First published: 20/11/2025
In 2025, PFAS regulations in Europe accelerated dramatically, touching everything from cosmetics and textiles to packaging and cookware. The pace and breadth of regulatory action have created both compliance challenges and opportunities for brands that move proactively. Below we break down the latest EU-wide developments, key country actions, business implications, and how Eurofins Sustainability Services can help you navigate this fast-changing landscape.
PFAS in Consumer Products: Why They’re Under Fire
PFAS (per- and polyfluoroalkyl substances) have long been valued for their ability to repel water, grease and stains. These properties have made them common in a wide range of consumer goods, including textiles and technical apparel, cosmetics, non-stick cookware, food-contact packaging, toys and menstrual products, often chosen for their performance-enhancing qualities.
However, growing scientific evidence has raised serious concerns about the health and environmental impacts of PFAS. Studies have linked exposure to certain PFAS compounds with increased risks of cancer, fertility and developmental issues, thyroid and liver dysfunction, and immune system suppression.
In response, consumer organisations across Europe have intensified scrutiny of PFAS in everyday products. Recent testing by consumer groups within the BEUC (The European Consumer Organisation) revealed that nearly 30% of items across 16 product categories contained detectable levels of PFAS, with some exceeding current or proposed EU limits. This growing awareness is driving demand for safer formulations, and many sectors are already exploring viable alternatives, signalling that reformulation is not only possible, but increasingly expected.
EU-Wide Regulatory Developments in 2025
REACH universal restriction proposal (10,000+ PFAS)
The EU’s broad REACH restriction proposal (initially tabled in 2023) was updated in August 2025 after reviewing 5,600+ consultation comments. The revised dossier expands sector coverage and explores three restriction options, including a ban with time-limited derogations and a conditional-use pathway under strict controls. RAC and SEAC continue their evaluation through 2025–26.
POPs Regulation tighter PFOS limits in articles
The EU amended Regulation (EU) 2019/1021 (POPs) via Delegated Regulation (EU) 2025/718, aligning PFOS thresholds with PFOA. From 3 December 2025, unintentional trace contaminant limits apply at ≤ 0.025 mg/kg for PFOS and its salts, and ≤ 1 mg/kg (sum) for PFOS-related compounds in substances, mixtures and articles; specific exemptions were removed.
Learn more about the summarised changes for affected industries, including staged timelines and cross‑references to related POP updates.
Cosmetics bans under EU Cosmetics Regulation when classified as CMR; broader PFAS controls via REACH
Under Article 15 of the EU Cosmetics Regulation, PFAS substances classified as CMR are prohibited in cosmetics, with fresh Omnibus VII (Regulation (EU) 2025/877) updates published in May 2025 reinforcing the automatic ban of newly classified CMR substances. Many PFAS controls in cosmetics will continue to be pursued under REACH due to environmental concerns beyond consumer health risk.
Packaging & Packaging Waste Regulation (PPWR) (Regulation (EU) 2025/40)
PFAS restrictions in food-contact packaging: The PPWR, published 22 January 2025 and effective from 11 February 2025 (with general application from 12 August 2026), introduces harmonised rules for packaging design, labelling, recyclability and explicit PFAS concentration limits for food packaging (including thresholds such as 25 ppb for any PFAS in targeted analysis, plus sum limits), ahead of the wider REACH restriction timetable.
Country-Specific Actions in 2025
France
Law No. 2025-188 (27 February 2025) bans manufacture, import, export and sale of PFAS-containing cosmetics, ski wax, clothing textiles, footwear and certain waterproofing agents from 1 January 2026 (with residual thresholds and specific protective gear exemptions to be set by decree). A broader ban applies to all textiles from 1 January 2030, subject to defined essential-use exceptions. Notably, cookware was excluded from the final law after lobbying; NGOs and legal observers continue scrutiny of marketing claims around PFAS safety.
Denmark
Executive Order BEK no. 464 (2 May 2025) prohibits import and sale to consumers of clothing, footwear and certain impregnation agents containing PFAS at total fluorine ≥ 50 mg F/kg, effective 1 July 2026 (sell-through permitted until 1 January 2027), with exemptions for reuse, certain PPE, medical devices and transit goods.
United Kingdom
UK REACH 2025/26 Work Programme prioritises PFAS risk management, including consultation on a PFAS restriction in firefighting foams, alignment with other jurisdictions where appropriate, and continued SVHC updates.
Business Implications for Consumer Product Brands
- Compliance risks for imported and EU-manufactured goods: Tighter POPs thresholds (PFOS), sector-specific bans (France, Denmark), PPWR packaging limits and evolving REACH proposals increase the likelihood of non-compliance, especially for multi-component products with coatings and finishes.
- Labelling and marketing challenges: Claims such as ‘non-toxic cookware’ face heightened scrutiny by authorities and self-regulatory bodies; evidence must reflect real-world use, not only lab scenarios.
- Supply-chain disruption and reformulation: The shift to safer chemistries can affect performance, durability and cost. That said, market testing shows feasible alternatives exist across many categories already.
- Proactive testing and documentation are critical: As thresholds tighten (e.g., PFOS ≤ 0.025 mg/kg; PPWR limits in food packaging), brands need robust analytical methods, traceability and supplier assurance to demonstrate compliance across articles and packaging.
Practical Next Steps for Brands (2025–2026)
2025 has been a tipping point for PFAS regulations in Europe. With new PFOS limits under POPs, the PPWR setting PFAS thresholds in food packaging, and robust national bans in France and Denmark, the regulatory journey towards a universal restriction under REACH is gathering strength. Brands that act now—auditing products, testing proactively, reformulating where needed, and tightening documentation—will reduce compliance risk, protect consumers and the environment, and build trust
- Audit portfolios now for PFAS in articles and packaging; prioritise high-risk categories (water-repellent textiles, cosmetics, non-stick cookware, food-contact materials).
- Align test plans to POPs and PPWR thresholds; set pass/fail criteria including PFOS ≤ 0.025 mg/kg and applicable PPWR PFAS limits.
- Strengthen supplier contracts to require disclosure of PFAS use and transition timelines; incorporate right-to-test clauses.
- Update claims and labels to avoid over-promising without traceable evidence across all components.
- Plan reformulation with sustainable chemistry support; leverage documented alternatives in cosmetics and textiles where viable.
How Eurofins Sustainability Services Supports Compliance
- PFAS testing for consumer products: Detection of regulated PFAS in textiles, apparel and footwear (including screening for PFOS/PFOA-related compounds aligned to POPs thresholds). Food-contact materials and packaging testing against PPWR PFAS limits and migration requirements.
- Regulatory intelligence & watch services: Continuous monitoring of REACH committee opinions, POPs amendments, PPWR implementation guidance and key national measures (France, Denmark, UK), and other international PFAS regulations translated into actionable compliance roadmaps.
- Sustainable chemistry & reformulation support: Guidance on safer alternatives, performance benchmarking and risk assessments, helping brands phase out intentionally added PFAS while maintaining product quality and durability.
- Documentation & due diligence: End-to-end support to build supplier declarations, testing plans and technical files that withstand regulatory and market scrutiny.
If you need to benchmark your current PFAS exposure, verify compliance against POPs and PPWR thresholds, or plan a PFAS phase-out strategy across cosmetics, apparel, footwear and packaging, we’re here to help.
Contact us to schedule an exploration meeting, PFAS testing programme, or regulatory briefing tailored to your product lines and markets.
Regulatory References
- ECHA updated PFAS REACH proposal (Aug 2025)
- Cosmetics regulatory context & REACH approach for PFAS
- POPs—PFOS limits (EU 2025/718)
- PPWR (EU 2025/40) & PFAS in food packaging
- France Law No. 2025-188 PFAS (Feb 2025)
- Denmark BEK no. 464 (May 2025)
- UK REACH Work Programme 2025/26 (HSE/Defra)
- Eurofins PFAS/POPs updates
