Table of Contents
- What does the French PFAS law prohibit?
- What changed on January 1, 2026?
- Which products are affected?
- Cosmetics
- Ski wax
- Clothing and footwear
- Other textile products
- What is the PFAS residual concentration threshold?
- What exemptions apply?
- What does this mean for product manufacturers?
- Why supplier data matters
- How should manufacturers assess products for France?
- 1. Identify products sold in France
- 2. Map materials and components
- 3. Collect supplier evidence
- 4. Assess the French requirement
- 5. Maintain supporting evidence
- France PFAS requirements and the wider EU PFAS restriction
- Managing France PFAS compliance across products
- What should manufacturers do now?
France has introduced national restrictions on products containing per- and polyfluoroalkyl substances (PFAS), alongside the wider EU PFAS regulatory process.
Law No. 2025-188 of February 27, 2025 introduced restrictions on the manufacture, import, export and placing on the French market of specified PFAS-containing products. The implementing Decree No. 2025-1376 of December 28, 2025 defines the residual concentration threshold and exemptions for certain products. The decree entered into force on January 1, 2026.
For product manufacturers and importers, the practical question is no longer whether France is considering PFAS restrictions. It is:
Which products are covered, what applies now, what changes in 2030, and what evidence is needed to assess products for the French market?
What does the French PFAS law prohibit?
Article L.524-1 of the French Environmental Code prohibits, from January 1, 2026, the manufacture, import, export and placing on the market of certain PFAS-containing products.
The initial product categories include:
- Cosmetics
- Ski wax
- Consumer clothing textiles
- Footwear
- Waterproofing agents for clothing textiles and footwear
The law provides specific exceptions, including certain protective and safety clothing and footwear.
A separate restriction applies from January 1, 2030 to textile products containing PFAS, subject to statutory exceptions for essential uses, national sovereignty and certain technical industrial textiles.
The legislation also provides for a residual PFAS concentration threshold below which the prohibitions do not apply. That threshold is established through the implementing decree.
What changed on January 1, 2026?
The most important point for manufacturers is that the French requirements are already operational.
The implementing decree entered into force on January 1, 2026. It establishes the rules for applying the product prohibitions and defines the residual concentration threshold and applicable exemptions.
The decree also provides a 12-month stock sell-through period for products manufactured before January 1, 2026.
This distinction matters when assessing legacy inventory.
A compliance team should therefore distinguish between:
Product manufactured before January 1, 2026
and
Product manufactured from January 1, 2026 onward.
The applicable treatment can differ depending on the product category and the conditions of the decree.
Which products are affected?
Cosmetics
PFAS-containing cosmetic products are within the products prohibited from manufacture, import, export and placing on the French market from January 1, 2026, subject to the applicable residual threshold and legal conditions.
Ski wax
PFAS-containing ski wax is also covered by the January 1, 2026 prohibition.
Clothing and footwear
The law covers consumer clothing textiles, footwear and waterproofing agents for clothing textiles and footwear from January 1, 2026.
There are exceptions for specified protective and safety products. The implementing decree defines products that benefit from the statutory exceptions.
Other textile products
A broader restriction applies from January 1, 2030 to textile products containing PFAS.
The law provides exceptions for:
- Essential uses
- Products contributing to national sovereignty where no substitute exists
- Certain technical industrial textiles
The applicable exemptions are subject to the conditions established in the legislation and implementing provisions.
What is the PFAS residual concentration threshold?
The French law does not simply prohibit every product in the covered categories whenever any PFAS is detected.
Article L.524-1 provides that the prohibitions do not apply where PFAS are present at or below a residual concentration defined by decree.
The implementing decree establishes the relevant threshold and defines how the requirements apply.
This makes PFAS concentration data important for product compliance.
A supplier declaration stating that PFAS are present is therefore not necessarily enough to determine whether a product can be placed on the French market.
The assessment may need to establish:
- Which PFAS are present
- Where they occur
- Their concentration
- Whether they are intentionally used
- Which product category applies
- Whether an exemption applies
- Whether the product was manufactured before or after the applicable date
What exemptions apply?
The French requirements include exemptions for specific products and uses.
The implementing decree identifies, among other categories, certain personal protective equipment and protective equipment intended for armed forces, internal security and civil protection. It also addresses waterproofing agents used to re-waterproof specified protective equipment.
The decree also provides an exception for clothing and footwear incorporating at least 20% post-consumer recycled material, subject to the conditions concerning residual PFAS in the finished product.
Manufacturers should therefore avoid treating the French law as a simple blanket ban.
The correct assessment is:
Product → category → PFAS status → concentration → exemption → effective date
What does this mean for product manufacturers?
The French law creates a product-level compliance requirement.
A manufacturer selling multiple products in France may need to identify:
- Which products fall within the regulated categories
- Which materials contain PFAS
- Which components or treatments introduce PFAS
- Relevant concentration information
- Supplier evidence
- Applicable exemptions
- Manufacturing dates
- French market status
This requires product data to be connected to chemical information.
For manufacturers already managing PFAS across multiple jurisdictions, the global PFAS regulatory landscape provides the wider context.
Why supplier data matters
PFAS information may not be available directly from the finished-product manufacturer.
It can sit with:
- Raw-material suppliers
- Component suppliers
- Textile suppliers
- Chemical suppliers
- Contract manufacturers
- Treatment providers
Supplier information can help establish whether PFAS are present, where they are used and what evidence supports the product assessment.
For the broader supplier-data workflow, see PFAS supplier chemical transparency.
The key is to connect the supplier response to the actual product.
Supplier → Material → Component → Product → France → PFAS requirement
A supplier declaration stored separately from the product record does not provide the same level of traceability.
How should manufacturers assess products for France?
A practical assessment can follow five steps.
1. Identify products sold in France
Create the population of products manufactured, imported or placed on the French market.
2. Map materials and components
Identify materials, treatments and components where PFAS may be relevant.
3. Collect supplier evidence
Request PFAS information from suppliers where internal records cannot establish the product's PFAS status.
4. Assess the French requirement
Determine:
- Product category
- PFAS status
- Concentration
- Applicable date
- Exemption status
- Market status
5. Maintain supporting evidence
Keep the supplier declarations, material information, test results and regulatory assessment supporting the final decision.
This approach is particularly important where the same component is used across several products.
France PFAS requirements and the wider EU PFAS restriction
France's national requirements should not be confused with the proposed EU-wide PFAS restriction under REACH.
The French law is a national measure with its own product categories, dates, thresholds and exemptions.
The EU PFAS restriction is a separate regulatory process.
For the broader European regulatory picture, see EU PFAS restriction: proposal, status and timeline.
A product manufacturer may therefore need to assess both:
France-specific requirements
and
EU-wide PFAS requirements applicable to the product and market.
Managing France PFAS compliance across products
For companies with large product portfolios, maintaining French PFAS compliance manually can become difficult when substance information, supplier declarations and product data sit in separate systems.
The compliance team needs to be able to answer:
- Which products contain PFAS?
- Which products are in the French market?
- Which suppliers have provided evidence?
- Which products fall within the restricted categories?
- Which products qualify for an exemption?
- Which products require additional testing or supplier follow-up?
- Which assessments need to be revisited when regulations change?
Regilient's PFAS compliance software connects PFAS identification and tracking with supplier data collection, product-level assessment, regulatory monitoring and compliance documentation.
This allows product compliance teams to connect:
Supplier data → material/component → product → regulation → market → compliance status → evidence
rather than managing each PFAS requirement as a separate spreadsheet exercise.
What should manufacturers do now?
For products sold in France, manufacturers should:
- Identify affected product categories.
- Review PFAS use in relevant materials and treatments.
- Collect missing supplier information.
- Confirm applicable concentration information.
- Check statutory exemptions.
- Review manufacturing and inventory dates.
- Document the compliance decision and supporting evidence.
- Monitor the French requirements alongside the wider EU PFAS regulatory process.
The key change is that French PFAS compliance is now an operational product-compliance requirement, not simply a future regulatory issue.
