Manufacturers, retailers and brand managers in the footwear and clothing industry are confronted with a large number of legal requirements in the EU. These are decisive for the marketability of the products. The legal requirements can be divided into two main categories: Regulations on harmful substances and regulations on sustainability.
1) Regulations on harmful substances
One of the central requirements for regulating harmful substances is the REACH regulation, in particular Annex XVII. This lists specific substances for which defined limit values must be observed in certain applications - including chromium VI in leather or phthalates in plastics.
REACH Annex XVII - Restrictions
Another important regulation is the Verordnung über persistente organische Schadstoffe (POP-VO). Besonders relevant sind hier PFAS (per- und polyfluorierte Alkylsubstanzen), die als Hydrophobierungsmittel in zahlreichen Materialien Verwendung finden. Aufgrund ihrer Umweltpersistenz plant die EU ein umfassendes PFAS-Verbot. Einen Überblick zu aktuellen Entwicklungen finden Sie im Artikel „Regulations on PFAS in footwear: What manufacturers need to know now„.
The new PFAS analytical methods already show today: PFAS can be detected in textiles, microfibre fabrics, leather, foams and even in recycled materials. The limit values apply not only to end products, but also to intermediate materials.
Specific requirements for skin contact only apply in a few cases, such as nickel in metal parts. Violations are penalised by market surveillance and can lead to product withdrawal . The EU rapid alert system Safety Gate (formerly RAPEX) provides an overview.
In addition to the regulations mentioned above, the list of SVHC candidates (Substances of Very High Concern)- must also be taken into account. It currently comprises around 250 substances for which there is an obligation to provide information along the supply chain in order to increase safety in production. Although SVHCs do not directly affect marketability, they are crucial in communication with partners. You can read more about the latest additions in the article ‘SVHC candidate list July 2025 – Three new substances added’.
In addition, stricter requirements are often imposed by brands, associations and organisations. One example of this is the cads RSL, which provides annually updated requirements for harmful substances in shoes.
2) Regulations on sustainability
The UN Agenda 2030 defined 17 Sustainable Development Goals (SDGs). The EU Green Deal, presented in 2019, aims to make Europe climate neutral by 2050. The footwear and clothing industry is a particularly resource-intensive sector and is therefore a key focus. The article ‘The EU Green Deal and the associated commitments’ provides a concise overview of the impact on the industry.
As part of the EU Green Deal, the ESPR (Ecodesign for Sustainable Products Regulation) was adopted on 18 July 2024. This regulation sets requirements for products in terms of resource efficiency, durability, reparability, recyclability and the digital product passport. The first delegated acts for clothing are expected in 2026/2027 at the earliest, while those for footwear are still pending.
Ein zentrales Ziel der ESPR ist es, die Sustainability: messbar and vergleichbar zu machen – etwa durch die Einführung des Product Environmental Footprint (PEF). Für die Schuhproduktion bietet der PEF eine Möglichkeit, Umweltwirkungen systematisch zu erfassen und transparent darzustellen. Wie dies in der Praxis aussehen kann, zeigt der Artikel „PEF shoe production – making sustainability visible and comparable„.
The ESPR is supplemented by the Green Claims Directive, which aims to prevent greenwashing. Environmental claims must be verifiable. At the same time, banks and public contractors are increasingly introducing sustainability credentials as a prerequisite.
Even smaller companies that are not directly subject to statutory reporting requirements should prepare themselves: large trading partners are already actively demanding corresponding sustainability concepts.
The PFI test mark for shoes and the PFI Eco Label offer companies efficient ways to meet legal requirements and contribute to greater sustainability.
Do you have any questions? Our experts are here to help!
Dr. Ines Anderie
Chemical and Microbiological Analysis
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