On May 2, 2025, Denmark officially issued an administrative order prohibiting the use of perfluorinated and polyfluoroalkyl substances (PFAS) in clothing, footwear, and clothing and footwear waterproofing agents.
PFAS is a well-known chemical substance with strong environmental persistence, which can persist in the environment for decades to hundreds of years. Although the process of restricting PFAS within the EU is still ongoing, Denmark has followed France's example and implemented a ban on PFAS in clothing and footwear. This administrative order does not cover or affect PFAS substances that are currently subject to EU REACH regulations and POPs control. The following are the core contents of this ban and industry response suggestions:
1、 Core content of the ban
1. Scope of Control
Target product: Consumer oriented clothing, footwear, and waterproofing agents (total fluorine content)
When ≥ 50mg/kg).
Exemption scope:
Reuse and reutilization of clothing or footwear;
Personal protective equipment (PPE) used to protect users from specific risks in accordance with Annex I Risk Category III (a) or (c) of EU Regulation (EU) 2016/425;
PPE containing PFAS to protect consumer safety functions;
Waterproof agent for re impregnating the above PPE;
Medical equipment;
Transporting goods.
2. Testing standards
Total fluorine content threshold: According to the new regulations, if the total fluorine content of clothing, footwear, and waterproofing agents reaches or exceeds 50 milligrams per kilogram, importation and sale are prohibited. But if the fluorine content comes from non PFAS substances, it is not subject to this ban. In such cases, the Danish Environmental Protection Agency (EPA) may require relevant supporting documents to be provided.
3. Implementation schedule
Effective date: July 1, 2026.
Inventory sales transition period: until January 1, 2027, sales of existing inventory products are allowed.
2、 Industry compliance recommendations
1. Supply chain traceability and alternative solutions
Conduct a comprehensive review of the raw material supply chain and prioritize the use of materials without PFAS or that meet exemption criteria.
Accelerate the development of environmentally friendly waterproofing agents that can replace PFAS, such as bio based fluorine free materials or nanotechnology solutions.
2. Testing and certification system
Establish a fluorine content detection process to ensure that the total fluorine content of the product is below the threshold of 50mg/kg.
Prepare exemption proof documents in advance (such as PPE functional certification, medical equipment certification, etc.).
3. Inventory Management and Market Adjustment
Develop an inventory digestion plan and utilize the transition period to clear high fluoride content products.
For exempted products, clearly label and retain compliance records to avoid market confusion.
3、 Industry impact and outlook
Denmark's move provides a precedent for EU PFAS control and may accelerate the follow-up of other member states. Enterprises need to closely monitor the progress of the EU's PFAS restriction proposal and lay out green supply chains in advance to cope with stricter global regulations in the future.
