Overview

The most significant 2026 development is the EU’s progress towards a broad, group-based PFAS restriction under REACH. ECHA’s scientific committees have advanced the proposal, but the restriction is not yet law and final requirements and transition periods remain pending.

The most immediate compliance deadline is 10 October 2026, when EU PFHxA restrictions begin to apply to several consumer-product categories, including clothing, related accessories, footwear, certain food-contact materials, mixtures and cosmetics. A further deadline applies to other consumer textiles, leather, furs and hides from 10 October 2027. Companies should verify product composition, supplier evidence and applicable exemptions without delay.

Other important 2026 developments include the UK’s updated PFAS Plan and continued development of separate UK REACH measures, the revised timetable for US federal PFAS reporting, Japan’s decision to designate long-chain PFCAs as Class I Specified Chemical Substances, and the continuing implementation of Stockholm Convention decisions across Asia.

For international companies, there is no single global PFAS compliance standard. Requirements must be assessed by market, product category, substance definition and applicable threshold. Companies should prioritise PFHxA compliance in the EU, maintain separate EU and Great Britain assessments, monitor US state requirements, document supplier information and prepare substitution plans for uses that may become difficult to justify.

Regulatory activity concerning per- and polyfluoroalkyl substances (PFAS) continues to accelerate worldwide. However, regulatory approaches differ considerably between jurisdictions.

The European Union is moving towards broad regulation of PFAS as a group, while also implementing restrictions on individual PFAS and PFAS subgroups. The United States combines federal requirements with an increasingly complex patchwork of state legislation. Great Britain is developing its own PFAS strategy under UK REACH, while several Asian countries are strengthening controls primarily through national implementation of the Stockholm Convention.

For companies placing products on several international markets, PFAS compliance can therefore no longer be addressed through a single global limit or a simple statement that a product is “PFAS-free”.

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European Union – towards broad PFAS restriction

The EU remains at the forefront of comprehensive PFAS regulation.

The proposed universal PFAS restriction under REACH would cover the manufacture, placing on the market and use of a very large group of PFAS.

A major milestone was reached in March 2026. ECHA’s Committee for Risk Assessment (RAC) adopted its final opinion, while the Committee for Socio-Economic Analysis (SEAC) agreed its draft opinion. Both committees support EU-wide regulatory action, although targeted derogations and transitional arrangements are considered necessary for applications where technically and economically feasible alternatives are not yet available. (ECHA)

This does not mean that the universal PFAS restriction is already law. The restriction still has to proceed through the remaining REACH decision-making process before binding requirements and final transition periods can be established.

Companies should nevertheless prepare for a regulatory environment in which the use of PFAS will increasingly require justification and where substitution will be expected whenever suitable alternatives are available.

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PFHxA restriction – immediate importance

While the universal restriction is still being developed, the EU restriction on PFHxA, its salts and PFHxA-related substances has already been adopted.

From 10 October 2026, the following concentration limits apply to several important consumer product categories:

* 25 ppb for the sum of PFHxA and its salts

* 1,000 ppb for the sum of PFHxA-related substances

The limits are measured in homogeneous material.

The first group of products includes textiles, leather, furs and hides used in clothing and related accessories for the general public, footwear for the general public, paper and cardboard food-contact materials, mixtures for the general public and cosmetic products.

For other textiles, leather, furs and hides intended for the general public, the corresponding restriction applies from 10 October 2027.

Specific exemptions exist, including certain Category III personal protective equipment, medical devices, in-vitro diagnostic devices and construction textiles. (Eur-Lex)

This is particularly important for textile, footwear and consumer-product supply chains using C6 fluorocarbon chemistry. The fact that a treatment has historically been marketed as “PFOA-free” or based on “C6 chemistry” is no longer sufficient evidence of compliance.

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Existing EU PFAS legislation remains important

The future universal restriction should not be confused with PFAS requirements already in force.

PFOS, PFOA and PFHxS are subject to stringent controls through persistent organic pollutant legislation, while additional groups such as C9–C14 perfluorocarboxylic acids have also been regulated.

Consequently, companies need to assess both existing substance-specific requirements and emerging group restrictions.

The regulatory direction is moving away from controlling only a small number of well-known PFAS towards addressing larger groups of structurally related substances.

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Great Britain – a separate regulatory path

Following Brexit, EU REACH restrictions do not automatically become UK REACH restrictions in Great Britain.

The UK Government published its first comprehensive PFAS Plan in February 2026, setting out actions to identify PFAS sources, reduce releases and exposure and develop appropriate regulatory measures. The plan was subsequently updated in August 2026. (GOV.UK)

This distinction is particularly important for PFHxA.

The EU PFHxA restriction taking effect for several consumer-product categories on 10 October 2026 does not automatically apply in Great Britain.

However, the UK Government has specifically identified existing EU restrictions, including PFHxA, as measures that will be considered when developing future UK REACH restrictions. The Government has also stated its intention to make UK REACH more capable of aligning efficiently with its closest trading partners, particularly the EU. (GOV.UK)

One of the most advanced UK PFAS initiatives concerns PFAS in firefighting foams. HSE has concluded that restriction is an appropriate risk-management measure. A socioeconomic consultation closed on 7 September 2026, with a government decision expected in 2027. (Health and Safety Executive)

Companies selling into both the EU and Great Britain should therefore avoid assuming regulatory equivalence. EU REACH and UK REACH compliance should currently be assessed separately.

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United States – federal and state requirements must be considered separately

The US regulatory landscape differs substantially from the European model.

There is currently no federal equivalent to the proposed EU universal PFAS restriction covering PFAS across virtually all uses. Instead, regulation consists of federal environmental, reporting and chemical-control measures combined with rapidly developing state legislation.

One important federal requirement is the PFAS reporting rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA).

The rule concerns manufacturers and importers of PFAS manufactured or imported during the period 2011–2022, and the reporting framework includes information on chemical identity, uses, production volumes, exposure, environmental and health effects and disposal.

In April 2026, EPA changed the reporting timetable. The reporting period will now begin 60 days after the effective date of EPA’s forthcoming revision of the PFAS reporting rule. Companies should therefore not rely on older reporting dates without checking the current EPA position. (US EPA)

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US state legislation

For consumer products, state legislation is becoming at least as important as federal PFAS legislation.

Different states have introduced or are developing requirements covering areas such as:

• intentionally added PFAS
• textiles and apparel
• outdoor apparel
• food packaging
• cosmetics
• juvenile products
• cookware
• carpets and rugs
• firefighting foams
• product reporting and disclosure

The terminology and regulatory mechanisms differ between states. Some legislation targets specified PFAS, while other requirements use broader definitions such as “intentionally added PFAS”.

For companies selling nationally in the United States, compliance therefore requires a state-by-state assessment rather than reliance solely on federal requirements.

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Asia – increasingly important but less harmonised

There is currently no Asian equivalent to the proposed EU universal PFAS restriction.

Regulation remains country-specific and is strongly influenced by the Stockholm Convention on Persistent Organic Pollutants.

An important international development occurred at COP-12 in 2025, when long-chain perfluorocarboxylic acids (LC-PFCAs), their salts and related compounds were added to Annex A of the Stockholm Convention, subject to specified exemptions. (Stockholm Convention)

This expands the international PFAS regulatory framework beyond the earlier Stockholm Convention listings for PFOS, PFOA and PFHxS. (POPs)

Countries are now incorporating these decisions into national legislation at different speeds.

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Japan

Japan continues to strengthen PFAS controls under its Chemical Substances Control Law (CSCL).

PFHxS-related compounds were designated as Class I Specified Chemical Substances, and Japan has specifically prohibited the import of certain products, including water-repellent and oil-repellent textiles, when they contain the designated PFHxS-related compounds. (Japan Ministry of Economy, Trade and Industry)

A significant further development occurred in May 2026 when the Japanese Cabinet decided to designate long-chain PFCAs, their salts and related compounds as Class I Specified Chemical Substances in response to the 2025 Stockholm Convention decision. (Japan Ministry of Economy, Trade and Industry)

This demonstrates how international POP decisions are rapidly being converted into national product and chemical controls.

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China and South Korea

China and South Korea have also progressively implemented controls resulting from the Stockholm Convention listings of PFOS, PFOA, PFHxS and related substances.

For companies manufacturing products in Asia for export, however, compliance with local manufacturing legislation does not necessarily demonstrate compliance in the destination market.

A product legally manufactured in China, Korea or another Asian country may still fail EU, UK or US state requirements.

The regulatory requirements of the market where the product is placed on the market must therefore be assessed independently.

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Taiwan

Taiwan is developing a broader PFAS management framework.

Its authorities have established a national PFAS Management Action Plan and have progressively expanded the number of PFAS addressed under chemical-management legislation. Taiwan has also adopted future drinking-water standards covering combinations of PFOA, PFOS and PFHxS, effective from 1 July 2027. (Taiwan Ministry of Environment)

This illustrates a broader trend in Asia: regulation is gradually expanding from a small number of individual legacy PFAS towards larger groups and additional exposure pathways.

The Stockholm Convention is becoming increasingly important

The international regulatory baseline for PFAS continues to expand.

PFOS, PFOA and PFHxS are already covered by the Stockholm Convention, although the regulatory structure and available exemptions differ between substances.

The 2025 addition of long-chain PFCAs, their salts and related compounds to Annex A represents another major expansion of international PFAS regulation. (POPs)

This development is particularly important because Stockholm Convention decisions are subsequently implemented through national legislation across Europe, Asia and many other regions.

Consequently, companies should expect additional countries to introduce or strengthen national PFAS controls during the coming years.

From individual substances towards PFAS groups

A clear regulatory trend can now be identified.

Historically, PFAS regulation concentrated primarily on individual substances such as PFOS and PFOA.

The regulatory scope subsequently expanded to PFHxS, long-chain PFCAs and other defined PFAS subgroups.

The EU universal PFAS restriction represents the next potential step: regulating PFAS largely as a class rather than continuing to regulate individual substances one by one.

Other jurisdictions have not necessarily adopted the same approach, but developments under the Stockholm Convention and national legislation indicate that the number of regulated PFAS will continue to increase.

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What should companies do now?

Companies should first establish whether PFAS are intentionally used anywhere in their products, materials or production processes.

Particular attention should be paid to:

• water-, oil- and stain-repellent treatments
• membranes and technical textiles
• outdoor clothing and footwear
• food-contact materials
• cosmetics
• firefighting foams
• industrial coatings
• fluoropolymer-based components
• processing aids and production equipment

Supplier declarations should be supported by appropriate technical documentation and, where relevant, analytical testing. A general “PFAS-free” statement may not be sufficiently precise because definitions, reporting thresholds and analytical methods differ between jurisdictions.

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Companies should also:

1. Map products and materials by destination market.

2. Identify intentionally added PFAS and relevant PFAS-related substances.

3. Distinguish between EU, UK, US federal, US state and Asian requirements.

4. Review product portfolios against the EU PFHxA deadlines.

5. Monitor the development of the EU universal PFAS restriction.

6. Track UK REACH developments separately from EU REACH.

7. Assess US state requirements on a state-by-state basis.

8. Maintain documented supplier communication and compliance evidence.

9. Prepare substitution plans for applications where PFAS use may become difficult to justify.

10. Reassess compliance regularly as new national measures enter into force.

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Conclusion

PFAS regulation is moving from isolated restrictions on a limited number of substances towards broader controls covering PFAS groups and, in some jurisdictions, PFAS as a class.

The EU is leading this development through the proposed universal REACH restriction, while the PFHxA restriction creates immediate obligations for several consumer-product categories. Great Britain is developing a separate regulatory path under UK REACH. The United States combines federal requirements with extensive state-level legislation, and Asian countries are progressively implementing international PFAS decisions through national law.

For international companies, the key compliance challenge is not only identifying whether PFAS are present.

It is also determining:

• which definition applies
• which concentration limit applies
• whether the substance is intentionally added
• which product category is relevant
• which market is concerned
• which transition period applies
• and whether an exemption is available

A robust PFAS compliance programme should therefore combine product mapping, supplier documentation, regulatory monitoring, analytical verification and substitution planning.