What are PFAS, and why are they used in textiles?
Per- and polyfluoroalkyl substances, commonly known as PFAS, are a large group of manufactured chemicals valued for their resistance to water, oil, grease and stains.
These properties have made PFAS useful in textile treatments, particularly where products are expected to remain waterproof, stain-resistant or durable in demanding conditions. They may be associated with outdoor jackets, rainwear, uniforms, footwear, carpets, upholstery and other treated textile products.
PFAS are often described as “forever chemicals” because many of them break down very slowly and can remain in the environment for long periods. Their persistence, widespread use and potential health and environmental effects have resulted in growing regulatory attention worldwide.
Where can PFAS appear in a textile product?
PFAS may be introduced at different stages of textile and apparel production rather than only in the final fabric.
Possible sources include:
- Durable water-repellent finishes applied to outer fabrics
- Oil- and stain-resistant surface treatments
- Waterproof or breathable membranes
- Coated zippers, trims and accessories
- Footwear treatments and protective coatings
- Production aids used during textile processing
- Contamination from shared machinery or chemical systems
This means that checking only the finished product may not provide a complete view. Brands may also need information from fabric mills, chemical suppliers, trim suppliers and manufacturing facilities.
Why does PFAS compliance matter to fashion and outdoor brands?
PFAS compliance is becoming an important issue for product development, sourcing, quality, sustainability and legal teams.
Brands may face several forms of risk:
- Market-access risk: A product may no longer be permitted for sale in a jurisdiction that restricts intentionally added PFAS.
- Supplier risk: Brands may not know which treatments or chemical formulations have been used by upstream suppliers.
- Testing risk: Different laws may use different definitions, thresholds and testing approaches.
- Documentation risk: Retailers or authorities may request declarations, certifications or supporting evidence.
- Reputation risk: Unsupported “PFAS-free” claims may create consumer and legal concerns.
- Substitution risk: Replacing one restricted PFAS with another fluorinated chemistry may not provide a durable long-term solution.
The main challenge is therefore not only removing a chemical. It is proving what was used, where it was used and which evidence supports the product claim.
What is happening in the European Union?
The European Union already regulates certain PFAS substances through legislation including the REACH Regulation and the Persistent Organic Pollutants framework.
A broader restriction proposal covering a large group of PFAS has also been submitted under REACH. The proposal considers the manufacture, placing on the market and use of PFAS across many sectors. The regulatory evaluation process is ongoing, so businesses should avoid presenting the proposal as though a complete EU-wide ban on all PFAS is already in force.
For textile businesses, the important message is that PFAS use is receiving increased scrutiny and that additional restrictions may affect materials, finishes, coatings and imported products.
Brands selling products in the EU should therefore:
- Identify PFAS uses in their product and supplier portfolios
- Monitor the progress of the wider REACH restriction proposal
- Check existing restrictions on individual PFAS substances
- Evaluate technically suitable non-fluorinated alternatives
- Maintain evidence supporting chemical and product claims
What is happening in the United States?
The United States does not currently have one single federal rule banning all PFAS in every textile product. However, federal reporting requirements and individual state product restrictions are creating significant obligations for manufacturers, importers, brands and retailers.
California
California legislation restricts the manufacture, distribution and sale of textile articles containing regulated PFAS from 1 January 2025, subject to the law’s scope, definitions and limited exemptions.
The law also places responsibilities on manufacturers to use the least toxic available alternative when replacing regulated PFAS and to provide specified compliance information.
New York
New York prohibits the sale or offering for sale of new apparel containing intentionally added PFAS from 1 January 2025.
A separate restriction for outdoor apparel intended for severe wet conditions takes effect from 1 January 2028. New York guidance also encourages sellers to obtain and retain compliance certifications from manufacturers or suppliers.
Federal reporting
Under the US Toxic Substances Control Act, certain manufacturers and importers may have PFAS reporting and recordkeeping obligations. Depending on the business and product, reporting can include PFAS imported as part of articles such as textiles and apparel.
Because state requirements continue to develop, businesses should evaluate every market in which their products are sold rather than relying on one national compliance position.
Which textile products may require the most attention?
Products designed to resist water, oil, dirt or stains are more likely to require detailed PFAS review.
Examples include:
- Waterproof jackets and rainwear
- Ski, hiking and mountaineering apparel
- Tents, sleeping systems and outdoor equipment
- Workwear and protective clothing
- Footwear and coated accessories
- School uniforms and performance apparel
- Carpets, upholstery and home textiles
- Products marketed as stain-resistant or easy-clean
Some laws provide different treatment for specialised protective equipment or apparel used in severe wet conditions. These distinctions should be checked carefully rather than assumed.
What evidence should brands collect?
A supplier statement saying “PFAS-free” may be useful, but it may not be sufficient on its own.
A stronger evidence package may include:
- Supplier declarations identifying whether PFAS are intentionally added
- Full material and component records
- Chemical formulation or treatment information
- Certificates signed by authorised supplier representatives
- Laboratory test reports using an appropriate method
- Purchase orders and specifications prohibiting defined PFAS uses
- Records of alternative finishes and substitution decisions
- Manufacturing-site and process information
- Evidence linking the declaration or test result to the exact product, style, batch or material
The final point is important. A valid certificate has limited value when a company cannot prove which products or production batches it covers.
Does a laboratory test prove that a product is PFAS-free?
Testing can provide valuable evidence, but the result must be interpreted carefully.
PFAS is a broad chemical group, and no single test necessarily identifies every possible PFAS substance. Different approaches may measure targeted compounds, total fluorine or extractable organic fluorine. Each method has strengths and limitations.
A test result should therefore be considered together with:
- The legal definition applicable in the target market
- The substances included in the analytical method
- The detection and reporting limits
- The material or component that was sampled
- The relationship between the sample and the marketed product
- Supplier declarations and process information
Brands should avoid making broad “PFAS-free” claims unless the evidence and claim definition are clear, documented and suitable for the relevant jurisdiction.
What should fashion and outdoor brands do now?
A practical PFAS programme should connect legal requirements, supplier data, testing and product traceability.
- Map the product portfolio. Identify products and materials with waterproof, stain-resistant, oil-resistant or protective functions.
- Map the supply chain. Identify fabric mills, chemical formulators, finishers, trim suppliers and manufacturing sites.
- Define the restricted-substance requirement. State clearly which PFAS definition, market and product scope the supplier must follow.
- Collect supplier evidence. Request declarations, formulations, certificates and supporting documentation.
- Prioritise testing. Use a risk-based plan focused on high-risk materials, suppliers and product claims.
- Evaluate alternatives. Confirm that replacement chemistries provide the necessary product performance without creating another compliance concern.
- Link evidence to products. Connect every declaration and test report to the relevant material, style, purchase order, lot or batch.
- Monitor regulatory change. Review requirements regularly because state, national and EU rules continue to evolve.
How digital traceability supports PFAS compliance
PFAS compliance requires more than storing documents in separate folders. Brands need to understand how material, chemical, supplier and production information connects to the product being sold.
A traceability system can help organisations:
- Map materials and components across multiple supply-chain tiers
- Record which finishes and chemical treatments were used
- Collect supplier declarations and compliance certificates
- Connect laboratory reports to specific products and batches
- Track replacement materials and PFAS phase-out progress
- Maintain evidence for customer and authority requests
- Support product-level transparency and Digital Product Passport initiatives
The goal is to move from a general supplier claim to a verifiable record showing what material was used, where it came from and which evidence supports its compliance status.
How Evidnt can help
Evidnt helps manufacturers and brands connect product, material, supplier and compliance information across the value chain.
For PFAS readiness, Evidnt can support:
- Material and component traceability
- Supplier and facility records
- Batch- and lot-level product genealogy
- Compliance-document management
- Laboratory report and certificate linkage
- Restricted-substance attributes
- QR-enabled product information
- Digital Product Passport preparation
- API-based integration with enterprise and supplier systems
By connecting compliance evidence to the products and materials it covers, businesses can respond more confidently to changing PFAS requirements.
Frequently Asked Questions
What does PFAS stand for?
PFAS stands for per- and polyfluoroalkyl substances. It refers to a large group of manufactured fluorinated chemicals.
Why have PFAS been used in textiles?
PFAS have been used because they can provide resistance to water, oil, grease and stains. These properties are particularly useful in outdoor, technical and performance textiles.
Are all PFAS banned in textiles worldwide?
No. Requirements differ by country, state, product type and PFAS definition. Some jurisdictions restrict intentionally added PFAS in broad textile categories, while others regulate individual substances or specific products.
Is a supplier declaration enough?
A supplier declaration is an important starting point, but brands may also need traceable material data, testing, certifications and evidence linking the declaration to the exact product or batch.
Does “PFOA-free” mean “PFAS-free”?
No. PFOA is only one substance within the wider PFAS group. A product described as PFOA-free may still contain other PFAS.
Can a brand claim that a product is PFAS-free?
Any claim should be clearly defined and supported by appropriate supplier, process and testing evidence. Businesses should also consider the legal requirements governing environmental and product claims in the markets where the product is sold.
Conclusion
PFAS regulation is moving textile compliance away from broad supplier assurances and toward product-specific, traceable evidence.
Fashion and outdoor brands should identify where PFAS may enter their products, understand the rules in each sales market, work with suppliers on alternatives and maintain reliable records linking every claim to the appropriate material and product.
Preparing early can reduce market-access risks while supporting safer chemistry, stronger supplier engagement and more transparent product information.
Official sources
- US Environmental Protection Agency – PFAS Explained
General official information about PFAS, their persistence and their use in industrial and consumer products. - US Environmental Protection Agency – Textile Mills Effluent Guidelines
Official information concerning PFAS use and discharge considerations in textile manufacturing. - US Environmental Protection Agency – TSCA PFAS Reporting and Recordkeeping
Current federal information on PFAS reporting obligations and submission deadlines. - California Legislative Information – AB 1817
Official text of California’s PFAS requirements for textile articles. - New York State Department of Environmental Conservation – PFAS in Apparel Law
Official guidance on New York’s apparel and outdoor-apparel PFAS restrictions and compliance certifications. - European Chemicals Agency – PFAS
Official information on PFAS regulation and the broader PFAS restriction process under REACH. - United Nations Environment Programme – PFAS
International background on PFAS and substances listed under the Stockholm Convention.
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