Forever Chemicals in Beauty & Fashion: Navigating PFAS Regulation and Mass Litigation Risks Ahead
20 min read
PFAS in the Beauty and Fashion industry have been publicly debated before, but their constant detection in fashion and beauty products across the EU has reignited the regulatory debate with new global momentum. Most recently, an EU-wide ban on PFHxA, its salts, and PFHxA-related substances in textiles, apparel, footwear, and cosmetic products took effect on 10 October 2026. This ban is widely seen as a dress rehearsal for the far more sweeping comprehensive PFAS ban applicable to both sectors (amongst others). Initiated by five EEA states, the proposed ban is now firmly on the EU agenda, sharpening a regulatory landscape that has so far taken more of a substance-by-substance approach.
Meanwhile, the EU’s landmark product liability reform, due for transposition by December 2026, is rewriting the rules. Combined with growing PFAS exposure in textile and cosmetics supply chains, this sets the stage for consumer mass claims in Europe, as US litigation already foreshadows. For manufacturers / producers, brands, and retailers, the window to get ahead of PFAS in textiles and cosmetics across the EU is closing fast.
PFAS in Beauty & Fashion: Performance, Persistence and Product Liability
Built to perform. Made to last. But what happens when lasting performance becomes a lasting concern? Per- and polyfluoroalkyl substances (“PFAS”) have long helped beauty and fashion products deliver the properties consumers expect: rainwear that repels water, fabrics that resist stains and cosmetics that stay put. Yet the persistence that makes these substances useful also puts them under increasing scrutiny.
The term PFAS refers to a group of more than 10,000 industrially manufactured substances. Since the 1950s, they have been used in many products including consumer goods,1 and many industrial processes,2 in particular due to their water, dirt and grease-repellent properties. The same properties that make PFAS useful also present significant challenges: Being highly persistent in the environment, PFAS do not break down under normal conditions. Some PFAS are bioaccumulative, with concentrations building up in humans and the environment, including groundwater and surface waters.3 Due to the potential risks to health and the environment, as well as their widespread use, PFAS have become a key issue in regulation of chemical substances.
Beauty and fashion illustrate both their appeal and the challenges they present. In textiles, PFAS provide moisture , oil- and dirt-repellent properties relevant to rainwear, outdoor gear, workwear and medical textiles. Manufacturing and repeated washing can contribute to the release of PFAS from textiles into the environment. In cosmetics, PFAS offer waterproof, oil-repellent and smoothing properties. A December 2025 FDA4 study found 51 PFAS intentionally used as ingredients across 1,744 product formulations sold in the US, with eye shadows, face and neck products, eyeliners, face powders and foundations making up roughly 56% of all PFAS-containing cosmetics. Performance helps explain continued PFAS use, but the search for alternatives is already underway. Indeed, alternatives exist for a range of applications in both sectors; yet their suitability depends on the intended use, required performance and commercial availability. Meanwhile continued reports of non-compliant products highlight an immediate priority: Businesses need to address existing restrictions, not just prepare for future measures. The challenge is to balance product performance and compliance with an evolving regulatory landscape alongside transitioning to suitable alternatives, while the sector faces increasing EU regulatory demands under the EU’s circular economy ambitions at the same time.
The American Precedent: How US PFAS Enforcement Foreshadows European Corporate Exposure
For companies trying to predict where European PFAS liability is heading, the US courts may offer instructive parallels. US courts have spent many years defining the contours of corporate accountability in this area. Key procedural differences remain, such as punitive damages, jury trials and extensive pre-trial discovery in the US EU regulatory changes taking effect in 2026, especially the revised Product Liability Directive and the Representative Actions Directive, will bring parts of European PFAS product liability closer to the US approach, even though the EU’s collective redress mechanisms do not replicate the full reach and scale of US-style class actions.
The financial stakes are high in the field of PFAS-related litigation which is demonstrated by precedents in the US in the context of drinking water contamination: In 2017, DuPont and Chemours paid USD 671 million to settle around 3,550 personal injury claims tied to allegations of PFOA5-contaminated drinking water. That settlement followed a landmark class action against DuPont, in which an independent science panel established a “probable link” between PFOA exposure and disease. This finding set the blueprint for the wave of PFAS mass litigation that followed. In 2023, 3M settled with the US public water systems for USD 10.3 billion, while DuPont, Chemours and Corteva collectively paid USD 1.185 billion to resolve similar public water system liability claims. The full financial exposure of PFAS manufacturers is still far from being settled, with thousands of personal injury claims still pending nationwide.
PFAS in EU Product Law: Key Rules and Requirements
Although the EU PFAS litigation landscape is nowhere near the scale seen in the US, a similar picture might be drawn in the EU after all, and sooner than expected, also as regards product liability.
PFAS have been subject to EU product regulation for years, but the approach has remained fragmented, targeting only specific substances or groups of substances in selected sectors. This is now due to change. The EU is at a turning point in establishing a group-based universal PFAS regulatory framework under REACH, with a far-reaching group-based regulatory approach continuing its legislative journey. Coupled with the procedural reforms embedded in the revised Product Liability Directive, these developments could transform the EU product litigation landscape. The following sets out a concise overview of the key regulatory frameworks and upcoming changes most relevant to the textile and cosmetics industries.
The Status Quo in EU PFAS Regulation
Within EU legislation, PFAS in textiles and cosmetics are governed by three main regimes: the general chemical substances rules under REACH, the Regulation on Persistent Organic Pollutants (“POPs”), and the sector-specific Cosmetics Regulation.
REACH Regulation (EC) 1907/2006
REACH (Regulation (EC) 1907/2006), adopted in 2006, is the EU’s principal chemicals law. For textile and cosmetics companies, depending on their role in the supply chain, it sets the baseline in terms of substance registration and information communication duties and the conditions applicable to the use and making available of substances, including, for example, authorisation requirements or restrictions under Annex XVII. These restrictions are subject to concentration limits, derogations and transitional provisions. For manufacturers and users, substituting regulated substances or subgroups with permissible, technically suitable and available alternatives typically proves a complex process. In the context of PFAS, this process is further complicated if the chosen alternative shall not only ensure compliance with existing restrictions but also avoid allegations of “regrettable substitution”. Because substitution can move faster than the regulatory process for extending restrictions, including amendments to Annex XVII, the absence of a current restriction does not by itself resolve that concern.
POPs Regulation (EU) 2019/1021
Implementing the Stockholm Convention into EU law, the POPs Regulation (EU) 2019/1021 prohibits the manufacturing, placing on the market and use of substances listed in Annex I, including PFOS, PFOA and PFHxS, subject to unintentional trace contaminant (“UTC”) limits in recognition that these forever chemicals are somewhat omnipresent in manufacturing supply chains, raw materials and the environment, so that zero tolerance is technically unfeasible. The Regulation also imposes stockpile- and waste-management duties for prohibited or restricted substances. In essence, REACH and the POPs Regulation operate in parallel: While REACH manages risks of, most notably, chemical substances through registration, evaluation, supply chain communication, authorisation and restriction, the POPs Regulation’s focus is on eliminating or restricting a set of listed persistent organic pollutants.
EU Cosmetics Regulation (EC) 1223/2009
The EU Cosmetics Regulation (EC) 1223/2009 sets sector-specific safety rules for finished cosmetic products through ingredient controls, including a prohibition list (Annex II), a restricted-use list, and approved ingredient lists. PFAS are primarily addressed under Annex II, covering PFOS, its derivatives, PFOA and its salts.
2026 and Beyond: Developments and Upcoming Measures
In Force and in Effect: Regulation (EU) 2024/2462, amending Annex XVII to REACH, introduced a ban on PFHxA, its salts and related substances at or above specified concentration limits, with the restrictions applying in phases depending on the product category. On 10 October 2026 the restriction prohibiting the placing on the market or use, in a concentration equal to or greater than 25 ppb for the sum of PFHxA and its salts, or 1000 ppb for the sum of PFHxA-related substances, measured in homogeneous material, in textiles, leather, furs and hides in clothing and related accessories as well as footwear mixtures for the general public, food-contact paper and cardboard, and cosmetic products (with a later effective date of 10 October 2027 for other textiles, leather, furs and hides other than in clothing, and carve-outs for personal protective equipment, medical devices and construction textiles). Products in these categories placed on the market before the respective date of application benefit from a grandfathering clause and remain exempt from the corresponding restriction, provided that the supplier can demonstrate that they were placed on the market before the relevant date.
In Progress: The universal restriction proposal under REACH initiated by Germany, Denmark, the Netherlands, Norway and Sweden would restrict the manufacture, placing on the market and use of PFAS under REACH. It addresses roughly 10,000 substances, including PFAS on their own and in other substances, mixtures and articles, subject to proposed concentration limits (depending on the analytical method used): 50 ppm for total PFAS content, 25 ppb for any individual PFAS and 250 ppb for the sum of targeted PFAS. If adopted, it would have wide-ranging implications for substitution, product development and compliance across many sectors.6
The Risk Assessment Committee (RAC) adopted its final opinion in March 2026. The Socio-Economic Analysis Committee’s (SEAC) final opinion is now under preparation, expected for end-2026 and a decision of the EU Commission in 2027/2028. Binding restrictions could take effect around 2030/2031, after an 18-month general transition period; however, with time-limited derogations likely being available at least for certain sectors and uses. RAC favors the narrowest possible sector- and use-specific derogations (essentially limited to certain PPE applications and associated re-impregnating agents), while also accepting certain overreaching derogations in principle or subject to additional conditions. SEAC, in contrast, considers a full restriction unlikely to be proportionate and supports broader, time-limited derogations instead. Either way, the direction clearly points toward a universal restriction. Treating the transition period as a reason to wait is itself a risk.7
For textile and cosmetics companies, adoption of the proposed universal restriction would presumably require changes to supply chain management, production and product formulations, with significant operational and financial implications – in detail depending on the final regulatory approach for relevant consumer applications, transition periods and recycling. For instance, SEAC supports a time-limited derogation (subject to proof-of-origin requirements) for, inter alia, recycled textiles, but notes that such derogation would need to be carefully drafted to counter circumvention attempts.8
Beyond Brussels: PFAS Liability Is Already Taking Shape at the National Level
While the EU’s regulatory framework continues to evolve, PFAS are also coming into sharper focus for national authorities in key markets. Developments in France, Italy and Germany signal growing scrutiny, with initial issues emerging around contamination and other PFAS-related concerns. For companies in the textile and cosmetics sectors, these developments warrant attention beyond their immediate sectoral scope, given the importance of these markets both as locations for corporate headquarters and as sources of revenue.
France leads with a unilateral ban: France has banned PFAS in cosmetics, ski wax and consumer apparel / footwear containing PFAS above specified residual concentration limits since 1 January 2026, subject to exemptions for certain protective and recycled-content apparel / footwear and a 12-month sell-through period for products manufactured before that date.9 These prohibitions will extend to all textile products by 1 January 2030.10 Given France’s market weight, companies face a binary choice: a France-only PFAS-free line or full transition.
Italy shows that mass claims can succeed: The MITENI case11 is one of Italy’s largest environmental criminal proceedings. It resulted in the conviction of former executives over groundwater contamination in the Veneto region, with sentences totaling 141 years in prison and civil damages exceeding EUR 75 million.
Germany’s courts are already on board: On 13 April 2026, the Regional Court of Baden-Baden held a compost manufacturer waste disposal company, which had mixed PFAS-contaminated industrial waste with compost and spread it on agricultural land, liable in principle for PFAS contamination of groundwater feeding Rastatt’s municipal water utility, with the claimant seeking approximately EUR 6.5 million plus ongoing costs. The amount of damage is still to be determined, but the liability finding stands.12
The Cost of Non-Compliance: PFAS Liability and the Potential Wave of EU Mass Litigation
The rules on PFAS may be varied and only partially harmonised, but they share one trait: non-compliance can trigger civil claims and fines under multiple liability regimes at once. This creates fertile ground for mass litigation.
The EU litigation environment has shifted significantly since collective redress mechanisms came into force. Under the EU Representative Actions Directive (EU) 2020/1828), authorised entities can now pursue collective redress on behalf of entire consumer groups, pooling resources that turn individual grievances into serious financial exposure through litigation. Any company placing non-compliant products on the market faces material risk of mass claims and substantial fines, most obviously under product liability, but also under regimes companies may not immediately associate with PFAS.
The Revised PLD: A Risk Multiplier Built for Mass Claims
The main focus must be on product liability: The revised Product Liability Directive (PLD) (Directive (EU) 2024/2853) could materially increase PFAS litigation exposure by lowering the barriers to bring and win product-liability claims. The result: conditions for large-scale private enforcement with no precedent in European law.
The PLD must be transposed into national law by 9 December 2026. In Germany, the implementing law13 will enter into force on 9 December 2026, replacing the current Act on Product Liability14.
The Directive sets out when companies placing products on the EU market bear liability for damage caused by a defect. A product is defective if it fails to provide the level of safety a person is entitled to expect, or the level required under EU or national law.15 Caution: this wording points to two potentially distinct timelines, since the safety expectation applies as of today, while the national legal requirements each depend on domestic legislation, some of which has yet to be developed. For PFAS, liability attaches to breaches of REACH, the POPs Regulation and the EU Cosmetics Regulation, meaning any future PFAS ban or restriction automatically raises the safety bar. Liability covers death, personal injury and property16 damage, and rests primarily with the manufacturer or, outside the EU, the importer, authorised representative or fulfillment provider.17 The headline change for PFAS: the limitation period for latent health damage jumps from 10 to 25 years18, reflecting the long latency of PFAS-related harm and potentially exposing companies to claims over conduct that is decades old.
The Directive provides for disclosure of relevant evidence: where a claim is plausible, courts may order a defendant to disclose evidence within its control.19 For businesses, this reinforces the importance of accessible records on product composition, testing, supplier information and safety assessments.
A Procedural Turning Point: The Presumption of Causation Under Art. 10(4) PLD
Of all the PLD’s innovations, Art. 10 has the potential to have the greatest practical significance for PFAS litigation risk because it substantially lowers the claimant’s burden of proof. Under Art. 10(3), causation may be presumed once a defect is established and the damage matches a type typically linked to it.
Under Art. 10(4) PLD, where technical or scientific complexity makes full proof excessively difficult (which may be the issue with a given PFAS, depending on the scientific research), and the claimant demonstrates that it is likely that the product is defective or that a causal link exists, a court shall presume the defectiveness or the causal link. Lowering the bar from “certain” to “plausible” where proof would otherwise be excessively difficult marks a structural shift in how PFAS claims can be litigated, significantly lowering the standard claimants must meet. This shift is reinforced by the risk assessments underlying the REACH process, which found no reliably safe exposure level for certain PFAS, a finding likely to carry significant weight with courts even where applicable thresholds have not been exceeded.
Combined with collective redress under the Representative Actions Directive (EU) 2020/1828, European defendants now face a PFAS litigation environment unlike anything before. From December 2026 on, the pieces are in place for large-scale mass litigation. Companies that fail to adapt face mounting regulatory penalties and civil exposure alike.
PFAS Liability in Germany
Beyond the EU frameworks, national liability regimes add a further layer of exposure. Germany in particular presents a number of aspects that deserve closer examination.
Under German tort law20, companies face liability for damage from unlawful PFAS emissions affecting health, property or environmental assets, including consequential losses like agricultural damage or diminished property values. Regarding environmental damage to, in particular, waters, groundwaters and soil, the Environmental Liability Act21 and Environmental Damage Act22 add no-fault strict liability for listed installations and operators thereof, and further strict-liability regimes apply under the Federal Water Resources Act23, the Federal Soil Protection Act24 and state laws.
The German Product Liability Act adds strict manufacturer liability for damage from defective PFAS-containing products, including legacy products whose risks only surfaced after market entry.
Beyond PFAS: Avoiding Regrettable Substitution
For clothing and beauty product manufacturers using PFAS, substitution is a product-development and investment decision, not simply a change of ingredients. Potential alternatives include fluorine-free water-repellent finishes, wax coatings and plasma technology in textiles, and natural waxes, mineral pigments and alternative polymers in personal care products. The key question for each manufacturer is whether an alternative can deliver the required functionality, durability and consumer experience in the specific application, at an acceptable cost and with reliable supply at commercial scale. Adoption of bio-based or fluorine-free technologies by other brands can provide useful reference points, but does not by itself establish that a substitute is suitable for every product or manufacturing process.
Manufacturers also have an interest in ensuring that investment in reformulation delivers a durable solution rather than creating a need for another costly transition. Assessing potential substitutes therefore means looking beyond current restrictions to the available substance-specific safety data, the intended use and the prospect of further regulatory scrutiny. This is also important in addressing allegations of “regrettable substitution”, where a replacement is alleged to present risks similar to those associated with the substance it replaces. Cyclosiloxanes such as D4, D5 and D6 illustrate why non-PFAS alternatives should be assessed against their own hazard profiles and applicable restrictions, rather than treated as suitable merely because they are outside the PFAS family.
For manufacturers, the challenge is to make the transition count: preserving product performance and business continuity without laying the groundwork for another costly reformulation. Whether replacing a restricted PFAS with another currently permitted PFAS or moving to a non-PFAS alternative, permitted today does not necessarily mean suitable for the long term. A documented, application-specific assessment combining technical testing, supplier information and monitoring of regulatory developments can help manufacturers make informed choices, plan investment and reduce the risk of having to start again.
Industry Pulse: What Is Actually Happening in Beauty and Fashion
Recent testing, enforcement and litigation developments illustrate the practical importance of product verification and substantiated marketing claims.
Fast-fashion under the microscope
In May 2025, an independent testing by the Danish Consumer Council THINK Chemicals identified that several retailers including Temu sold waterproof jackets containing PFAS groups that were already forbidden under the current EU framework. This finding is a reminder that supplier assurances and marketplace compliance policies are no substitute for effective product-level verification. Risk-based testing, traceable sourcing and documented follow-up on non-compliant findings are critical to managing regulatory exposure and protecting brand credibility.
Premium brands are not shielded either
In April 2026, the Texas Attorney General issued a civil investigative demand to Lululemon to determine whether its activewear contains PFAS that “health-conscious customers would not expect”, despite the brand’s own claim to have phased out intentionally added PFAS since fiscal year 2023 and capped total organic fluorine at 50 ppm. The inquiry was framed as a consumer-deception question, not only a chemistry one, testing whether marketing claims matched the actual product. On 22 October 2026, the Attorney General announced an Assurance of Voluntary Compliance requiring Lululemon, for three years, to maintain and enforce its chemical safety requirements, including vendor compliance with its Restricted Substances List through independent laboratory testing or valid third-party certifications, verification of certifications and commercially reasonable corrective action for vendor noncompliance. Lululemon stated that the agreement reflected its existing practices, that the State had not identified PFAS in its products or materials, and that the agreement included no admission of wrongdoing or liability and no financial penalty. For brands whose commercial positioning relies on health and sustainability credentials, the outcome underscores the importance of substantiating marketing claims and demonstrating effective chemical-management programs across the supply chain.
Tighter technical thresholds are arriving
OEKO-TEX, whose certifications are widely used as a de facto industry benchmark, tightened its own PFAS limit to 25 µg/kg across all standards effective 1 January 2026, alongside stricter bisphenol limits and new biodegradability evidence requirements for its ECO PASSPORT label, with the full 2026 update applying from 1 June 2026. Because retailers and buyers routinely reference OEKO-TEX certification in supplier contracts, this shift is already moving down supply chains faster than the underlying EU legislation, effectively pulling forward compliance deadlines for anyone selling into certified programs.
Beauty’s greenwashing exposure is catching up
In the US, a federal court gave final approval in October 2025 to a USD 1.5 million class action settlement against Rust-Oleum over “Non-Toxic” and “Earth Friendly” claims on its Krud Kutter products, requiring permanent removal of the “Non-Toxic” claim and a qualifying disclosure for “Earth Friendly”. This case is now treated as the reference precedent for unsubstantiated safety claims. The beauty sector is not immune from the same playbook: A pending class action against Ulta Beauty alleges that products marketed under its “Conscious Beauty” clean-ingredient program actually contained ingredients on the brand’s own prohibited “Made Without List”. The read-across for PFAS is straightforward: “clean”, “non-toxic” and “free-from” claims on cosmetics and personal-care packaging are exactly the kind of unqualified environmental or safety marketing the FTC Green Guides and EU EmpCo regime are designed to catch, and PFAS-related claims sit squarely in that exposure zone once a product’s actual PFAS content diverges from its marketing.
Key Takeaways
Map current obligations and future change. Identify PFAS substances, uses, products and sales markets, then distinguish restrictions already applicable from proposals and later application dates. Assign responsibility for monitoring developments and maintain records supporting product composition and any reliance on transitional provisions.25 For sustainable compliance management, also be aware of and stay in tune with evolving improved PFAS testing methods and discussions about regulation of unintentional trace contaminants, a topic already having gained attention under the recent French ban of PFAS in cosmetics.
Verify products and supplier information. Use risk-based testing and appropriate supplier evidence to assess product composition and compliance. Distinguish intentionally added PFAS from contamination, and ensure that contracts support information access, corrective action and the allocation of compliance responsibilities.
Watch the US rear-view mirror. With representative actions now live across the EU, the multi-billion-dollar US PFAS litigation record is not a cautionary tale: It is a preview. European companies that wait for their own Krud Kutter or Ulta moment do so at their own peril.
Substitute with diligence. Assess alternatives against the required functionality, durability, safety data, cost and commercial availability. Document the basis for the decision and monitor further scientific and regulatory developments to reduce the risk of repeated reformulation.
1 For example, in cooking pots, rain jackets, cosmetics and heart implants, as well as plant protection products, active and pharmaceutical ingredients.
2 For example, as hydraulic fluids or in battery and chip manufacturing.
3 See EU Commission on PFAS Pollution: https://environment.ec.europa.eu/topics/chemicals/pfas-pollution_en.
4 See: United States Food and Drug Administration (FDA), Report on the Use of PFAS in Cosmetic Products and Associated Risks, available here https://www.fda.gov/media/190319/download?attachment, see also FDA, FDA Finds Insufficient Data to Determine Safety of PFAS in Cosmetic Products, https://www.fda.gov/news-events/press-announcements/fda-finds-insufficient-data-determine-safety-pfas-cosmetic-products
5 Perfluorooctanoic acid.
6 See also White & Case LLP, Europe’s PFAS restriction proposal is moving forward, Alert of 13 April 2026 (the “Alert on ECHA’s Scientific Committees’ Conclusions”).
7 See Alert on ECHA’s Scientific Committees’ Conclusions, noting that RAC accepts a general 18-month transition period from the restriction's entry into force, consistent with the approach employed in other legislation, with use-specific derogations of 5 or 12 years running from the expiry of that transition period; RAC does not support adoption of the numerous sector- or use-specific derogations proposed by the Dossier Submitters, except for limited PPE-related derogations. SEAC, by contrast, endorses a general concentration-limit-based ban combined with tailored, time-limited derogations and generally agrees with transition periods of 5 and 12 years, while noting that the specific time frames were chosen rather arbitrarily.
8 See Alert on ECHA’s Scientific Committees’ Conclusions. SEAC further notes that no recycling derogation is warranted for recycled metals, as concentration limits can be met at entry into force.
9 See Décret n. 2025.1376 du 28 décembre 2025 relatif à la prévention des risques résultant de l'exposition aux substances perfluoroalkylées et polyfluoroalkylées, available here: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053201526.
10 See TÜV-Süd report here: https://www.tuvsud.com/en/knowledge-hub/technical-updates/consumer-products-and-retail-essentials/france-new-pfas-limits-are-now-finalised.
11 For further case details, see https://chemtrust.org/news/italian_ruling_sentences_exectives_pfas_pollution/.
12 For further case details, see https://landgericht-baden-baden.justiz-bw.de/pb/,Lde/Startseite/Presse+und+Aktuelles/Klage+der+Stadtwerke+Rastatt+GmbH+gegen+die+Umweltpartner+Vogel+AG/?LISTPAGE=1151175.
13 Gesetz zur Modernisierung des Produkthaftungsrechts und zur Änderung weiterer Vorschriften.
14 Produkthaftungsgesetz.
15 See Art. 7(1) Directive (EU) 2024/2853.
16 See Art. 6(1) Directive (EU) 2024/2853.
17 See Art. 8(1) Directive (EU) 2024/2853.
18 See Art. 17 Directive (EU) 2024/2853.
19 See Art. 9 Directive (EU) 2024/2853.
20 Sec. 823 et seq. of the German Civil Code (BGB).
21 Umwelthaftungsgesetz
22 Umweltschadensgesetz
23 Wasserhaushaltsgesetz
24 Bundes-Bodenschutzgesetz
25 See Alert on ECHA’s Scientific Committees’ Conclusions, listing these measures as evidence of the Commission’s commitment to stringent PFAS regulation under the European Chemicals Industry Action Plan.
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