France Drafts Decree on PFAS Threshold Values

By Donia Amara, Regulatory Specialist, Supply Chain Team, UL Solutions

On Feb. 25, 2025, law No 2025-188 was promulgated into French law. This legislation is aimed at protecting the population from risks linked to per- and polyfluoroalkyl substances (PFAS), provides for a ban on PFAS used above a certain residual concentration threshold in cosmetics, ski waxes and textiles. The law now must be implemented through decrees. The draft decrees were published on Aug. 7, 2025. Though this article focuses on the draft decree impacting consumer products, the second decree clarifies the scope and timeline of PFAS phase-out in industrial aqueous effluents (as outlined in Article 2 of the law). For the summary of the passed law, please refer to our previous article: France Adopts Ban of PFAS in Consumer Products.

Objectives of the draft decree 

The draft decree proposed pursuant to paragraph of article 1 of the Law, sets out two elements: 

1. The threshold concentration of PFAS above which the prohibitions on their use, as referred to in that article, apply.
2. The list of products exempt from prohibitions.

It also introduces a new chapter in the Environmental Code, specifying the procedures for applying these bans.

Residual concentration limits 

Article D525-4, introduced by the decree, establishes the threshold values below which prohibitions under paragraphs I and II of Article 1 of the law do not apply.

The proposed thresholds are subject to these three cumulative conditions:

• For any PFAS measured by targeted analysis (excluding polymers): 25 parts per billion (ppb)
• For the sum of PFAS measured as the sum of targeted analysis (with prior degradation of precursors where applicable, but excluding polymers): 250 ppb
• For PFAS, including polymers: 50 parts per million (ppm)

Below these thresholds, traces are considered unintentional contamination. The limits specified in the draft also align with the limits in the draft proposal to restrict PFAS at the European Union level, which is currently undergoing review and awaiting opinions from ECHA’s Risk Assessment and Socio-Economic Analysis Committees (RAC and SEAC). Final opinions from the Committees are anticipated to be delivered to the European Commission by the end of 2026.

Exempted Products from PFAS ban

A few categories remain exempt from ban due to their essential uses in safety or medical roles:

• Personal Protective equipment (PPE, including military, security, and civil protection)
• Waterproof agents intended for re-impregnating the above PPE
• Technical textiles for industrial use and medical textiles

Point raised during the public consultation

Several contributions were made during the public consultation, including:

• Extension of the scope to the shoes and related textiles business to cover all products affected by the law
• Monitoring PFAS in the drinking water: the need to clarify the monitoring procedures for PFAS in water intended for human consumption, in accordance with Article 1 on of the law, was emphasized.
• Maximum protection requirement: some opinion called for a total ban on all the PFAS substances, without exception, to ensure maximum population protection

Implementation and enforcement

To date, Law No 2025-188 has not yet been fully implemented, this decree enters effect the day after its publication in the Journal Officiel. The control authorities will use the defined thresholds to check compliance.

The draft decree is awaiting publication, and its final content may be adjusted based on feedback from public consultation. The consultation was open to the public until Sept. 5, 2025.

References

Draft decree implementing Article 1 of Law No. 2025-188 of 27 February 2025 addressing PFAS in consumer products
Draft Decree implementing Article 2 of Law No. 2025-188 of 27 February 2025 addressing the reduction of PFAS in aqueous industrial effluent