February 25th, 2026
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France’s Groundbreaking Decrees on PFAS Restrictions: Key Insights for Businesses
This blog was originally posted on 26th August 2025 and was updated on 25th February 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
AUTHORED BY DIEUDONNÉ YMEDJI, SENIOR REGULATORY COMPLIANCE SPECIALIST & CECÍLIA FERREIRA DE CARVALHO, REGULATORY COMPLIANCE SPECIALIST, COMPLIANCE & RISKS
In the final quarter of 2025, the French Ministry of Ecological Transition published two decrees implementing the Per- and Polyfluoroalkyl Substances (PFAS) Restrictions under Law No. 2025-188 of 27 February 2025.
The first implementing Decree No. 2025-1376 reflects France’s proactive strategy to eliminate PFAS from specific products and reinforces its commitment to environmental and public health protection. The ban took effect on 01 January 2026 and will be gradually expanded to cover all textile products placed on the market from 1 January 2030.
The second, Decree No. 2025-958, clarifies the scope and timeline of the progressive phase-out of PFAS from industrial effluents.
This blog distils the content of these two implementation decrees, making it easier for your organisation to understand the scope of PFAS restrictions and the drivers behind these changes.
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Understanding Decree 2025-1376, Tightening Control Over PFAS in Certain Consumer Products
Adopted on the basis of Law No. 2025-186, which bans the production, import, export, and placing on the market of textiles, footwear, wax, and cosmetics containing PFAS, Decree 2025-1376 clarifies the prohibition regime for these substances in certain critical industrial uses and consumer articles. In this regard, it sets out the residual concentration threshold below which the prohibition on PFAS use in these products does not apply, as well as a narrow list of products exempted from the ban.
1. Scope of the Implementing Measure
Article 1 of the decree introduces a new Chapter V to the regulatory section of the French Environmental Code. This chapter emphasises the prohibition on placing certain PFAS-containing products on the market. The ban applies to manufacturers, importers, exporters, and suppliers of textiles, footwear, wax, and cosmetics.
1.1 Definitions
Contrary to the proposed text, the final version of the new Article D.525-1 under this Chapter of the Code does not include a definition of ‘textiles’ but retains the initial description of:
- PFAS, as any substance containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, with no attached hydrogen, chlorine, bromine or iodine atoms; and
- Placing on the market, as importing, supplying or making available, whether in return for payment or free of charge, to a third party.
1.2 Permitted Residual PFAS Concentrations
Article D.525-4 establishes three cumulative concentration thresholds to ensure that only unintentional trace amounts of PFAS are present in products. Unless exempt, any products exceeding these thresholds will be prohibited. These thresholds are:
- 25 parts per billion (ppb) for any PFAS measured by a targeted analysis, excluding polymers;
- 250 ppb for the total PFAS measured as the sum of targeted analyses of PFAS, where appropriate, with prior degradation of precursors, but excluding polymers;
- 50 ppb for PFAS, including polymers.
These thresholds align with the standard detection limits of the analytical methods used for PFAS and are also similar to the limits outlined in the draft generic restriction on PFAS, which is currently under review at the EU level. Additionally, the decree includes a provision to revise these thresholds in response to scientific and technical progress, making it a flexible framework that can adapt to new findings.
Notably, there is no designated “official” analytical technique for determining these thresholds. Companies must use accredited laboratories and standardised methods, such as liquid chromatography–tandem mass spectrometry (LC-MS/MS) or combustion ion chromatography, to ensure compliance.
1.3 List of Products to Benefit from the Ban Exemptions
Not all products are subject to the ban. In accordance with Articles L. 524-1 I and II of the Environmental Code, as amended by Law No. 2025-188, Articles D.525-2 and D.525-3 clarify the list of products that may not be subject to the prohibition from 01 January 2026 and 01 January 2030, respectively. These include:
- Technical textiles for industrial purposes, such as high-performance membranes used for filtration or separation processes;
- Textiles necessary for essential use or contributing to the exercise of national sovereignty, provided that no PFAS-free alternative exists;
- Medical textiles, such as sanitary products essential for healthcare;
- Textiles and footwear containing more than 20% recycled content, including recycled polymers.
2. Timeline and Implications for Businesses
From 1 January 2026, the manufacture, import, export, and sale of a wide range of PFAS-treated products, including textiles, clothing, footwear, cosmetics, and wax products, are prohibited in France. However, products manufactured before this date may be sold or exported until 31 December 2026, giving businesses time to adjust to the new regulations.
Regarding compliance enforcement, one believes that a market surveillance and control approach to restrictions will be proactive, document-driven, and supported by strict penalties.
Customs authorities will monitor and control the import and export of products containing PFAS, ensuring that non-compliant items do not enter or leave the national market.
The market surveillance body (DGCCRF), in its role of monitoring and verifying the regulatory compliance of consumer products placed on the French market, will likely conduct inspections, tests, and audits of products available on the market. Non-compliance could result in market bans, product recalls, and administrative or financial penalties of up to €15,000 in accordance with Article L. 521-18 of the Environment Code. In addition, criminal prosecution may become a real risk under specific aggravating circumstances. These include violations of more general Articles of the French Consumer Code (Article L. 454-1), the Environmental Code, and the Health Code (Articles L. 5431-1).
3. What Should Affected Businesses Do Now?
Manufacturers and importers placing or intending to place textiles, clothing, footwear, cosmetics, and wax products on the French market shall, among other things:
- Review their product lines and collaborate with suppliers to source materials that are free of PFAS or meet the new regulatory thresholds;
- Maintain documentation and testing evidence;
- Invest in research and development to create PFAS-free alternatives, thereby gaining a competitive advantage in a sustainability-focused market.
In summary, this French regulatory initiative marks a significant step forward in the global effort to eliminate the unregulated use of PFAS in consumer products. By setting strict limits and promoting the development of safer alternatives, the decree aims not only to protect public health and the environment but also to encourage innovation and a shift towards sustainability. Businesses facing the potential impact of these measures are urged to adopt safer, more sustainable practices immediately and proactively. By doing so, they can ensure compliance with the new regulations while contributing to a healthier environment for future generations.
Progressive Phase-out of PFAS in Aqueous Industrial Effluents Under Decree 2025-958
1. Phase-out Trajectory for PFAS
Approved on 8 September 2025, the final decree is identical to the original proposal issued in August 2025. Issued pursuant to Article 2 of the PFAS Restriction Law, the decree implements the law, which mandates a national strategy to eliminate industrial PFAS discharges within five years. It sets a target to reduce PFAS emissions by 70% by 27 February 2028, using 2023 levels as a baseline, with the ultimate goal of fully eliminating PFAS from all industrial effluents by February 2030.
This target is based on findings from an extensive research and analysis campaign carried out in 2023. The focus of this campaign was to detect PFAS in aqueous discharges from certain classified installations subject to authorisation in accordance with the French nomenclature of ICPEs. It required listed facility operators to conduct monthly wastewater analyses over three consecutive months, focusing on the 20 PFAS identified in the Drinking Water Directive. The campaign was mandated by the Order of 20 June 2023 relating to the analysis of PFAS in industrial aqueous discharges. Findings showed that half of the industrial sites surveyed discharged at least one PFAS compound in their wastewater. Detected PFAS emissions did not only originate from industrial processes but were also found in the water supply of industrial sites.
2. Toward Comprehensive Control of PFAS Discharges in Industrial Sites
The decree establishes France’s national plan to progressively reduce PFAS in industrial wastewater and applies to operators of industrial facilities that discharge per- and polyfluoroalkyl substances (PFAS) in their effluents. PFAS falling in scope are defined therein as PFAS substances containing at least one fully fluorinated methyl (–CF3) or methylene (–CF2) carbon atom, with no bonded hydrogen, chlorine, bromine, or iodine atoms. The legislation appears to close a significant gap in French environmental law, which until now has not comprehensively addressed the broader environmental risks posed by PFAS.
To date, only one other measure requires operators of authorised ICPEs to monitor a specific PFAS compound – PFOS in their wastewater discharges. This obligation arises from the RSDE Order of 24 August 2017, which amended an earlier Order of February 1998.
This Order sets a maximum PFOS concentration of 25 μg/l for wastewater discharged into the natural environment. The installations subject to the above PFOS emission limit are limited to ICPEs operating under the authorisation regime (Article L. 512-1 of the Environmental Code). These include installations that pose serious risks to health, public safety, and the environment (e.g., waste incineration plants, hazardous chemical storage facilities, wastewater treatment plants, etc.).
Additional PFAS emission limits may be found in the BAT (Best Available Techniques) documents for certain authorised installations. In addition, the French State Council has also authorised Departmental Prefects to activate, as part of their special police power, the precautionary principle to restrict the release of PFAS from facilities operating in their jurisdictions (Council of State, December 20, 2024, no. 475355; Council of State, May 24, 1993, Union of Chemical Industries, No. 113896).
3. Spotting Loopholes: Ambiguities in Site Coverage and Enforcement of PFAS Trajectory
The legislator’s ambition is clear: reduce and eliminate PFAS emissions from industrial wastewater. However, the practical implementation of the new phase-out trajectory remains uncertain.
The term “all industrial sites” suggests that all industrial sites discharging PFAS in their wastewater would be subject to the phase-out, even though they were not initially included in the 2023 measurement campaign. A national trajectory carries little weight if it is not supported by binding measures that require industrial sites to comply with specific emission limits. If it is intended to cover all industrial sites, regulatory PFAS emission thresholds may need to be established for a broader range of facilities, including ICPEs under the declaration or registration regimes, as well as for industrial sites currently unclassified.
This Order represents just the beginning. Another key measure of the PFAS Restriction Law introduces a €100 fee for every 100 grams of PFAS discharged into water by authorised ICPEs. The specific PFAS substances subject to this fee will be defined by a government decree.
4. What’s Next?
Following the adoption of Decree 2025-958, the French Ministry of Ecological Transition is expected to develop a monitoring framework to support compliance with the PFAS phase-out trajectory. Authorities may also provide further guidance to clarify the scope of sites and obligations covered under the decree.
Interested in learning more about chemical legislation in the EU and beyond? Download a copy of our expert whitepapers ‘2025 Update on EU REACH and POPs Restrictions: Key Insights‘ and ‘PFAS Under Pressure: Key Trends and Challenges Worldwide‘.
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PFAS Regulations: Are You Ready for What Comes Next?
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