Two Markets, Two Timelines: Managing EU and UK PFAS Compliance
Until Brexit, the EU and UK followed the same rules on PFAS. That is no longer the case.
The EU is restricting PFAS gradually, one substance and one sector at a time. REACH is at the centre of this approach, supported by sector-specific rules covering areas such as cosmetics, packaging and food contact materials. Some Member States are also introducing their own restrictions. The UK published its PFAS Plan in early 2026 and is taking a slower, more phased approach.
For brands selling consumer goods in both markets, this creates two compliance pathways, two timelines and, in some cases, two different interpretations of what qualifies as a PFAS-restricted product.
This guide helps compliance, regulatory and sourcing teams understand where the EU and UK still align, where their rules have already diverged, and where further differences are likely to emerge over the next eighteen months.
How the EU and UK regulate PFAS: two different frameworks
The EU regulates PFAS through several laws that work together:
- REACH Annex XVII is the main mechanism. It includes restrictions on specific PFAS, such as PFOA (Entry 68) and PFHxA (Entry 79). It is also the framework that would be used if the proposed universal PFAS restriction is adopted.
- The EU POPs Regulation 2019/1021 covers PFAS that have already been classified as persistent organic pollutants, including PFOS, PFOA and PFHxS.
- The Cosmetic Regulation 1223/2009 lists substances that cannot be used in cosmetic products through Annex II. The EU has used this route to ban additional PFAS in cosmetics.
- The Packaging and Packaging Waste Regulation, adopted in December 2024 and published in January 2025, introduces a separate PFAS restriction for food contact packaging.
Alongside these existing laws, ECHA is also assessing a proposal for a universal PFAS restriction. Submitted in January 2023 by five Member States, the proposal would restrict the entire PFAS class across most uses, while allowing certain sector-specific exemptions.
The UK regulates PFAS through a smaller number of legal frameworks:
- UK REACH, which is the UK’s version of EU REACH.
- The UK’s retained POPs framework, based on the EU POPs Regulation as it existed at the time of Brexit.
- The retained Cosmetic Regulation, which mirrors EU Regulation 1223/2009.
- The UK PFAS Plan, published in early 2026, which outlines the government’s approach to PFAS regulation in the years ahead.
The first three frameworks were carried over from EU law after Brexit and are now updated separately in Great Britain. Northern Ireland follows a different arrangement under the Windsor Framework, which is a separate topic.
The main difference between the EU and UK approaches is the pace of regulation. The EU has introduced new PFAS restrictions steadily over time and continues to expand them. The UK has moved more slowly since Brexit, and its PFAS Plan points to a phased, risk-based approach rather than a broad restriction covering all PFAS at once.
As a result, the gap between the two regulatory systems is becoming larger rather than smaller.
REACH Entry 79: EU PFHxA restriction deadlines and the UK gap
One of the clearest differences between the EU and UK is the regulation of PFHxA. In 2024, the EU added PFHxA, its salts and PFHxA-related substances to REACH Annex XVII as Entry 79.
The restriction sets a concentration limit of 0.025 mg/kg for PFHxA itself and 1 mg/kg for the total amount of PFHxA-related substances.
The transition periods are staggered by sector:
- 10 April 2026: most firefighting foams.
- 10 October 2026: clothing, footwear, food contact paper, cosmetics, and mixtures sold to the general public.
- 10 October 2027: non-clothing textiles.
- 10 October 2029: civil aviation firefighting foams.
The UK does not currently have a PFHxA-specific restriction in place. While the UK PFAS Plan identifies PFHxA as a substance of interest, there is no equivalent to the EU’s Entry 79 restriction as of mid-2026.
This means that a textile or footwear product that complies with the EU limit from October 2026 can also be sold in the UK. However, a product that exceeds the EU limit may still be legally placed on the UK market.
For brands selling into both markets, the key decision is whether to apply the stricter EU standard across all products or maintain separate specifications for the EU and UK.
The EU universal PFAS restriction explained (and why the UK is not following)
The EU’s most far-reaching PFAS proposal is the universal restriction submitted in January 2023 by five countries: Germany, the Netherlands, Denmark, Sweden and Norway. Norway is not an EU Member State but participates in REACH through the EEA agreement. ECHA’s scientific committees, RAC and SEAC, have both now completed their evaluations. RAC adopted its opinion in March 2026, and SEAC agreed its draft opinion the same month, with a public consultation running until May 2026. ECHA has indicated it supports a restriction with targeted derogations for certain uses.
The process has moved on significantly, and the file now sits with the European Commission to decide on the final form of any restriction. What is clear is that any version adopted would cover thousands of PFAS substances, not just individual chemicals. It would also affect a wide range of sectors, including consumer products, industrial applications and specialist uses.
The UK is taking a different approach. The PFAS Plan supports a phased, risk-based strategy that looks at sectors individually rather than introducing a single restriction covering the entire PFAS class.
As a result, even if the EU adopts a broad PFAS restriction in 2027 or 2028, the UK is unlikely to introduce an equivalent measure shortly afterwards. Businesses should not assume that UK compliance will simply follow the EU model with a delay of eighteen months.
France and Denmark PFAS bans: national rules going beyond EU REACH
Another growing area of divergence is action taken by individual EU Member States. Two countries in particular are moving ahead of the wider EU framework.
France adopted Law No. 2025-188 in early 2025, introducing a national ban on PFAS in several product categories, including certain cosmetics, ski waxes and various textile products. The restrictions begin to take effect on 1 January 2026. Companies selling textiles in France should check the latest requirements against Decree No. 2025-1376, as some of the transitional provisions in the original law have since been updated.
Denmark has gone even further. Statutory Order BEK nr 464 of 2 May 2025 bans PFAS in clothing, footwear and impregnation agents from 1 July 2026. The Danish rules are stricter than the EU baseline for two reasons. First, they apply before similar EU-wide restrictions take effect. Second, they use a total fluorine limit of 50 mg/kg across the entire product rather than focusing only on specific PFAS substances.
This approach can identify polymeric PFAS, short-chain alternatives and precursor substances that may not be detected through testing for individual PFAS compounds alone.
The UK has not introduced comparable national PFAS bans for specific product categories beyond the restrictions already contained in retained legislation. The PFAS Plan also does not commit to introducing similar measures.
As a result, the EU is becoming a faster-moving and more complex compliance environment, with additional requirements emerging not only at EU level but also within individual Member States.
PFAS in cosmetics, food contact and packaging: EU vs UK rules
The same pattern can be seen in sector-specific regulations.
In cosmetics, the EU added more PFAS substances to Annex II of Regulation 1223/2009 in 2024, placing them on the list of ingredients that cannot be used in cosmetic products. The UK retained the Cosmetic Regulation after Brexit and can choose to add the same substances to its own prohibited list. However, these changes do not happen automatically. Until the UK makes equivalent updates, a cosmetic product that is no longer compliant in the EU may still be legal to sell in Great Britain.
Food contact paper and board are another area of difference. In the EU, these products will be subject to REACH Entry 79 from 10 October 2026. The UK’s food contact materials framework is governed by separate legislation and does not currently include an equivalent PFHxA restriction.
Packaging provides one of the clearest examples of EU-UK divergence. The EU’s Packaging and Packaging Waste Regulation introduces restrictions on PFAS in food contact packaging, with key requirements beginning to apply from August 2026. The UK has not introduced an equivalent PFAS restriction for packaging.
PFAS testing methods and enforcement: EU vs UK
Enforcement differs between the EU and the UK, and so do the testing methods used to support compliance.
In the EU, enforcement is carried out by national market surveillance authorities, with ECHA providing coordination and guidance. Border inspections, market surveillance campaigns and product recalls are managed at Member State level. PFAS-related enforcement activity has increased in recent years, particularly in sectors such as textiles and cookware.
In the UK, enforcement responsibilities are shared across several organisations. The Health and Safety Executive oversees UK REACH, while the Office for Product Safety and Standards is responsible for wider consumer product compliance. The Department for Environment, Food and Rural Affairs leads overall chemicals policy and is responsible for the PFAS Plan. Enforcement activity has generally been less intensive than in the EU so far, although the PFAS Plan suggests that this may change in the future.
For many businesses, the bigger challenge is testing. Most PFAS restrictions, including REACH Entry 79, focus on specific PFAS substances and are typically assessed using targeted analytical methods such as LC-MS/MS.
Denmark has taken a different approach. Its rules are based on total fluorine content and are typically tested using combustion ion chromatography. The UK has not yet set out a detailed testing framework for PFAS compliance.
As a result, a supplier declaration supported by targeted PFAS testing may be sufficient for EU REACH compliance, may not satisfy a Danish market inspection, and may fall into a less clearly defined position in the UK.
EU and UK PFAS compliance: five practical steps for brands
There are a few practical takeaways from all of this.
1. Treat EU and UK compliance as separate projects.
The timelines, regulatory scope and, in some cases, testing requirements are no longer the same. The gap between the two systems is growing, not shrinking.
2. Build Entry 79 deadlines into product development plans now.
The October 2026 deadlines for clothing, footwear, food contact paper and cosmetics are approaching quickly. Any new product in these categories should have its PFAS compliance assessed well before launch rather than later in the process.
3. Monitor Member State rules as well as EU-wide legislation.
National measures such as Denmark’s restrictions from 1 July 2026 and France’s measures from January 2026 can take effect well before broader EU requirements. If you sell into France or Denmark, whether directly, through distributors or via online marketplaces, these rules may apply to your products.
4. Make sure suppliers understand the testing requirements.
A declaration that a product is “PFOA-free” or even “PFHxA-compliant” is not the same as a total fluorine test result. Where total fluorine testing is required, compliance evidence needs to reflect that requirement.
5. Treat the UK as a separate and evolving regulatory market.
The UK PFAS Plan is currently the best guide to the direction of future regulation. At this stage, it does not suggest that the UK will simply replicate REACH Entry 79 or adopt the EU’s proposed universal PFAS restriction at a later date.
Planning EU and UK PFAS compliance
PFAS is one area where EU and UK rules have clearly gone in different directions, and the gap is likely to grow over the next few years. If you sell products in both markets, it no longer makes sense to treat PFAS compliance as a single project. The EU and UK need to be tracked separately.
The October 2026 deadlines for clothing, footwear and cosmetics are not far away. If you have not already reviewed your products and supply chain for PFAS, now is the time to do it.
If you need help, Euverify works with businesses across both the EU and UK and can handle this workstream for you.
Sources
REACH Entry 79 — PFHxA Restriction: Commission Regulation (EU) 2024/2462 of 19 September 2024
EU POPs Regulation: Regulation (EU) 2019/1021
ECHA Universal PFAS Restriction Proposal (submitted January 2023, RAC & SEAC opinions ongoing)
UK PFAS Plan (published February 2026 by DEFRA) Denmark PFAS Ban — BEK nr 464 of 2 May 2025 (clothing, footwear and impregnation agents, effective 1 July 2026)
