Regulations on PFAS in footwear: What manufacturers need to know now

PFAS regulations are increasingly becoming the focus of the footwear and textile industry due to the EU restrictions on perfluorinated and polyfluorinated alkyl substances (PFAS). But what exactly do the new regulations contain? What exemptions apply? And how should companies deal with uncertainties regarding materials and test methods? Dr Ines Anderie, Head of the Chemical Analysis Department at the Testing and Research Institute Pirmasens e. V. (PFI), provided answers to these questions as part of the international seminar series „2025 CADS RSL & PFAS Updates – Interpretation“.The most important information on the PFAS regulations have been summarised for you here.

Are there exceptions in the PFAS regulations for safety footwear?

Yes, regulations around PFAS provide for certain exemptions - for example for personal protective equipment (PPE) such as firefighting boots. Even after a complete PFAS ban comes into force, further exemptions could follow. Nevertheless, if you want to avoid or specifically test PFAS, you need to know the regulations in detail and must not make blanket assumptions about exemptions.

Do shoes that are not explicitly waterproof also have to be tested for PFAS?

The PFAS ban is not tied to specific materials or product types - it applies in principle. Even if some materials are still permitted, it remains unclear where PFAS could be present. In our investigations, we have also found PFAS in polyester and recycled polyester, for example.

Many manufacturers are unsure because different brands and institutions have very different requirements for PFAS tests. What is your advice in this case?

In our experience, it makes sense to use the PFAS list of the CADS Restricted Substances List (RSL) as a guide. This list contains the currently most relevant PFAS that are typically found in clothing and footwear - it is therefore a practical and sound basis.

If PFAS are used in a targeted manner, for example via sprays, they can usually be avoided. It becomes problematic when they are unintentionally introduced during material production - then even the suppliers are often unaware of their presence.

We therefore recommend having materials from suppliers checked regularly. A comparison should also be carried out for colour variants or batch changes.

One last question: Which test methods do you currently recommend? And is the previous method EN 17681:2022 still applicable?

The new test standard EN 17681-1:2025 was published on 30 April 2025 and replaces the previous version EN 17681-1:2022. From 31 October 2025, only the new standard will be valid.

This standard is much stricter and also recognises bound PFAS in material structures - in practice, this usually leads to higher measured values. Those who adhere to the PFAS regulations should therefore switch to the new test procedure at an early stage.

What counts now: Check, understand, act

The regulations surrounding PFAS remain complex - and present many companies in the footwear and textile industry with new challenges. This makes it all the more important to familiarise yourself with the new requirements at an early stage, to test relevant materials in a targeted manner and to work with reliable partners. The new test standard EN 17681-1:2025 and the orientation towards the CADS RSL list can eliminate many uncertainties - and take an important step towards sustainable product safety.

Do you have questions about PFAS regulations or would you like to have your products tested?

Contact our team of chemical analysis experts - we will be happy to answer your questions!