Per- and polyfluoroalkyl substances (PFAS) have been used in textiles for decades for their water-repellent and stain-resistant properties. They are in the durable water repellent (DWR) coatings on outdoor performance jackets, in waterproof footwear membranes, in stain-resistant upholstered furniture, and in a range of other consumer products. They are also persistent environmental contaminants that accumulate in human tissue and wildlife, do not biodegrade, and are increasingly subject to regulatory bans.
For fashion and outdoor brands, the PFAS regulatory landscape has moved from a watch-list item to an active compliance obligation. California, New York, and Maine have enacted PFAS restrictions on textiles. The EU is implementing broader PFAS restrictions through its chemicals regulation framework. And the product liability exposure from PFAS-containing products is growing through consumer litigation.
This article explains what PFAS are, which regulations apply to textile products, what compliance requires in practice, and how supply chain data connects to chemical compliance.
AT A GLANCE
California, New York, and Maine have enacted PFAS restrictions on textile products, with compliance dates now active or imminent. The EU is implementing broad PFAS restrictions through REACH and the Universal PFAS Restriction proposal, affecting any US brand selling into the EU market. PFAS compliance requires material-level data from chemical suppliers and manufacturers, not just a brand-level declaration. Outdoor and performance brands using DWR coatings and waterproofing membranes have the highest immediate exposure.
WHAT ARE PFAS AND WHY DO THEY MATTER FOR TEXTILES?
PFAS, or per- and polyfluoroalkyl substances, is a broad class of more than 10,000 synthetic chemical compounds characterised by strong carbon-fluorine bonds. This bond makes them exceptionally resistant to heat, water, oil, and chemical degradation – precisely the properties that made them valuable in textile finishing applications like durable water repellent coatings and waterproof membrane treatments.
The same chemical stability that makes PFAS useful in products also makes them persistent environmental contaminants. PFAS do not biodegrade under normal environmental conditions. They accumulate in soil, water, and biological tissue over time. Exposure has been associated with a range of health concerns including immune system effects, hormonal disruption, and elevated cancer risk. The US Environmental Protection Agency and European Chemicals Agency have both classified certain PFAS compounds as substances of very high concern.
For textiles, the most common PFAS applications are durable water repellent coatings applied to outdoor and performance garments and footwear, waterproof-breathable membrane treatments including fluoropolymer-based PTFE membranes, stain-resistant finishing on upholstered furniture and some apparel, and soil-release coatings on synthetic performance fabrics.
WHAT US STATE LAWS CURRENTLY APPLY TO PFAS IN TEXTILES?
Three US states have enacted PFAS restrictions on textile products, and the patchwork is growing.
California.
California's PFAS-in-textiles restriction prohibits the sale of textile articles containing PFAS above specified concentration thresholds. Outdoor apparel, rugs, and upholstery are covered. The law uses a class-based approach that restricts all PFAS rather than individual compounds, which has significant implications for brands that had replaced regulated PFAS compounds with chemically similar alternatives. California's approach means there is no safe harbour in switching to a shorter-chain PFAS variant.
New York.
New York's PFAS restrictions on apparel and other textile articles overlap substantially with California's approach. The class-based restriction covers similar product categories and applies to products sold in New York regardless of where they are manufactured or where the brand is headquartered.
Maine.
Maine has enacted broader PFAS restrictions covering textiles and other product categories. Maine's approach includes a reporting requirement for products containing intentionally added PFAS that predates its sales prohibition, giving brands a reporting obligation ahead of the sales ban.
Three US states have active PFAS restrictions on textiles using a class-based approach that restricts all PFAS, not individual compounds. Switching to shorter-chain PFAS variants does not create compliance – it creates a different compliance problem.
WHAT IS THE EU DOING ON PFAS?
The EU's approach to PFAS is broader and faster-moving than the US state-level patchwork. The European Chemicals Agency (ECHA) has been working on a universal PFAS restriction under REACH that would apply to all PFAS above de minimis concentrations across a wide range of product categories including textiles.
For US brands selling into the EU, the REACH PFAS restriction creates an obligation to understand the chemical composition of treated materials at a level most brands have not historically needed to track. REACH chemical compliance for DPP is also emerging as a requirement – EU DPP data fields are expected to include relevant substances of concern, which PFAS would qualify as under the applicable regulatory framework.
This EU-side development connects PFAS compliance to the DPP data infrastructure discussion. Brands building DPP capability that includes chemical compliance data fields will need supplier-level chemical substance data that can satisfy both REACH obligations and DPP data requirements. It is the same data need from two different regulatory angles.
WHAT DOES PFAS COMPLIANCE ACTUALLY REQUIRE IN PRACTICE?
PFAS compliance for textile brands requires action at the product and material level, not the brand level. A brand cannot simply declare itself PFAS-free without verifying the chemical inputs at each stage of production. Here is what the compliance process involves in practice.
Chemical supplier transparency.
The brand needs to know which chemical treatments are applied to its materials at the fabric and finishing stages. This requires suppliers to disclose the chemical inputs in their finishing processes — information that some suppliers have historically treated as commercially confidential. Compliance requires supplier engagement on chemical transparency, not just a contractual prohibition on PFAS.
Testing.
Because PFAS can appear in textiles as an unintended contaminant from water, soil, or equipment contamination as well as from intentional use, brand declarations alone are not sufficient. Regulatory frameworks typically require testing to verify PFAS absence or concentration levels below specified thresholds. Testing protocols need to be defined, and testing needs to be conducted by accredited laboratories.
Alternative chemistry validation.
Where brands are transitioning to PFAS-free alternatives — fluorine-free DWR chemistry, non-fluorinated waterproofing membranes — the alternative chemistry needs to be validated for performance and confirmed not to contain regulated substances. The class-based approach in state regulations means that not all fluorinated compounds are equivalent, and alternatives need to be verified against the specific restriction language in each jurisdiction.
Documentation and traceability.
Compliance with multi-jurisdictional PFAS restrictions requires documented evidence that can be produced to regulators or in litigation. This means maintaining supplier declarations, test reports, and chemical substance data at the product level, not just at the brand level. The documentation challenge is a supply chain data challenge.
WHY OUTDOOR AND PERFORMANCE BRANDS FACE THE HIGHEST EXPOSURE
Outdoor and performance brands face elevated PFAS compliance exposure for a straightforward reason: PFAS-based chemistry was central to the functional performance proposition that differentiates this segment. DWR coatings on waterproof-breathable garments, fluoropolymer membranes in hiking footwear, and stain-resistant treatments on pack fabrics were performance standards, not incidental product attributes.
Many outdoor brands have already begun transitioning to PFAS-free alternatives, driven by consumer expectations ahead of regulatory obligations. The regulatory obligation is now live in multiple jurisdictions, which means brands that have not completed the transition are in active non-compliance territory, not on a voluntary improvement timeline.
The performance question is real: fluorine-free DWR chemistry has historically performed below PFAS-based equivalents, particularly after repeated laundering. Consumer expectations for performance in technical outdoor products are high. But this is a product development and sourcing challenge, not a reason to delay compliance. The regulatory deadline is not contingent on performance parity.
FREQUENTLY ASKED QUESTIONS
What are PFAS and why are they used in textiles?
PFAS (per- and polyfluoroalkyl substances) are a class of over 10,000 synthetic chemicals characterised by strong carbon-fluorine bonds that resist heat, water, and degradation. In textiles, they are used primarily for durable water repellent coatings on outdoor garments, waterproof membrane treatments, and stain-resistant finishes. Their persistence in the environment and accumulation in biological tissue has driven increasing regulatory restrictions.
Which US states have banned PFAS in textiles?
California, New York, and Maine have enacted PFAS restrictions on textile products. All three use a class-based approach that restricts PFAS broadly, not individual compounds, meaning that switching from long-chain to short-chain PFAS variants does not achieve compliance. Additional states are monitoring these programmes and may introduce similar legislation.
Do the EU PFAS restrictions apply to US brands?
Yes, if the brand sells products in the EU market. REACH chemical restrictions apply to products placed on the EU market regardless of where they are manufactured or where the brand is headquartered. The universal PFAS restriction being developed under REACH would apply to US brands selling PFAS-containing textile products into the EU.
How does PFAS compliance connect to Digital Product Passport requirements?
EU DPP data requirements are expected to include relevant substances of concern for textiles, which PFAS would qualify as under EU regulatory definitions. Brands building DPP capability that includes chemical compliance data fields will need the same supplier-level chemical substance data that satisfies REACH PFAS obligations. The data need is the same from both regulatory angles.
What evidence do brands need to demonstrate PFAS compliance?
PFAS compliance evidence typically includes supplier chemical substance declarations confirming no intentional addition of PFAS, third-party laboratory test results confirming PFAS concentration below regulatory thresholds, and documentation of alternative chemistry specifications for transitioned products. The specific requirements vary by jurisdiction.
ABOUT TRUSTRACE
TrusTrace is the multi-regulatory supply chain and product compliance platform for global brands. Chemical compliance data, including PFAS and substance of concern tracking, connects to the same supplier data foundation that powers EUDR, UFLPA, and EU DPP compliance. Contact TrusTrace to understand how the platform maps to your organization's compliance requirements.
Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.
