A jacket, two journeys

Under the EU Textile Labelling Regulation (TLR, Regulation (EU) No 1007/2011), a textile product may only be made available on the EU market if it is labelled or marked with its fibre composition, and a label must be durable, easily legible and securely attached. The manufacturer, or the EU importer where the manufacturer is outside the EU, answers for supplying the label and for its accuracy; between businesses in the supply chain, commercial documents may replace or supplement the label.

LawEUPublications Office of the European Union (EUR-Lex)

The TLR label must give the name and percentage by weight of every constituent fibre in descending order, and where a product has textile components with different fibre contents, the content of each component. Components that are not main linings and weigh under 30% of the product need not be listed, so a jacket's label covers its outer fabric and main lining but may leave smaller textile parts unstated.

LawEUPublications Office of the European Union (EUR-Lex)

When fibre composition is worked out for the TLR label, finishing chemistry is expressly left out: 'impregnating products' and 'other textile processing products' are not taken into account, nor are non-textile parts. The label is designed to say 'polyester', not what the polyester was finished with, so a durable water-repellent (DWR) finish has no place on it by law.

LawEUPublications Office of the European Union (EUR-Lex)

Fibre composition must be clearly visible to the consumer before purchase, including when buying online, and the label must be in the official language or languages of the Member State where the jacket is sold to the consumer, unless that state provides otherwise. For a jacket sold in France the label must therefore be readable in French.

LawEUPublications Office of the European Union (EUR-Lex)

EU law does not require a textile label to carry care instructions, country of origin, allergenic substances or any electronic labelling. In the TLR these appear only as topics the Commission was asked to examine in a review report due by 30 September 2013.

LawEUPublications Office of the European Union (EUR-Lex)

A study for the Commission's Joint Research Centre (JRC) reports, citing the care-labelling association GINETEX (2017), that care instructions are mandatory in 12 EU Member States. France is not among those listed, so the care symbols on a jacket sold in France appear to be voluntary practice rather than a legal requirement.

InterpretationEU / FranceEuropean Commission, Joint Research Centre (JRC)

No proposal to revise the TLR had been published by 20 September 2026. The European Parliament's Legislative Train marks the file 'Blocked', citing a revision planned for the second quarter of 2026 that would introduce specifications for physical and digital labelling of textiles.

ProposalEUEuropean Parliament

Under REACH Article 33(1), any supplier of an article containing a substance of very high concern (SVHC) on the Candidate List above 0.1% weight by weight must give the recipient enough information for safe use, at least the substance name. The duty runs between EU supply chain actors: 'recipient' means a professional user or distributor and excludes consumers, and the information is only what is 'available to the supplier'.

LawEUPublications Office of the European Union (EUR-Lex)

A consumer gets SVHC information only by asking. Under REACH Article 33(2), any supplier of the article must, on a consumer's request, give at least the substance name, free of charge, within 45 days.

LawEUPublications Office of the European Union (EUR-Lex)

The Court of Justice ruled in 2015 (Case C-106/14) that the 0.1% threshold applies to each article that forms part of a complex product, not to the product as a whole. For a jacket, each constituent article (for example the outer fabric, the zip) is assessed separately, so dilution across the whole garment does not remove the duty to inform.

LawEUCourt of Justice of the European Union (via EUR-Lex)

On 23 October 2026 the REACH Candidate List of substances of very high concern includes several PFAS (per- and polyfluoroalkyl substances): PFOA and its ammonium salt, the C11 to C14 perfluorocarboxylic acids, PFNA, PFDA, PFHxS, PFHpA, PFBS, HFPO-DA, perfluamine and a fluorinated morpholine mixture. PFHxA is not on it, and there is no group entry for PFAS, so the SVHC information duties (Article 33, SCIP, France's AGEC mention) do not reach PFHxA or PFAS in general.

LawEUEuropean Chemicals Agency (ECHA)

The information duties and the restrictions work on scales 40,000 times apart. REACH Article 33 (and France's AGEC mention) start above 0.1% by weight, which is 1,000,000 parts per billion (ppb), while the PFHxA restriction starts at 25 ppb. A PFAS residue can make a jacket unlawful to sell long before any information duty would require anyone to name it.

InterpretationEU / FrancePublications Office of the European Union (EUR-Lex)

Older restrictions already cap long-chain PFAS in the jacket: since 25 February 2023, REACH Annex XVII entry 68 bars articles containing 25 ppb or more of C9 to C14 perfluorocarboxylic acids (PFCAs) and their salts, or 260 ppb or more of related substances. Like the PFHxA rule, this is a restriction with no information duty attached.

LawEUPublications Office of the European Union (EUR-Lex)

Since 5 January 2021, every EU supplier of an article must send the European Chemicals Agency (ECHA) the information it owes under REACH Article 33(1). ECHA holds it in the SCIP database and must give access to waste treatment operators and, on request, to consumers. This is the one route by which SVHC information from the point of sale is meant to reach sorters and recyclers; France transposed it in Code de l'environnement Article L. 521-5 III.

LawEU / FrancePublications Office of the European Union (EUR-Lex)

The Commission proposed on 10 December 2025 (COM(2025) 986) to end the duty to submit data to SCIP, saying the database 'is not fulfilling its intended objectives'; data already reported would be kept. At 23 October 2026 the European Parliament's procedure file shows the proposal awaiting a committee decision, with an indicative plenary date of 14 December 2026. Until it is adopted, the SCIP duty still applies.

ProposalEUEuropean Commission (via Publications Office Cellar)

Since 10 October 2026, REACH Annex XVII entry 79 (Commission Regulation (EU) 2024/2462) bars placing on the market textiles in clothing for the general public with 25 ppb or more of PFHxA (perfluorohexanoic acid) and its salts, or 1,000 ppb or more of PFHxA-related substances, measured in homogeneous material; the recitals name rain jackets. Jackets already placed on the market before that date are exempt, so the placing-on-the-market date becomes evidence the brand may need. The entry imposes no labelling or information duty.

LawEUOfficial Journal of the European Union (via Publications Office Cellar)

The EU-wide 'universal' PFAS restriction is still a proposal. ECHA's Risk Assessment Committee (RAC) adopted its final opinion on 2 March 2026 and the consultation on the Socio-Economic Analysis Committee (SEAC) draft opinion ran from 26 March to 25 May 2026. SEAC is expected to adopt its final opinion by the end of 2026, after which the Commission will propose a restriction for a vote by Member States in the REACH Committee.

ProposalEUEuropean Chemicals Agency (ECHA)

Under RAC's recommended conditions, the universal restriction would set limits of 25 ppb for any single PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymers, applying 18 months after entry into force. Where total fluorine exceeds 50 mg F/kg, the manufacturer, importer or downstream user would owe proof of the fluorine's origin to enforcement authorities on request. The only consumer statement, 'This product contains PFAS', is reserved for products that keep using PFAS under a derogation, and consumer apparel has none, so for this jacket the proposal would work as a ban without a label.

ProposalEUEuropean Chemicals Agency (ECHA)

SEAC's draft assessment names jackets as consumer apparel, lists fluorine-free alternatives in general practical use (dendrimers, hybrid silicone/hydrocarbons, hydrocarbons, polyurethane, silicones), and concludes there is 'overwhelming evidence' against claims that PFAS cannot be replaced in consumer apparel, with high substitution potential at entry into force.

ProposalEUEuropean Chemicals Agency (ECHA)

RAC agrees that mechanical recycling does not destroy PFAS and that only mixing with virgin, PFAS-free fibre lowers their concentration in recycled products. It notes that many PFAS-treated consumer textiles may enter normal textile recycling, and that no data exist on PFAS exposure of workers in textile recycling.

Technical findingEUEuropean Chemicals Agency (ECHA)

Since 1 January 2026, French law bans the manufacture, import, export and placing on the market of clothing textiles for consumers that contain PFAS (Loi n° 2025-188, Code de l'environnement Article L. 524-1). All textiles follow from 1 January 2030, with listed exceptions. Products below a residual value set by decree are outside the ban.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

France's implementing decree defines PFAS as a group, any substance with at least one fully fluorinated CF3 or CF2 carbon, the same structural definition RAC uses. It sets the residual values at 25 ppb for any single PFAS and 250 ppb for the sum of targeted PFAS (both excluding polymers), and 50 ppm for PFAS including polymers. Where total fluorine exceeds 50 mg F/kg, the person placing the product on the market must prove to the authorities, on request, whether that fluorine comes from PFAS.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

France exempts clothing and footwear containing at least 20% recycled material from post-consumer waste, provided any PFAS in the finished product is limited to the recycled fraction. The exemption only works if someone can show the recycled share and where the PFAS came from, information that originates at the sorting and recycling stages.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

Clothing containing PFAS that was manufactured before 1 January 2026 may be placed on the French market or exported for at most twelve months from that date. The sell-off window closes on 31 December 2026, and the manufacturing date becomes the evidence that matters.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

Under France's anti-waste law (AGEC, Code de l'environnement L. 541-9-1 and R. 541-227 to R. 541-229), producers and importers with over EUR 10 million turnover and at least 10,000 units a year must publish a free, machine-readable 'fiche produit' for each new consumer product, accessible at the time of purchase. Information on hazardous substances may instead be given through an app designated by ministerial order, and the sheet must stay available for two years after the last unit is placed on the market.

LawFranceAIDA (INERIS), consolidated reproduction of the Code de l'environnement

Where a hazardous substance is present above 0.1% by mass, the French product sheet must state 'contient une substance dangereuse' or, for a Candidate List substance, 'contient une substance extrêmement préoccupante', followed by the name of each substance. This turns REACH's on-request consumer right into published information for in-scope products.

LawFranceAIDA (INERIS), consolidated reproduction of the Code de l'environnement

France's 'hazardous substances' for AGEC are the Candidate List SVHCs plus substances of comparable concern listed by ministerial order. The only order found (30 August 2023) adds two substances, DIOP and resorcinol, so French consumer disclosure adds no PFAS beyond those on the Candidate List.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

For clothing sold in France, the AGEC product sheet must name the country where each of three steps mainly took place: weaving, dyeing and printing, and making-up. For this jacket that would show Vietnam (in the scenario), but finishing, including the water-repellent treatment, is not a named step, so the place where the DWR chemistry was applied need not be disclosed.

LawFranceAIDA (INERIS), consolidated reproduction of the Code de l'environnement

Where synthetic fibres make up more than 50% of a garment's mass, the French product sheet must carry the statement 'rejette des microfibres plastiques dans l'environnement lors du lavage' (releases plastic microfibres into the environment when washed). A polyester rain jacket meets that condition.

LawFranceAIDA (INERIS), consolidated reproduction of the Code de l'environnement

A French law of 8 July 2026 (Loi n° 2026-602) requires the places of manufacture of clothing sold online to be shown clearly on the platform, in type the same size as the price and next to it.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

The Ecodesign for Sustainable Products Regulation (ESPR, Regulation (EU) 2024/1781) requires future product rules to let 'substances of concern' be tracked through the product's life: name, location in the product, concentration or range, safe-use instructions and end-of-life information, given on the product or through a data carrier on it. 'Substance of concern' is wider than the Candidate List, covering certain hazard classes, persistent organic pollutants and substances that hinder reuse and recycling. None of this binds a jacket until a textile delegated act is adopted.

LawEUPublications Office of the European Union (EUR-Lex)

The Commission's first ESPR working plan (April 2025) ranks textiles and apparel first among final products, with indicative adoption of the delegated act in 2027, and says its information requirements will work with the Textile Labelling Regulation, then under review.

ProposalEUEuropean Commission (via Publications Office Cellar)

A study for the JRC (13 May 2026) recommends that a textile digital product passport (DPP) give substance-of-concern data per batch, covering all chemicals for every colour in the batch. The substance identity and concentration would be public, while the substance's location in the garment and end-of-life handling information would be limited to actors with a 'legitimate interest'. Substances not intentionally added and absent from the final product would be exempt. It is a recommendation, not a draft act, and it does not mention PFAS.

ProposalEUEuropean Commission, Joint Research Centre (JRC)

Stakeholders interviewed for the JRC study report that apparel brands and retailers rely on supplier declarations, contract terms and third-party certification to support claims that regulated substances are absent. OEKO-TEX Standard 100 is the most cited mechanism and works as a pass or fail against thresholds. Substance-level concentration and location data are not reported and, they say, are not available in a form that could be disclosed reliably.

Reported practiceEU (reported practice across global supply chains)European Commission, Joint Research Centre (JRC)

The General Product Safety Regulation (GPSR, Regulation (EU) 2023/988), applying since 13 December 2024, requires a consumer product to carry a type, batch or serial number, and the name, postal and electronic address of the manufacturer and, for imports, of the importer, on the product or, where that is not possible, on packaging or an accompanying document. This gives the jacket an identity key back to the operators who hold its records, though it carries no chemical information, and technical documentation goes to authorities only on request.

LawEUPublications Office of the European Union (EUR-Lex)

Viet Nam's Law on Chemicals requires every producer or importer of a chemical, not only of a hazardous one, to classify it under the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) and label it before it is used or sold. Information also has to travel back up the chain: any business handling the chemical that finds a new hazard must promptly tell the producer or importer so that it reclassifies and relabels.

LawViet NamVăn phòng Quốc hội (Office of the National Assembly), via Government e-documents portal

A Vietnamese seller of a hazardous chemical must give the buyer a safety data sheet (SDS, 'phiếu an toàn hóa chất'), and the buyer must ask for it and keep it where the chemical is stored. The law also says the SDS and the chemical's trade name cannot be kept confidential. The SDS duty attaches only to chemicals that meet the legal definition of hazardous, so a finishing agent with no GHS hazard class carries no statutory SDS duty.

LawViet NamVăn phòng Quốc hội (Office of the National Assembly), via Government e-documents portal

For a mixture such as a DWR emulsion, the Vietnamese SDS template asks only for the identity and concentration range of hazardous components above the set thresholds, and says trade-secret (confidential business information, CBI) rules take priority when listing composition. A non-hazardous fluorinated or fluorine-free polymer need not appear, so the SDS a mill receives may not show whether the finish is PFAS-based.

LawViet NamBộ Công Thương (Ministry of Industry and Trade, MOIT), Công báo (Official Gazette) No. 319

A drum of finishing agent sold in Viet Nam must carry a Vietnamese-language label showing, among other items, its composition or quantitative composition, its chemical identification code if any, hazard pictograms, signal word and hazard statement if any, precautions and instructions for use and storage.

LawViet NamChính phủ (Government of Viet Nam), via the Official Gazette site

Viet Nam's import declaration for chemicals, which requires the SDS to be filed through the National Single Window before customs clearance, covers only goods in chapters 28 and 29 of the tariff nomenclature (inorganic and organic chemicals). Mixtures classed outside those chapters are exempt even if they contain chapter 28 or 29 chemicals.

LawViet NamChính phủ (Government of Viet Nam)

Interpretation: a DWR emulsion sold as a textile finishing preparation would ordinarily fall under Harmonized System (HS) heading 38.09 'finishing agents ... of a kind used in the textile ... industries' (or chapter 39 if presented as a polymer in primary form), not chapters 28 or 29. If so, its import into Viet Nam is exempt from the chemical import declaration, so the Vietnamese-language SDS field on that declaration does not reach it.

InterpretationInternational (HS nomenclature) applied to Viet NamWorld Customs Organization (WCO)

The Law on Chemicals separately obliges anyone engaged in chemical activities to give the authorities and users full and accurate information on the content of hazardous chemicals in chemicals and in products containing them. This is a general information duty towards users, but the law does not say how, when or in what form it is met.

LawViet NamVăn phòng Quốc hội (Office of the National Assembly), via Government e-documents portal

Workers who handle chemicals directly must receive chemical safety training at least every two years, with a first cycle of at least 8 hours. The training must cover the hazardous properties and SDSs of the site's hazardous chemicals, classification and labelling, and practice in recognising hazardous chemicals by their labels and pictograms.

LawViet NamChính phủ (Government of Viet Nam), via the Official Gazette site

Under Viet Nam's Occupational Safety and Health (OSH) Law, workers have a right to full information about hazardous and harmful factors at the workplace and the preventive measures, and to OSH training. Employers must inform workers about those factors, and manufacturers must supply safety information with products that may be unsafe at work. Warning signs and instructions for substances with strict safety requirements must be in Vietnamese and in the language the workers commonly use, placed where they are easy to read and see.

LawViet NamVăn phòng Quốc hội (Office of the National Assembly), Công báo Nos 1169+1170 and 1171+1172

Viet Nam lists PFOS (perfluorooctane sulfonic acid, with its sulfonates, sulfonamides and sulfonyls) and PFOA (perfluorooctanoic acid) and PFHxS (perfluorohexane sulfonic acid), each with salts and related compounds, as Group 2 'specially controlled chemicals' under the Stockholm and Rotterdam conventions. A mixture is specially controlled if it contains more than 1% by weight of one of them. These are the only per- and polyfluoroalkyl substances (PFAS) entries we found; there is no PFAS group listing.

LawViet NamChính phủ (Government of Viet Nam), via the Official Gazette site

Viet Nam registered a Stockholm Convention specific exemption for PFOA in 'textiles for oil and water repellency for the protection of workers from dangerous liquids'. The register shows it expired on 3 December 2025. Viet Nam's only active PFOA exemption is for perfluorooctyl iodide used to make perfluorooctyl bromide, so no PFOA exemption for textiles remains open to it. In the same register, the Government of Viet Nam gave as its reason that PFOA was still used in Viet Nam in several fields including textiles (an undated government statement, not measured data).

LawInternational (Viet Nam entry)Secretariat of the Basel, Rotterdam and Stockholm Conventions

The Stockholm Convention's listing of long-chain perfluorocarboxylic acids (PFCAs, C9 to C21), their salts and related compounds (decision SC-12/12) was communicated to Parties on 16 December 2025. Under Article 22 it enters into force one year after that communication for every Party that has not refused it or made an Article 25(4) declaration, which on the current record would include Viet Nam. Viet Nam's chemical lists do not yet include these substances.

LawInternational (applies to Viet Nam)United Nations Treaty Collection

Viet Nam's Law on Environmental Protection bans producing, exporting, importing and using persistent organic pollutants (POPs) in Stockholm Annex A, and goods containing them above the legal maximum, unless an exemption is registered. It also requires source control, information disclosure, labelling and conformity assessment for POPs and for goods containing them.

LawViet NamQuốc hội (National Assembly), Công báo Nos 1185+1186 (25 December 2020)

Viet Nam's environmental decree requires anyone importing, producing or trading goods containing POPs to label them with the POP's name and content, or with compliance with a relevant international standard. That duty is keyed to a national technical regulation on POP limits in goods, which we could not confirm has been issued. Whether it binds a PFOA-treated fabric today is unresolved.

LawViet NamBộ Nông nghiệp và Môi trường (Ministry of Agriculture and Environment)

Viet Nam has a product-level disclosure regime for hazardous chemicals in goods, but the Ministry of Industry and Trade's list of chemicals whose presence in products must be disclosed has 10 entries (acetone, cadmium, chromium VI compounds, formaldehyde, hydrochloric acid, lead, mercury, methanol, sulphuric acid and toluene), each tied to products such as glue, cleaners, plywood, batteries and electronics. No textile product and no PFAS is listed.

LawViet NamBộ Công Thương (Ministry of Industry and Trade, MOIT), Công báo (Official Gazette) No. 319

Where the product-disclosure regime does apply, it requires positive information: before sale, the producer or importer declares for each lot the product name, the hazardous chemical's name, its hazard, its content and the field of use on the national chemicals database, and publishes composition and content on its website or at the point of sale and on the product label.

LawViet NamChính phủ (Government of Viet Nam)

Viet Nam's technical regulation for textiles, QCVN 01:2017/BCT as amended in 2026, limits formaldehyde (30, 75 or 300 mg/kg by product group) and each aromatic amine released from azo dyes (30 mg/kg) in textile products before they go on the Vietnamese market. It sets no limit or information duty for PFAS or water-repellent finishes.

LawViet NamBộ Công Thương (Ministry of Industry and Trade)

Viet Nam's labelling decree sends export goods to the importing country's rules. Labels on exported goods follow the law of the importing country, contracts and treaties, and goods made only for export need not meet the rules for goods sold in Viet Nam. The Vietnamese textile label (composition, specifications, warnings, use and care instructions, year of manufacture) is therefore not required on a jacket made only for France.

LawViet NamChính phủ (Government of Viet Nam), via the Official Gazette site

The Zero Discharge of Hazardous Chemicals (ZDHC) Manufacturing Restricted Substances List (MRSL), version 3.1, does not permit any chemical formulation based on, or including, per- and polyfluoroalkyl substances (PFAS) for fashion, sport or outdoor clothing. A PFAS formulation is always deemed non-conformant, even for technical end uses that may need it, so a fluorinated durable water-repellent (DWR) agent for this jacket cannot be ZDHC-conformant.

Voluntary standardInternationalZDHC Foundation (copy hosted by Lindex Group)

The MRSL enforces its PFAS rule through a short list of marker substances rather than the whole class. ZDHC-approved certifiers test DWR formulations against limits in micrograms per kilogram of formulation (for example perfluorooctanoic acid (PFOA) 25 µg/kg; 6:2 fluorotelomer alcohol 1000 µg/kg) and may, at their discretion, screen for total fluorine with a quantification limit of 50 mg/kg.

Voluntary standardInternationalZDHC Foundation (copy hosted by Lindex Group)

The ZDHC ChemCheck report, which ZDHC says chemical formulators should share with customers, identifies a DWR product by organisation, product name, product ID and classification, and states its MRSL conformance level, MRSL version, certification body and certificate dates. Its listed contents include no Chemical Abstracts Service (CAS) numbers or composition: chemical supplier to mill, this channel passes a product name plus a conformance level, not chemical identity.

Voluntary standardInternationalZDHC Foundation

Since November 2025, chemical formulators can print a ZDHC QR code on drums or packaging. A mill worker who scans it, without logging in, sees product name, product ID, status, expiry, MRSL conformance level, Chemicals to Zero level, substrate and use category, enough to check conformance on delivery. The listed fields include no composition and no hazard or handling information.

Voluntary standardInternationalZDHC Foundation

ECO PASSPORT by OEKO-TEX certifies textile and leather chemicals, colourants and auxiliaries, such as a DWR agent. It is a chemical product certification, not a digital product passport. ZDHC recognises it as MRSL 3.1 conformance level 1, or level 2 with an on-site visit. However, formulation details given to OEKO-TEX stay confidential, and the mark does not guarantee that treated fabric will meet STANDARD 100.

Voluntary standardInternationalOEKO-TEX AG

AFIRM's PFAS phase-out guidance asks material suppliers, such as a finishing mill, to tell downstream customers when a material is water-repellent and what type of treatment (finish, coating, membrane or other) is used, and to collect and share safety data sheets (SDSs) and technical data sheets (TDSs). Because PFAS not classified as hazardous might not appear on an SDS, it recommends written confirmation from chemical suppliers that formulations are not PFAS-based.

Voluntary standardInternationalAFIRM Group

AFIRM publishes its 2026 RSL and its PFAS phase-out guidance in Vietnamese. The Vietnamese RSL carries the PFAS limits and a note that French Decree No. 2025-1376 on PFAS risks entered into force on 1 January 2026, so the French market rule is signposted in the mill's own language at the production end of the chain.

Voluntary standardInternational (Vietnamese edition; refers to France)AFIRM Group

A finishing mill's monthly ZDHC Performance InCheck report summarises the MRSL conformance of its whole chemical inventory, and brands connected to the mill on the ZDHC Gateway can review it. This channel runs straight from mill to brand. It reports facility-wide inventory conformance, not which chemicals went into a given fabric roll, and the garment factory is not a named recipient.

Voluntary standardInternationalZDHC Foundation

In June 2026 ZDHC said PFAS have no place in standard manufacturing and that its immediate focus is intentionally used PFAS in inputs. It acknowledged that newer test methods and broader definitions now find PFAS in some finished articles made with formulations previously considered compliant. ZDHC promised MRSL-related updates and a fuller PFAS communication, including how information should be communicated, for October 2026. None was found on ZDHC's news page on 23 October 2026.

Voluntary standardInternationalZDHC Foundation

For finished articles, the BSSL (bluesign System Substances List) bans intentional use of PFAS. It checks this against 50 mg/kg total fluorine (TF), a limit that also covers fluoropolymers such as PTFE (polytetrafluoroethylene), and against 25 µg/kg per substance and 250 µg/kg in sum for non-polymer PFAS. A TF result at or above 50 mg/kg requires a review of the chemical formulation, safety data sheet (SDS), technical data sheet (TDS) and other supply-chain records.

Voluntary standardInternationalbluesign technologies ag (an SGS company)

The bluesign system is run by bluesign technologies ag, an SGS company. In 2026 it replaced bluesign APPROVED and bluesign PRODUCT with one mark, bluepass, whose claims 'refer to processes, not to the product itself being certified'. A chemical supplier may give brands the hangtag wording 'bluepass fluorine-free water repellent'. The brand must verify the certified component by its bluesign Guide ID, and cannot call the jacket bluepass certified unless every component meets the thresholds.

Voluntary standardInternationalbluesign technologies ag (An SGS Company)

OEKO-TEX's current restricted substances list (RSL, version 03.2026) marks PFAS 'n.i.u.' (no intentional use). It also sets test limits for STANDARD 100 in every product class: 25 µg/kg for each PFAS, 250 µg/kg for their sum and 50 mg/kg total fluorine. For water repellents certified under ECO PASSPORT, the limits are 50 mg/kg total fluorine and 25 µg/kg for PFAS, and 'restrictions are not possible'.

Voluntary standardInternationalOEKO-TEX

A STANDARD 100 certificate covers only the articles and components described in its scope, in their as-produced state, for one year. The mark 'is not a quality label', and the certificate number lets anyone check online which criteria applied. From 2026, renewal requires every supplier that does wet or chemical processing, such as the DWR finishing mill, to hold a certificate for that product, and requires upstream certificates from the direct supplier. Both rules have a transition period until June 2027.

Voluntary standardInternationalOEKO-TEX (OEKO-TEX Service GmbH)

AFIRM separates claims about water-repellent products. 'Water-resistant, -repellent, or -proof' means the product may contain PFAS. 'No PFAS-based DWR finishing' cannot rule out a PFAS membrane such as polytetrafluoroethylene (PTFE). 'No intentional use of PFAS' allows contamination to be detected. Only 'no intentional use of PFAS, and PFAS not detected' covers both, and AFIRM strongly discourages 'free' claims.

Voluntary standardInternationalAFIRM Group

AFIRM says no single test both shows compliance with all PFAS rules and proves PFAS were not intentionally used. Total fluorine screening cannot distinguish PFAS from inorganic fluorine, and its best common detection limit is about 20 ppm. Targeted analysis of named PFAS is no guarantee that PFAS were not used. Untreated apparel can show several hundred ppm total fluorine, compared with several thousand ppm typically seen after intentional treatment.

Voluntary standardInternationalAFIRM Group

A Nordic Council of Ministers study, submitted to the Strategic Approach to International Chemicals Management (SAICM, predecessor of the Global Framework on Chemicals), drew on interviews mainly with brand owners. It found that textile supply-chain chemical information is mainly SDSs and test reports of variable quality, and mostly 'negative information' about absence rather than which chemicals were used. Exact composition is often withheld as a trade secret, test reports may not state methods or detection limits, and inventories cannot show per-batch use.

Reported practiceInternationalSAICM secretariat; study funded by the Nordic Council of Ministers, submitted by Sweden

In 2025 Vietnam was the second-largest supplier from outside the EU, after China, of synthetic-fibre anoraks and wind-jackets imported into the EU (CN 6201 40 and 6202 40). Those imports were worth €733 million, about 12% of extra-EU imports of these goods, against about 6% of all woven apparel (CN chapter 62). France imported €67 million of these goods directly from Vietnam.

Technical findingEUEurostat (Comext)

The waterproof membrane laminated into many rain jackets is polytetrafluoroethylene (PTFE), often in expanded form (ePTFE). The Swedish Chemicals Agency (KEMI) classes PTFE as a fluoropolymer within the per- and polyfluoroalkyl substances (PFAS) group, so a jacket can contain PFAS in its membrane whatever chemistry is used for the durable water-repellent (DWR) finish.

Technical findingInternationalSwedish Chemicals Agency (KEMI)

EU law already uses the Organisation for Economic Co-operation and Development (OECD) structural definition of PFAS: any substance with at least one fully fluorinated methyl (CF3) or methylene (CF2) carbon atom. PTFE, built from repeating CF2 units, and side-chain fluorinated DWR polymers both fall within it. The definition names a group, not an exact substance.

LawEUEuropean Commission (Official Journal of the European Union)

The waterproof layer of a rain jacket can be a microporous membrane of PTFE or polyurethane (PU), or a non-porous hydrophilic membrane of PU or polyester. A DWR finish is applied to the outer fabric of all shell garments whichever membrane is used, so the finish and the membrane raise separate chemical questions.

Technical findingInternationalUniversity of Leeds (White Rose eTheses Online)

In all-weather clothing, fluorine can come from two places: a porous PTFE membrane and an outer nylon or polyester fabric treated with side-chain fluorinated polymers (SFPs). KEMI reports that the volatile fluorotelomer alcohols (FTOHs) found in clothing come from the SFP finish, not the membrane, and puts PFAS at about 2 to 3 per cent of fibre weight in treated textiles.

Technical findingInternationalSwedish Chemicals Agency (KEMI)

The DWR finish is applied at the finishing mill, after dyeing or printing and before garment making, as a thin film by a pad-dry-cure process together with other finishing auxiliaries, then cured in an oven at up to 180°C. The mill is therefore the last actor in the chain to handle the finish as a chemical mixture; from H2 onwards it travels as part of a treated fabric.

Technical findingInternationalDanish Environmental Protection Agency

A chain-length description such as 'C6' describes the intended chemistry of an SFP product, not its full content. KEMI reports an industry figure of under 0.01 per cent C8 residue in C6 products alongside studies finding large contents of C8 and longer chains in products marketed as 'C6', and notes that SFPs can contain or degrade to FTOHs and to perfluorinated carboxylic acids such as perfluorooctanoic acid (PFOA) and perfluorohexanoic acid (PFHxA).

Technical findingInternationalSwedish Chemicals Agency (KEMI)

Fabric coated with an SFP-based DWR can carry unreacted residues and impurities, the DWR emulsion itself mixes polymers with shorter and longer side chains, and ageing of coated fabric increased the measured perfluoroalkyl acids (PFAAs). The chemistry on a jacket at sale or at collection is not the same as the chemistry in the finishing bath.

Technical findingInternationalEnvironmental Science & Technology (American Chemical Society)

Researchers comparing DWR chemistries coated their own fabrics because, for commercial outdoor clothing, it is often unknown which DWR chemistry and other additives were applied. Even specialists could not rely on information travelling with commercial garments to tell which finish they carried.

Technical findingInternationalEnvironmental Science & Technology (American Chemical Society)

Fluorine-free DWRs can provide water repellency, but a Danish Environmental Protection Agency (Danish EPA) survey found none that repel oil, alcohol or oil-based dirt as PFAS-based finishes do. Water repellency is therefore not evidence of PFAS; strong oil repellency points towards fluorinated chemistry but is not a test for it.

Technical findingInternationalDanish Environmental Protection Agency

'Fluorine-free' does not mean 'hazard-free'. A 2016 review found that impurities or degradation products of every DWR chemistry reach the environment, ranked hydrocarbon DWRs as the most environmentally benign followed by silicone and then SFP-based chemistries, and found hazard data lacking for dendrimer and nanoparticle finishes. This is a hazard ranking, not a product-specific exposure or risk conclusion.

Technical findingInternationalEnvironment International (Elsevier)

The Danish EPA found the compositions of alternative water-repellent agents mainly confidential, with some containing isocyanates, dipropylene glycol, metal salts or other unspecified substances. It found hardly any information on the trace raw materials, intermediates and degradation products left in finished textiles.

Reported practiceInternationalDanish Environmental Protection Agency

Supplier information for alternative water-repellent agents summarised by the Danish EPA described ingredients only as 'an unknown functionalized polymer' or 'an unknown organic silicon compound' with concentration ranges, and producers' statements that products need no environmental classification could not be verified. A record like this tells the mill a polymer is present but not what it is.

Reported practiceInternationalDanish Environmental Protection Agency

Under the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS), a mixture's safety data sheet (SDS) must give the identity and concentration of ingredients that are hazardous within GHS and present above cut-off levels: 1 per cent for most classes, 0.1 per cent for sensitisers, carcinogens, reproductive toxicants and category 1 mutagens. Listing non-hazardous ingredients is optional, and the cut-off table has no class for persistence, so an unclassified polymer need not appear.

LawInternationalUnited Nations

GHS lets national rules on confidential business information override ingredient identification on an SDS, provided this does not compromise the health and safety of workers or consumers or the protection of the environment. Where identity is withheld, the SDS should say that composition information was omitted.

LawInternationalUnited Nations

In the EU, the SDS for a mixture that is not itself classified must still list substances hazardous at 1 per cent or more, and substances at 0.1 per cent or more that are persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), on the Candidate List of substances of very high concern, or endocrine disruptors. Unclassified substances, including most polymers, may be listed but need not be.

LawEUEuropean Commission (Official Journal of the European Union)

Taken together, an SDS for a DWR agent does not necessarily reveal whether the finish is fluorinated. Polymers are exempt from REACH registration, SDS rules require only classified ingredients above cut-offs to be named, and confidentiality rules can withhold identity, so an unclassified side-chain fluorinated polymer, or residual PFAS below cut-offs, can be absent from SDS section 3.

InterpretationInternationalEuropean Environment Agency

EU classification rules gained new hazard classes in 2023, including persistent, mobile and toxic (PMT) and very persistent, very mobile (vPvM). Substances placed on the market before 1 May 2025 must be classified against them by 1 November 2026, and a mixture containing 0.1 per cent or more of a PMT or vPvM component must be classified from 1 May 2026, or by 1 May 2028 if already on the market.

LawEUEuropean Commission (Official Journal of the European Union)

The European standard EN 17681-1:2025 measures a defined target list of PFAS in textiles by liquid chromatography with tandem mass spectrometry (LC-MS/MS). It does not measure side-chain fluorinated polymers directly: alkaline hydrolysis releases degradation products such as PFOA or fluorotelomer alcohols, from which the polymers' contribution is inferred against limits for PFOA and C9 to C14 PFCA-related substances.

Voluntary standardEUEuropean Committee for Standardization (CEN), via the Estonian Centre for Standardisation (EVS) catalogue

Its companion, EN 17681-2:2022, uses gas chromatography for selected volatile PFAS such as fluorotelomer alcohols, and both parts are needed to cover PFOA-related substances. The standard notes that deciding whether side-chain polymers are intentionally present may need an alkaline hydrolysis step that it does not yet include.

Voluntary standardEUEuropean Committee for Standardization (CEN), via the Estonian Centre for Standardisation (EVS) catalogue

Total fluorine methods find fluorine that targeted tests miss but cannot say what it is. Combustion ion chromatography (CIC) cannot distinguish organic from inorganic fluorine or identify compounds, and can lose volatile compounds; particle-induced gamma-ray emission (PIGE) measures a surface at sensitivities of 68 to 238 parts per million and also cannot separate organic from inorganic fluorine. There are no standard methods for total fluorine or total organic fluorine in environmental samples.

Technical findingInternationalAnalytical and Bioanalytical Chemistry (Springer)

Other screening methods have blind spots too. Extractable organic fluorine (EOF) is underestimated when compounds are lost during solid-phase extraction. The total oxidisable precursor (TOP) assay converts only some precursors into measurable acids, leaves terminal acids unchanged and gives no speciation, and high-molecular-weight fluoropolymers are often missed by both LC-MS/MS and the TOP assay. Each method answers a different question, and none alone establishes 'PFAS-free'.

Technical findingInternationalAnalytical and Bioanalytical Chemistry (Springer)

When papers and textiles treated with PFAS were measured for total fluorine by PIGE, targeted volatile and ionic PFAS accounted for at most 2.2 and 0.41 per cent of it, and most fluorine stayed in the material after solvent extraction. A clean result on a targeted list can therefore coexist with substantial non-extractable fluorine.

Technical findingInternationalEnvironmental Science & Technology (American Chemical Society)

In multi-layer firefighter garments, the PTFE moisture-barrier film carried by far the highest total fluorine (122,000 milligrams of fluorine per kilogram), and researchers needed layer-by-layer testing plus pyrolysis gas chromatography-mass spectrometry (py-GC/MS) to tell PTFE film from SFP-finished fabric. By analogy, a total fluorine result on a whole laminated rain-jacket fabric cannot say whether the fluorine comes from the DWR or the membrane.

Technical findingInternationalEnvironmental Science & Technology (American Chemical Society)

Reporting limits differ by orders of magnitude between methods. In a study of 93 children's products, total fluorine screening had a detection limit of 10 parts per million and is biased low for heavily fluorinated material, while targeted PFAS had quantification limits of 1.11 to 26.6 nanograms per gram (parts per billion). The authors also found that products labelled waterproof may contain PFAS even where a physical barrier gives the water resistance, and that 'green' assurances did not reliably indicate absence of PFAS.

Technical findingInternationalEnvironmental Science & Technology (American Chemical Society)

In a 2026 study of products mainly from the Swiss market chosen for water- or grease-proofing, total fluorine was detected in 87 per cent of 15 textiles while every targeted PFAS was below 165 parts per billion. A modified TOP assay, which converts oxidisable precursors including side-chain fluorinated polymers, raised targeted PFAS in textiles by a factor of 1,300 on average and, across all products, showed a significant share of samples with precursors yielding PFHxA above a 1,000 ppb threshold that direct targeted testing did not reveal.

Technical findingInternationalChemosphere (Elsevier)

Sixteen outdoor jackets bought in 2011 and 2012 contained PFAS at 0.03 to 719 micrograms per square metre, with PFOA in all of them. After 3.5 years of sealed storage, four jackets kept only 10 to 20 per cent of their initial 8:2 FTOH while PFOA rose, so a test result describes the garment on the day it was tested.

Technical findingInternationalChemosphere (Elsevier)

Until 2025 there was no certified reference material (CRM) for PFAS in textiles. The first, for 18 PFAS in an outdoor textile, was produced by Germany's Federal Institute for Materials Research and Testing (BAM) for quality control of methods such as EN 17681-1, so laboratories had no certified textile benchmark for these results before then.

Technical findingInternationalAnalytical and Bioanalytical Chemistry (Springer)

On the care labels of 17 outdoor jackets on sale in 2015 and 2016, none stated the DWR chemistry. Some named the membrane, as a fabric 'with a PTFE membrane' or as an ePTFE or PTFE percentage in the fibre composition, so membrane identity can travel on the label while finish chemistry does not. Swing tags were left out because they are easily removed after purchase.

Reported practiceUnited Kingdom and Germany (jackets sampled in shops)University of Leeds (White Rose eTheses Online)

In a 2019 study for the Dutch government of 10,901 post-consumer garments, 24 per cent had no label, a figure that counted visibly cut-out labels as 'no label'. Most recyclers consulted said they do not rely on label composition declarations, partly because labels are often no longer present or legible when material reaches them.

Reported practiceNetherlandsCircle Economy, for the Netherlands Ministry of Infrastructure and Water Management (published as parliamentary annex blg-930139)

In the same study, only 59 per cent of readable labels matched the fibre composition found: 77 per cent for single-fibre garments, 41 per cent for multi-fibre garments and 23 per cent for cotton-polyester blends. Accuracy was judged against the sorting machine's near-infrared (NIR) categorisation, not laboratory analysis.

Reported practiceNetherlandsCircle Economy, for the Netherlands Ministry of Infrastructure and Water Management (published as parliamentary annex blg-930139)

Because it relies on NIR, the Fibersort automated sorting system used in the Dutch study can sort only monomaterial garments, meaning those with a composition homogeneous across the whole product, and therefore only single-layer garments. A laminated rain jacket falls outside what such a system can sort by fibre.

Technical findingNetherlandsCircle Economy, for the Netherlands Ministry of Infrastructure and Water Management (published as parliamentary annex blg-930139)

NIR recognition reads the surface facing the analyser. In an automated sorting-line study, coatings and finishes caused mismatched recognition depending on which side faced the NIR analyser, very thin fabrics let NIR pass through, and ageing changed spectra. NIR identifies fibre type; it is not a test for DWR chemistry, and for a laminate the reading may depend on which face is scanned.

Technical findingInternationalRecycling (MDPI)

In a 2025 study of 1,682 post-consumer textile items from residual waste in Catalonia, quantitative fibre composition by NIR agreed with the ISO 1833 laboratory method in only 37.9 per cent of cases, which the authors attribute to the limits of automated techniques for fibre blends.

Technical findingSpainTextiles (MDPI)

The European Environment Agency (EEA) finds that by the end-of-life stage any information on PFAS content in a textile has usually been lost, that chemical analysis to find PFAS-containing textile waste is expensive and generally not feasible, and that visual inspection does not work. It suggests sorting based on digital product information or X-ray fluorescence (XRF), at high cost if done at scale.

Technical findingEUEuropean Environment Agency

The EEA reports that, apart from a few PFAS identified as substances of very high concern, information on the presence and type of PFAS in textiles made outside the EU and sold in it is often extremely difficult to obtain. It gives three reasons: REACH registration does not extend to polymers or finished articles; suppliers may lack technical understanding and find requirements hard to pass up the chain; and suppliers hesitate to disclose.

Reported practiceEUEuropean Environment Agency

The EU Waste Framework Directive (WFD), as amended in 2018, required Member States to set up separate collection of textiles by 1 January 2025. The duty names a material category only. Nothing about the item's materials or chemistry has to accompany it, so the jacket can enter a textile collection point carrying only its sewn-in label.

LawEUEuropean Parliament and Council of the European Union (OJ L 150, 14.6.2018, p. 109)

The 2025 textile amendment to the Waste Framework Directive (WFD) requires producer responsibility organisations (PROs) under extended producer responsibility (EPR) to collect used textiles 'regardless of their nature, material composition, condition, name, brand, trademark or origin'. Collection is designed so that the person handing over the jacket has to supply no information.

LawEUEuropean Parliament and Council of the European Union (OJ L series 2025/1892, 26.9.2025)

Under the 2025 amendment to the Waste Framework Directive (WFD), separately collected used textiles are 'considered to be waste upon collection'. The exception is an item handed over directly by the end user and professionally assessed as fit for re-use at the collection point by a re-use operator or social economy entity. At H5, the jacket's legal status turns on a trained person's inspection, not on any record that travels with it.

LawEUEuropean Parliament and Council of the European Union (OJ L series 2025/1892, 26.9.2025)

The operative text of the 2025 textile amendment to the Waste Framework Directive (WFD) mentions substances once, in a duty to screen collected textiles 'to identify and remove non-target items or materials or substances that are potential sources of contamination'. A search of the operative articles found no use of 'chemical' or 'hazardous', and no duty for producers to pass chemical information to collectors or sorters. The recitals leave the tracking of substances of concern to the Ecodesign for Sustainable Products Regulation (ESPR).

InterpretationEUEuropean Parliament and Council of the European Union (OJ L series 2025/1892, 26.9.2025)

Once the 2025 amendment to the Waste Framework Directive (WFD) is transposed, sorters must separate items fit for direct re-use 'item-to-item', using 'up-to-date sorting criteria relevant to the receiving market'. Items not suitable for re-use go to remanufacturing and recycling, including fibre-to-fibre recycling 'where technological progress allows'. The criteria named are market criteria. Neither route has a chemical criterion.

LawEUEuropean Parliament and Council of the European Union (OJ L series 2025/1892, 26.9.2025)

France's textile extended producer responsibility (EPR) scheme, called REP TLC (textiles, chaussures, linge de maison) and run by the producer responsibility organisation Refashion, must ensure traceability of used textile waste to final treatment. Its standard contract with sorters must set out the traceability evidence that proves effective final re-use or recovery. Information about where sorted textiles go therefore travels back up the chain. The provisions say nothing about chemical content.

LawFranceMinistère de la Transition écologique; consolidated text published by INERIS (AIDA)

The fee adjustments (eco-modulations) in France's textile extended producer responsibility scheme (REP TLC) reward durability, recycled content and certification by named environmental labels, including Oeko-tex Made in Green, Bluesign, the EU Ecolabel and the Global Organic Textile Standard (GOTS). From 1 September 2026 a durability penalty of 12 euros per coat or jacket, rising to 19.50 euros from 2030, applies where the product's 'score D' is 0.8 or less. The consolidated text has no criterion on hazardous substances, per- and polyfluoroalkyl substances (PFAS) or finishes, and none of these adjustments produces information for sorters.

LawFranceMinistère de la Transition écologique; consolidated text published by INERIS (AIDA)

France's textile extended producer responsibility (EPR) rules set a recycling target for used textiles made of at least 90% synthetic plastic material: 50% from 2025 and 90% from 2028 of the quantity collected, sorted and not re-used. The rules also required a study, due by 1 January 2025, on synthetic products that combine different polymers. If no recycling solution is found, an 'eco-design penalty' for non-recyclability may be proposed. A polyester jacket with a laminated membrane may be such a multi-polymer product, depending on what the membrane is made of.

LawFranceMinistère de la Transition écologique; consolidated text published by INERIS (AIDA)

Refashion's 2025 key indicators report 272,479 tonnes of used textiles collected and 216,264 tonnes sorted (84% in France) by 74 contracted sorting centres that reported, 56 of them in France. Of the sorted tonnage, 54.47% went to re-use, 25.31% to materials for recycling, 11.03% to wiping rags and 8.4% to solid recovered fuel (combustible solide de récupération, CSR).

Reported practiceFranceRefashion

In December 2022 Refashion, the French textile producer responsibility organisation, told its members that no clothing, household linen or footwear product could lawfully carry a 'recyclable' claim under Code de l'environnement Article R.541-221 VI. One reason is that the criteria require 'the absence of elements or substances disrupting sorting, recycling or limiting the use of the recycled material'. Refashion concluded that the environmental product sheet should carry no recyclability information.

InterpretationFranceRefashion

A 2025 study for the European Commission's Joint Research Centre (JRC), based on sorters in Italy, Czechia and Romania, found 'no fixed criteria list' for deciding whether a garment is fit for re-use. Sorters follow facility manuals and judge usability, trend, colour, brand and visible damage. The re-use decision rests on what a trained person can see.

Reported practiceEU (Italy, Czechia, Romania)Joint Research Centre, European Commission (External Study report; Bakowska, O. et al.; Huygens, D., editor)

A 2026 study for the Joint Research Centre (JRC) on digital product passport (DPP) content for apparel finds that, at end of life, sorters and recyclers 'may rely on the information in physical labels' for garment composition, 'when they are not removed or faded'. It also finds that reading labels is slow, and that wear and removal compromise their accuracy and availability. The care label is the main composition record that reaches the sorter, and only if it survives.

Reported practiceEUEuropean Commission, Joint Research Centre (JRC)

Refashion's July 2026 review of sorting technology states that near-infrared (NIR) spectroscopy, the main automated method for identifying fibres, reads only the visible surface. Multilayered items and surface treatments 'such as coatings, finishes, dyes, waterproofing' are problematic because 'the technology cannot detect the underlying materials'. A coated face fabric over a laminated membrane falls squarely in this limitation.

Technical findingEU (survey of European equipment suppliers)Refashion

Refashion's 2026 environmental assessment of the French scheme reports that automated secondary sorting (sur-tri automatisé) was applied to only 0.1% of the material leaving sorting in 2025. Almost all routing decisions in the French system are therefore made by people reading labels and looking at garments.

Reported practiceFranceRefashion

The Joint Research Centre (JRC) textile waste study treated multilayered items as non-recyclable because 'there is no business case for their disassembly in Europe'. Multilayered items such as jackets and coats were 5.2% of its sample, and 'most of them were managed as reusable garments exported outside the EU'. Removing a membrane before recycling is not current practice. A laminated rain jacket that is not re-used in Europe most likely goes to export for re-use.

Reported practiceEU (Italy, Czechia, Romania)Joint Research Centre, European Commission (External Study report; Bakowska, O. et al.; Huygens, D., editor)

The Joint Research Centre (JRC) textile waste study states that its list of recycling disruptors 'lacks more detailed information (such as chemical composition) on various coatings, repellents, laminates or prints'. These probably occurred in the sample but 'were not identified in the data collection process'. Water repellents and laminates reach sorting as unidentified chemistry.

Technical findingEU (Italy, Czechia, Romania)Joint Research Centre, European Commission (External Study report; Bakowska, O. et al.; Huygens, D., editor)

The Joint Research Centre (JRC) textile waste study recommends focusing sorting for recycling on items of little second-hand value made of one layer, or several layers of the same material, and 'not covered in waterproof treatment, coating or excessive accessories'. A laminated rain jacket with a water-repellent finish fails these criteria on its defining features, before any chemical question is asked.

Technical findingEUJoint Research Centre, European Commission (External Study report; Bakowska, O. et al.; Huygens, D., editor)

In the Joint Research Centre (JRC) textile waste study, even garments judged ready for closed-loop mechanical recycling still need 'the care labels' removed before recycling. Near-infrared (NIR) scanning will not recognise elastane below 5% of a blend. The sewn-in label, the record designed to stay with the garment, becomes a disruptor and is cut off at this point.

Technical findingEUJoint Research Centre, European Commission (External Study report; Bakowska, O. et al.; Huygens, D., editor)

In a 2023 evaluation for the Swedish Chemicals Agency (KemI), the textile recycler Re:newcell said it may be offered deliveries, such as face masks, that it cannot accept 'since they cannot ensure its content'. Recyclers interviewed said they benefit from knowing chemical content 'at both item and material level', and one textile recycler accepts only flows labelled with the Nordic Swan Ecolabel. Without content information, recyclers fall back on refusing material or restricting intake to certified flows.

Reported practiceSwedenSwedish Chemicals Agency (Kemikalieinspektionen), study by Ramboll

The European Recycling Industries' Confederation (EuRIC), the trade body for Europe's recyclers, states that 'Recyclers cannot be held responsible for unknown chemical content in post-consumer textiles'. It cites 'the challenges of tracking thousands of substances in post-consumer textiles', and holds that trained sorting operators are best placed to judge reusability. This is an industry position, not a finding.

Reported practiceEUEuRIC (European Recycling Industries' Confederation)

The European Environment Agency (EEA) finds that when textiles reach end of life, 'any available information on PFAS content has usually been lost'. PFAS means per- and polyfluoroalkyl substances. Chemical analysis is 'expensive and generally not feasible', and identifying PFAS-containing textiles by visual inspection is 'very challenging'. The EEA calls for sorting and recycling investment that ensures PFAS-containing textiles are not recycled, and says current practice cannot trace PFAS at the waste stage.

Technical findingEUEuropean Environment Agency

Stakeholders interviewed for the Joint Research Centre (JRC) study on digital product passport (DPP) content 'consistently indicated that substance-level concentration and location data are not reported'. They said such data are 'unavailable in a form that could be disclosed reliably and proportionately'. Chemical verification such as OEKO-TEX Standard 100 works 'on a binary pass/fail basis'. The concentration and location fields that a downstream sorter would need are not generated upstream.

Reported practiceEUEuropean Commission, Joint Research Centre (JRC)

Since 2021 the Waste Framework Directive (WFD) has required suppliers of articles to notify the European Chemicals Agency (ECHA) of the information they must give under REACH Article 33(1). In practice this means Candidate List substances of very high concern (SVHCs) above 0.1% weight by weight. ECHA must give 'waste treatment operators' access to the resulting SCIP database (Substances of Concern In articles as such or in complex objects (Products)). This is the one EU channel built to carry chemical information to the waste stage.

LawEUEuropean Parliament and Council of the European Union (OJ L 150, 14.6.2018, p. 109)

A 2023 evaluation for the Swedish Chemicals Agency (KemI) found that none of 10 interviewed recyclers used the SCIP database (Substances of Concern In articles as such or in complex objects (Products)) regularly: 4 were aware of it and 2 had used it once. The textile recycler Renewcell searched it for substances of very high concern (SVHCs), but the results 'were however not useful' because it could not filter by material. The legal access route exists, but it was not demonstrated to support a textile recycler's decision.

Reported practiceSwedenSwedish Chemicals Agency (Kemikalieinspektionen), study by Ramboll

The Commission's December 2025 'Environmental Omnibus' proposal, COM(2025) 986, would end suppliers' duty to notify the SCIP database (Substances of Concern In articles as such or in complex objects (Products)) and leave the European Chemicals Agency (ECHA) only to 'maintain' data already submitted. The proposed new wording of Article 9(2) drops the sentence that grants waste treatment operators access. On 23 October 2026 the European Parliament's file showed the proposal awaiting committee decision, with an indicative plenary date of 14 December 2026.

ProposalEUEuropean Commission (via Publications Office Cellar)

The Ecodesign for Sustainable Products Regulation (ESPR) requires product-specific delegated acts to make substances of concern traceable 'throughout the life cycle', including their name, 'location … within the product', concentration and information for recycling at end of life. That information must be on the product or reachable through a data carrier on it. 'Substance of concern' includes any substance that 'negatively affects the reuse and recycling of materials'. This is the first EU duty designed to carry finish chemistry to sorters. It applies only once a textiles delegated act is adopted, and none had been adopted at the snapshot.

LawEUEuropean Parliament and Council of the European Union (OJ L series 2024/1781, 28.6.2024)

The Joint Research Centre (JRC) study on digital product passport (DPP) content for apparel defines a use case, 'Data exchange to facilitate sorting', whose primary actor is the end-of-life textile sorter and whose required data are 'Product composition and purity' and 'Substances of concern'. In its proposed access levels, substances of concern are public, but their location in the product is limited to those with a 'Legitimate interest'. It warns that benefits depend on a data carrier 'available and permanently attached to garments'.

ProposalEUEuropean Commission, Joint Research Centre (JRC)

A draft Joint Research Centre (JRC) working document for the ESPR (Ecodesign for Sustainable Products Regulation) textiles study says that if REACH adopts a broad restriction on per- and polyfluoroalkyl substances (PFAS), including in textiles, PFAS 'would, most likely, qualify as' substances of concern under Article 2(27)(d), the category for substances that hinder reuse and recycling. That would bring PFAS into the tracking duty that could carry finish chemistry to sorters.

ProposalEUJoint Research Centre, European Commission (Delre, A. et al.)

France's PFAS law bans from 1 January 2026 the manufacture, import, export and placing on the market of consumer clothing containing per- and polyfluoroalkyl substances (PFAS). Its implementing decree defines placing on the market as supply to a third party 'pour la première fois' (for the first time). Reselling a used jacket within France therefore appears to fall outside the ban, but the separate ban on 'exportation' is not limited to first supply. Whether a sorter may export a used PFAS-treated jacket for re-use is not resolved by the text.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

France's PFAS decree exempts from the clothing ban garments that contain at least 20% recycled material from post-consumer waste, but per- and polyfluoroalkyl substances (PFAS) are allowed only in that recycled fraction, in proportion to it. French law therefore expects that recycled textile feedstock may carry PFAS and lets recycled content bring some back into new garments.

LawFranceJournal officiel de la République française, reproduced by AIDA (INERIS)

The EU restriction on undecafluorohexanoic acid (PFHxA), its salts and related substances under REACH Annex XVII has applied since 10 October 2026 to clothing textiles for the general public, at 25 ppb (PFHxA and salts) or 1,000 ppb (related substances). It does not apply to articles 'placed on the market before 10 October 2026'. The entry says nothing about second-hand goods, waste or recycled material, and its recitals name 'outdoor clothing like rain jackets'.

LawEUOfficial Journal of the European Union (via Publications Office Cellar)

The EU restriction on nonylphenol ethoxylates (NPE) in textiles states expressly that it does not apply to 'second-hand textile articles' or to new articles made 'exclusively from recycled textiles' without NPE. The undecafluorohexanoic acid (PFHxA) restriction has no such clause. REACH defines placing on the market as any supply to a third party, not only first supply. Whether the PFHxA limits apply when a jacket first sold before 10 October 2026 is resold, or when recycled fibre goes into new clothing, is therefore not settled by the text.

InterpretationEUEuropean Commission (OJ L 9, 14.1.2016)

Once the 2025 Waste Framework Directive (WFD) amendment is transposed, each bale of used textiles shipped as fit for re-use must carry a record, fixed to the packaging, describing the items 'such as type of clothes, size, colour, gender, material composition', and naming the company that did the final sorting. A copy of every bale record must go with the consignment. This is a new information channel from sorter to re-use buyer. It describes bale contents at sorting granularity and has no chemical field.

LawEUEuropean Parliament and Council of the European Union (OJ L series 2025/1892, 26.9.2025)

The European Environment Agency (EEA) reports that EU exports of used textiles reached almost 1.7 million tonnes in 2019: 46% went to Africa and 41% to Asia. The 'fate of used textiles exported from the EU is highly uncertain'. The customs codes used, Combined Nomenclature (CN) 6309 and 6310, include 'no code for textile waste export', and 'classification does not necessarily describe the true state of what is exported'. Trade records do not record whether an item is waste, let alone its chemistry.

Reported practiceEUEuropean Environment Agency

France's environment ministry states that only about 35% of used textiles are collected, the rest going to household waste for incineration or landfill. It also states that the French scheme 'dépend de l'exportation' (depends on export) for both re-use and recycling of used textiles. A jacket that leaves France for re-use or recycling follows the scheme's normal route.

Reported practiceFranceMinistère de la Transition écologique

The Global Framework on Chemicals (GFC) was established at the fifth International Conference on Chemicals Management (ICCM5) in Bonn in September 2023 and adopted by resolution V/1 as a voluntary framework. None of its targets, including the one on information in products, creates a binding duty on any actor at any handover.

LawInternationalUnited Nations Environment Programme (UNEP)

GFC Target B2 reads in full: 'By 2030, stakeholders make available, to the extent possible, reliable information on chemicals in materials and products throughout the value chain.' It names no information fields, no sender and no recipient, and it is qualified by 'to the extent possible'.

LawInternationalUnited Nations Environment Programme (UNEP)

The GFC's scope covers the life cycle of chemicals 'including products and waste', and its Strategic Objective B aims for information that is 'accessible to all to enable informed decisions and actions'. On its own terms the framework therefore reaches the collector, sorter and recycler at H5 and H6, not only the factory.

InterpretationInternationalUnited Nations Environment Programme (UNEP)

The GFC's hooks for finishing-mill workers at H1 are Target B6 (all governments implement the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) by 2030), Target D7 (effective occupational health and safety 'throughout the supply chain') and paragraph 43, which asks industry to conduct due diligence so that International Labour Organization (ILO) health and safety standards apply 'throughout their value chains'.

LawInternationalUnited Nations Environment Programme (UNEP)

The GFC treats skills as part of the work: Target B5 calls for training and public awareness programmes on chemical safety and safer alternatives by 2030, and paragraph 57 says 'All stakeholders should be equipped with the necessary skills, knowledge and resources to implement the Framework.' The framework itself does not assume that available information is usable information.

LawInternationalUnited Nations Environment Programme (UNEP)

Alongside information, the GFC sets substitution and sector targets: Target D4 asks stakeholders to prioritise 'safer alternatives to harmful substances in products and mixtures, including in consumer products', and Target D6 calls for sector strategies that identify priority chemicals of concern and reduce 'their input along the value chain'. Information under Target B2 can inform these decisions but does not replace them.

LawInternationalUnited Nations Environment Programme (UNEP)

The first session of the International Conference of the GFC (IC1) runs from 16 to 20 November 2026 at the Geneva International Conference Centre, hosted by Switzerland. Under agenda item 4(c) it may consider a draft resolution and proposed indicators for possible adoption.

ProposalInternationalGlobal Framework on Chemicals secretariat (UNEP)

Pre-session document UNEP/GFC/IC.1/4 proposes three new indicators for Target B2, each with '[globally]' still in square brackets: countries with measures on harmonised digital products and materials information systems (B2.1), stakeholders using a harmonised standard, tool or platform to share information about chemicals in materials and products 'along the full value chain' (B2.2), and countries making harmonised data publicly accessible (B2.3). They are drafts for possible adoption at IC1, not adopted indicators.

ProposalInternationalGlobal Framework on Chemicals secretariat (UNEP)

The secretariat's indicative overview for IC1 finds that practices to provide information on chemicals in products 'are emerging' but that there is 'still a lack of effective systems and mechanisms to collect and share this information along the value chain'. For Target B2 it counts 48 countries with measures on harmonised digital information systems and 38 countries and 211 companies using a harmonised standard or platform, and says the data do not allow a robust assessment of the reliability of the information shared.

Reported practiceInternationalGlobal Framework on Chemicals secretariat (UNEP)

The IC1 document on issues of concern keeps 'chemicals in products' and 'managing perfluorinated chemicals and the transition to safer alternatives' on the list. It says that outside sectors with mandatory ingredient labelling, information exchange 'relies primarily on voluntary initiatives by individual sectors or companies', credits textile-sector systems and tools with progress, and says gaps remain in transparency, access to information and uptake.

Reported practiceInternationalGlobal Framework on Chemicals secretariat (UNEP)

IC1 is asked to confirm industry sector programmes for four high-impact sectors, including textiles, and a thematic workstream on 'Transparency, traceability and disclosure along value chains (target B2)'. The draft workplan gives the textiles programme 2027 to 2028 for mapping initiatives, knowledge-sharing, raising awareness and piloting, convened by UNEP.

ProposalInternationalGlobal Framework on Chemicals secretariat (UNEP)

IC1's programme includes sector exchanges on textiles covering 'data transparency, traceability and disclosure', a 'Fashion for the future' evening event on 16 November, and a high-level conversation titled 'Transparency without overload'. That title names the tension this piece examines: more data is not the same as usable information at each handover.

InterpretationInternationalGlobal Framework on Chemicals secretariat (UNEP)

UNEP's 2011 Chemicals in Products (CiP) textile case study found that 'except for fiber content essentially no information system exists for transmitting data on what chemicals are contained in individual products.' Fibre content, which the sewn-in label still carries, was the one field it found travelling with the garment.

Reported practiceInternationalUNEP Division of Technology, Industry and Economics (DTIE), Chemicals Branch

The same study separates restricted substance list (RSL) compliance from content disclosure: under an RSL programme the 'negative content' information (what is not in the product) 'does not accompany the product itself', whereas ecolabels attached to the finished article do carry it. A 'PFAS-free' statement is negative-content information in this sense.

Reported practiceInternationalUNEP Division of Technology, Industry and Economics (DTIE), Chemicals Branch

UNEP's 2015 CiP guidance says information passed within supply chains should cover selected chemicals above a reporting threshold, include hazards and safe handling instructions where required, and 'should be supplied in the appropriate language for the recipients.'

Voluntary standardInternationalUNEP for the Strategic Approach to International Chemicals Management (SAICM)

The CiP guidance states the structural break at H5 directly: 'Recyclers are outside the business-to-business information exchange because their connection to the data is interrupted by consumers.' It lists what waste managers need: hazardous chemicals and their location, how to prevent exposure, and product composition so materials can be sorted and processed.

Voluntary standardInternationalUNEP for the Strategic Approach to International Chemicals Management (SAICM)

The CiP guidance defines relevant information by the recipient's decision ('the information that the recipient needs to take an informed purchase or chemicals-management decision or action') and requires it to be 'accessible, clear and understandable'. For disclosure outside the supply chain it asks for attention to language and technical background and says the date the information was produced 'would also be useful to provide'.

Voluntary standardInternationalUNEP for the Strategic Approach to International Chemicals Management (SAICM)

UNEP's 2020 global stocktake of the textile value chain says large-scale textile recycling is 'hampered by a lack of traceability, insufficient or absent fibre labelling legislation and mixed materials', and will stay at low levels unless recyclers 'can be confident regarding the source, composition and chemical content of their feedstock'.

Reported practiceInternationalUnited Nations Environment Programme (UNEP)

UN General Assembly resolution 92(I) of 7 December 1946 recommends that member states prevent use of the United Nations name, emblem and initials without the Secretary-General's authorisation, 'in particular for commercial purposes by means of trade marks or commercial labels'. Foresight is a commercial company, so the piece should carry no UN, UNEP or GFC logo and no wording that implies endorsement.

LawInternationalUnited Nations General Assembly

UNECE Recommendation No. 46, from the UN Centre for Trade Facilitation and Electronic Business (UN/CEFACT), recommends that governments support 'harmonized collection and transmission of data for tracking and tracing materials, products, and processes across an entire value chain' in garments and footwear. It was agreed at UN/CEFACT's twenty-seventh session in April 2021 and is a recommendation to governments, not a duty on companies.

Voluntary standardInternationalUN Economic Commission for Europe (UNECE), UN/CEFACT

Recommendation No. 46 identifies the post-consumer stage as the hardest: closing the circle after sale is 'particularly challenging' because of missing collection infrastructure, 'missing or inaccurate information about the composition of goods' and technical barriers to post-consumer traceability.

Reported practiceInternationalUN Economic Commission for Europe (UNECE), UN/CEFACT

Recommendation No. 46 asks governments to define 'the minimum data that need to be collected in order to show due diligence and transparency in support of claims regarding the origin, composition and other characteristics' of products. A 'PFAS-free' or 'fluorine-free' finish claim is one such composition claim, and no minimum data set for it is defined in the recommendation.

Voluntary standardInternationalUN Economic Commission for Europe (UNECE), UN/CEFACT

UN/CEFACT records the capability barriers for smaller actors: traceability technologies 'may be difficult due to geographical and language barriers as well as costs', and the most important impediments are 'often cost and access, followed by language and a lack of available training'. Its guidelines say tool design should consider 'the language of users'.

Reported practiceInternationalUN Economic Commission for Europe (UNECE), UN/CEFACT

Electronics shows a mature model: IEC 62474 sets the procedure, content and form of material declarations passed from suppliers to downstream manufacturers, in two types (declaration for compliance and composition declaration). It excludes process chemicals, so even a mature product declaration describes what is in the product, not what was used to make it.

Voluntary standardInternationalInternational Electrotechnical Commission (IEC)

The IPC-175x family from IPC, the electronics industry association, 'establishes a standard reporting format for data exchange between supply chain participants'. IPC-1752A, named in the brief, has been followed by IPC-1752B (July 2020), built to match the EU SCIP database for Substances of Concern In articles as such or in complex objects (Products), and by IPC-1752C (June 2026), the current version.

Voluntary standardInternationalIPC (Association Connecting Electronics Industries)

Where an EU Ecodesign for Sustainable Products Regulation (ESPR) delegated act sets information requirements on substances of concern, they must make those substances trackable through the life cycle and include at least: the substance name or code, its location in the product, its concentration (or maximum or range) at product, component or spare-part level, instructions for safe use, and end-of-life information. That covers four of this piece's five fields; the list does not include the type or date of the underlying evidence.

LawEUEuropean Parliament and Council of the European Union

ESPR requires substances-of-concern information to be 'given either on the product or be accessible through a data carrier included on the product', in a language easily understood by customers as decided by the member state. For a jacket that points to the label or a carrier attached to it, but the regulation does not by itself ensure that a consumer or sorter can interpret a chemical name.

LawEUEuropean Parliament and Council of the European Union

ESPR lists who should have free, easy access to the digital product passport (DPP), including recyclers, professional repairers, refurbishers, trade unions, civil society organisations and authorities, 'based on their respective access rights set out in the applicable delegated act'. Which actor sees which data is left to each product-group delegated act.

LawEUEuropean Parliament and Council of the European Union

The Commission's first ESPR working plan (16 April 2025) ranks textiles and apparel first among new product groups, with 2027 as the indicative timeline for adoption, and says information requirements 'will work in synergy with the Textile Labelling Regulation, currently under review'. At the snapshot a textile DPP is planned, not in force.

ProposalEUEuropean Commission (via Publications Office Cellar)

OEKO-TEX ECO PASSPORT lets producers of textile chemicals prove their products 'can be used in an ecologically sustainable production'. The supplier discloses the formulation to OEKO-TEX or its testing institute, which holds it 'strictly confidential' and never passes it to third parties, so the finishing mill at H1 receives a certificate, not the formulation.

Voluntary standardInternationalOEKO-TEX AG

The ZDHC Gateway's Chemical Module calls itself 'the world’s first verified database of safer chemistry for the apparel and footwear industry'. It generates a ChemCheck Report, 'an individual product passport', for chemical products conformant with the ZDHC Manufacturing Restricted Substances List (MRSL), and InCheck reports show the MRSL conformance of a facility's chemical inventory.

Voluntary standardInternationalZero Discharge of Hazardous Chemicals (ZDHC) Foundation

ILO Chemicals Convention No. 170 (1990) requires hazardous chemicals to be labelled 'in a way easily understandable to the workers' and safety data sheets with identity, hazards, precautions and emergency procedures to be provided to employers. It does not apply to articles that will not expose workers under normal or reasonably foreseeable use, so it reaches the mixture at H1 but generally not the fabric roll at H2.

LawInternationalInternational Labour Organization (ILO), NORMLEX

Under Convention No. 170, workers and their representatives have the right to information on the identity of chemicals used at work, their hazards and precautions, label information and safety data sheets, and employers must instruct workers how to obtain and use that information. An employer may protect a mixture ingredient's specific identity from competitors in a manner approved by the competent authority.

LawInternationalInternational Labour Organization (ILO), NORMLEX

Convention No. 170 has 24 ratifications. Neither Viet Nam nor France is among them; China ratified in 1995. The GFC's proposed indicator D7.1 would count ratifications of up-to-date ILO conventions on chemical risks.

LawInternationalInternational Labour Organization (ILO), NORMLEX

ILO Recommendation No. 177 says workers should receive information on classification, labelling and safety data sheets 'in forms and languages which they easily understand', plus workplace-specific instruction and training. It is the clearest international statement that worker access depends on language and training, not only on a document existing.

LawInternationalInternational Labour Organization (ILO)