France’s PFAS Decree Explained: Key Questions for Manufacturers and Importers
This blog was originally posted on 11th March, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.
On 30 December 2025, the French Ministry of Ecological Transition published Decree No. 2025-1376 that defines the residual concentration values below which the prohibitions outlined in sections I and II of Article 1 of the so‑called PFAS Restriction Law No. 2025‑188 shall not apply, as well as the list of products that may be exempt from this ban.
In this blog, we answer some key PFAS compliance questions relating to French Decree No. 2025-1376 regarding Prevention of Risks Associated with Per- and Polyfluoroalkyl Substances (PFAS).
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Which commercial activities and supply-chain roles are covered by the law and the implementing measures (e.g., manufacturing, import, placing on the market, distribution, distance selling/e-commerce, warehousing, advertising, etc.)?
Scope of Application
The French PFAS Law and its implementing Decree No. 2025-1376 cover a broad range of commercial activities and supply chain roles related to products containing PFAS. It prohibits the manufacture, export, import, and placing on the market (meaning, the first making available of a product on the French market) of PFAS-containing products in France, including both physical and online sales channels.
Neither legal text explicitly mentions warehousing or advertising, but since both prohibit the import, export, and placing on the market of PFAS-containing products, storing or advertising such products for these purposes would likely also be restricted or prohibited.
What are the relevant milestones (entry into force, any transitional periods, and the dates of any prohibitions/restrictions for specific product categories)? Is there a transition period for selling off remaining stock? If so, under what conditions and until when?
Key Deadlines
The decree prohibits, 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. It also introduces residual PFAS thresholds and specific exemptions for certain uses where no viable alternatives exist, such as medical textiles, PPE, and products containing at least 20% post-consumer recycled material (with PFAS limited to the recycled portion).
Under Article 2 of the Decree, products manufactured before 1 January 2026 may be sold or exported until 31 December 2026, allowing businesses time to adapt.
What requirements apply once the transitional period expires – does this result in a total sales ban, or are there exemptions (e.g., for products manufactured or placed on the market before a certain date, specifically before 1 January 2026)?
Rules After the Transitional Period
After 31 December 2026, most PFAS-containing products cannot be sold, imported, or exported in France, except for the following categories exempt from this prohibition:
- PPE including equipment for defence, police and civil protection;
- water-repellent products used for the re-impregnation of PPE;
- technical textiles for industrial applications;
- medical textiles used in healthcare settings;
- clothing and footwear containing at least 20% recycled material from post-consumer waste, provided that PFAS is present only in the recycled portion.
As a final point, under Law 2025-188, a comprehensive ban on all textiles will take effect on 1 January 2030. There will be specific exemptions for essential uses, national sovereignty needs, and industrial technical textiles, as defined in an implementing decree.
What is the CAS list included in this regulation, and what are the official methods to verify the presence and concentration of PFAS?
CAS Numbers
French Law No. 2025-108 and its implementing Decree No. 2025-1376 do not provide a comprehensive list of CAS numbers for all PFAS substances. Instead, they categorise PFAS substances as a class and establish specific thresholds for total fluorine and individual PFAS compounds. In alignment with the OECD (2021) definition, PFAS substances are generally described in the Decree as “any substance containing at least one fully fluorinated methyl (-CF₃) or methylene (-CF₂-) carbon atom without any attached H, Cl, Br, or I atoms.”
Verification of Presence and Concentration of PFAS
The Decree does not designate a specific “official” analytical technique or testing method for determining PFAS thresholds in products. Instead, it emphasises concentration limits, suggesting that any validated analytical method, such as liquid chromatography–tandem mass spectrometry (LC-MS/MS), ion chromatography, or other suitable methods that can meet these limits, is acceptable. In practice, companies must use accredited laboratories and standardised analytical methods to verify compliance with the specified thresholds.
Are textile footwear, textile bags, leather clothing, leather footwear and leather bags in scope?
Scope of Decree No. 2025-1376 in Relation to Textiles
The French PFAS ban, Decree 2025-1376, primarily targets products where PFAS use is most widespread, such as cosmetics, textiles, footwear, and accessories.
Although leather goods, including clothing, footwear, and bags, are not explicitly covered by the decree, It is reasonable to assume that they could still face scrutiny if they incorporate textile components or treatments containing PFAS. For instance, a leather jacket with a treated textile lining or a leather bag with a PFAS-treated inner pocket would likely be subject to the restrictions placed on those textile components.
This interpretation aligns with the broader goal of the Decree, which focuses on addressing the presence of certain chemicals rather than being limited to the dominant material of the final product. As a result, businesses in the leather goods sector are encouraged to perform thorough due diligence on all raw materials, including coatings, dyes, and any ancillary textile parts, to ensure compliance with the Decree’s requirements.
Will France’s PFAS Decree No. 2025-1376 (Prevention of Risks Associated with Per- and Polyfluoroalkyl Substances) impact electrical products by 2030?
Scope of Decree No. 2025-1376 in Relation to Electronic Products
Electronic products incorporating textile components are not specifically listed among the affected or exempted products under the PFAS ban, Law No. 2025-188, or its implementing Decree 2025-1237. The law does not distinguish between textiles used in clothing, footwear, or as components in other products. It simply provides that from 1 January 2030, the ban will be extended to all textile products placed on the French market, regardless of their end use or integration into other products.
In light of this, it can reasonably be assumed that, by 2030, manufacturers, importers, and distributors of electronic products with textile components must ensure that the textiles are PFAS-free or fall under an approved exemption for essential uses, national sovereignty needs, healthcare, or industrial applications. This could include certain medical or military-grade electronics, but not standard consumer devices.
How is the importation and sale of textiles containing PFAS above the permitted limits, and not covered by any exemption, legally classified?
Classification of Textiles Containing PFAS Above Permitted Levels Imported and Sold in France
Under French Law No. 2025-108 and its implementing Decree No. 2025-1376, the import and sale of textiles containing PFAS above the permitted limits, unless covered by specific exemptions, are strictly prohibited. Specifically, since 1 January 2026, the law explicitly bans the manufacture, import, export, and marketing of textiles (and other products) containing PFAS, with exceptions for certain categories. These exemptions include personal protective equipment, textiles used for national defence, and technical textiles for industrial purposes when no alternatives are available.
This means that any textile product containing PFAS above the established thresholds, and not included in the listed exemptions, is considered non-compliant and illegal to import or sell in France. Violations of this prohibition may result in enforcement actions, including penalties and the removal of non-compliant products from the market.
What administrative sanctions may be imposed in the event that textiles containing PFAS above the permitted limits are found to be imported or placed on the market?
Administrative Sanctions for Non-Compliance
Neither the law nor the decree establishes a distinct sanctions regime; instead, they utilise existing legal frameworks, such as the Environmental Code and customs laws, for enforcement. Consequently, if there is non-compliance with the permitted PFAS limits, various administrative sanctions and enforcement measures may be implemented. These measures can include bans and recalls of products that exceed PFAS limits, as well as financial fines, especially for repeated or serious violations.
Are there specific statutory maximum amounts for fines set out in the applicable legislation, or how is the level of sanctions determined in practice?
Fines for Non-Compliance
Neither the law nor the decree specifies a single, explicit maximum fine for all PFAS violations. However, under Article L. 521-18 of the Environment Code, failure to comply may result in an administrative penalty. This may include a fine of up to €15,000, a daily penalty of €1,500, and possible bans on importing or selling products, as well as withdrawal measures.
The level of sanctions is determined by the nature, severity, and persistence of the non-compliance. The DGCCRF (consumer protection authority) and other agencies (e.g. customs) monitor compliance and can impose penalties accordingly.
Under what circumstances could a breach of the PFAS prohibition escalate from an administrative offence to criminal liability?
Criminal Liability for Non-Compliance
While administrative penalties can be severe, criminal prosecution may become a real risk under specific aggravating circumstances. This includes 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).
Transitioning from an administrative offence to criminal liability may occur if there is evidence of deliberate circumvention, concealment, fraud, or a blatant disregard for the law’s purpose. This may include:
- Misleading commercial practices, such as marketing a product as “PFAS-free” or compliant with the law when it intentionally contains banned PFAS.
- Failing to recall or inform the authorities about products that do not comply with regulations.
- Intentional, repeated, or large-scale violations, particularly those involving fraud, endangering public health, or causing environmental harm.
- Selling banned PFAS products that are linked to a specific, significant pollution event (see Article L. 216-6 of the Environmental Code).
For further information on PFAS legislation in France, check out our blog ‘France’s Groundbreaking Decrees on PFAS Restrictions: Key Insights for Businesses‘.
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February 25th, 2026
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