France Issues FAQs for PFAS Ban Implementation

On May 31, 2026, France issued Frequently Asked Questions to clarify the application of Decree No. 2025-1376, which took effect on January 1, 2026 under Law No. 2025-188 of February 27, 2025. These measures aim to reduce public exposure to perfluoroalkyl and polyfluoroalkyl substances and address environmental and health risks.

The FAQ provides practical clarification on how the regulation applies across product categories and supply chains. It outlines which products fall within scope, establishes how PFAS limits apply, and explains how substances should be measured. It also defines available exemptions and describes how transition periods for stock clearance operate. This guidance supports manufacturers, brands and suppliers as they interpret regulatory expectations and evaluate product compliance.

The FAQ document clarifies several important elements for PFAS restriction implementation in France.

Scope of application

• Leather garments are not subject to bans because they are not classified as textiles.
• Imitation leather products, when textile-based, are subject to bans.
• Textile clothing accessories such as ties, scarves and belts are included, while non-clothing accessories such as handbags and watches with fabric straps are excluded.
• Fully leather accessories remain excluded.
• All footwear, including leather shoes, falls within PFAS restriction requirements.
• Mixed-material garments are covered, with rules applied to textile components.

PFAS thresholds and compliance

• Requirements apply to finished products.
• Testing is conducted at the homogeneous material level, such as lining or outer fabric.
• All thresholds must be met cumulatively.
• If one limit is exceeded, the product is considered noncompliant without further testing needed.

Testing and evidence

• The regulation applies to all PFAS substances, with no fixed list specified.
• No mandatory testing method is prescribed, but state-of-the-art or technically relevant approaches should be used.
• Supplier documentation may support compliance, including identifying sources of fluorine when total fluorine levels are exceeded.

Organizations can approach conformity by aligning testing strategies and documentation with the expectations outlined in the FAQ. This includes evaluating finished products at the homogeneous material level and confirming that all applicable thresholds are met across each component.

Because the regulation applies to all PFAS substances and does not prescribe a single testing method, companies may rely on technically relevant and state-of-the-art analytical methods to assess compliance. Supplier documentation can play a supporting role, particularly when identifying the source of total fluorine results.

UL Solutions supports companies navigating PFAS requirements through targeted testing and supply chain insight. This includes testing for specific PFAS substances as well as total fluorine analysis to help identify potential sources of noncompliance.

In addition, UL Solutions works with organizations to develop Restricted Substance Lists to help reduce the risk of noncompliant goods entering the market. Advisory support and training programs provide visibility into evolving regulatory requirements and upcoming PFAS restrictions, helping teams stay informed and take action aligned with regulatory expectations.

Source: https://www.cosmed.fr/download/?url=2026/06/20260527_faq_decret_pfas.pdf