:
  • • Run clean fabric through the machines before PFAS-free production.
    • Use high-pressure cleaning systems.
    • Tailor cleaning based on the application method (e.g., pad-dry, jet, exhaust processes).

Industry Standards & Certifications:

Following tools to support PFAS-free implementation:

- Bluesign®: No longer lists PFAS-containing formulations.
- GreenScreen Certified™: PFAS are on the restricted list.
- OEKO-TEX®: Bans PFAS in multiple standards (STANDARD 100, LEATHER STANDARD, ECO PASSPORT).
- ZDHC MRSL v3.0: Includes all PFAS — the ZDHC Gateway helps find compliant chemical formulations.

Regulatory Updates: EU & France

France: PFAS Product Ban

• France has adopted a phased national PFAS restriction starting from 1st of January 2026, with sector-specific bans, exemptions, and transition periods
• Includes defined exceptions and transition periods, e.g.:
  • • 12-month sell-through for products manufactured before 01/01/2026.
    • Special provisions for products with >20% recycled content.

This represents the first legally binding national PFAS product ban within the EU, going beyond reporting or due-diligence obligations.

EU Outlook

• The French regulation is widely seen as a precedent.
• A broader EU-wide PFAS restriction is expected and under active discussion.

PFAS-free materials and verified supply chains are no longer a future ambition but a near-term market and compliance requirement.

Cheers to Progress. Cheers to Impact. Cheers to What Comes Next.