CEC Seeks Clear Compliance Rules Under Proposed EU PFAS Restriction

The European Footwear Confederation (CEC) has called for clear regulatory responsibilities, proportionate testing requirements and time limited transition periods under the proposed European Union-wide restriction on per- and polyfluoroalkyl substances (PFAS), while supporting the transition towards PFAS-free footwear and leather goods.

In a position paper, the CEC backed the EU’s objective of reducing PFAS emissions and exposure, along with the progressive elimination of intentionally used PFAS in footwear and leather goods manufacturing. However, it stressed that the final restriction must distinguish between intentional chemical use, PFAS present in supplied materials, subsequent treatments of finished products and incidental contamination.

The Confederation said responsibility should rest with the economic operator that intentionally introduces PFAS into an article. For example, a footwear manufacturer should not automatically be held responsible if an independent operator later applies a PFAS containing waterproofing or stain repellent treatment. Ordinary transport, storage, distribution and retail handling should not, in themselves, constitute PFAS use or create regulatory liability.

The CEC also highlighted the potential presence of PFAS in supplied materials, including treated leather, coated textiles, waterproof membranes, surface coatings and adhesives. It recommended using supplier declarations, technical documentation and risk assessments as the primary basis for compliance, supported by targeted analytical testing where necessary. Systematic testing of every component, it argued, would impose unnecessary burdens on the supply chain.

Addressing chemical testing, the organization said total fluorine measurements should be used as screening tools rather than conclusive evidence of PFAS presence or regulatory non-compliance. Where a screening threshold is exceeded, companies should be allowed to demonstrate that the detected fluorine originates from a non-PFAS source before further targeted analysis is required.

The CEC further emphasized that compliance requirements for finished articles must remain distinct from responsibility for the intentional introduction of PFAS. Clear rules are particularly important for repair, refurbishment, resale and component replacement.

Acknowledging that suitable safer alternatives are not yet available for every application, the Confederation called for justified, time limited transition periods. These would allow manufacturers to develop, validate and adopt alternatives that meet performance, durability and safety requirements, particularly in protective, professional and high-performance footwear.

The CEC said clear responsibility, risk based due diligence and scientifically appropriate testing would support an effective and legally workable transition towards PFAS-free footwear and leather goods.