The C&A “Iconic Puffer” Case
A recent example involves a Greenpeace Austria investigation into C&A’s “Iconic Puffer” jackets. According to Greenpeace Austria, laboratory testing detected PFAS in several jackets, with some results reported to exceed limits applicable to specific regulated PFAS substances.
C&A responded that its products complied with the applicable legal requirements based on testing conducted by external, internationally accredited laboratories. The company also stated that the Greenpeace findings were connected to a newer PFAS testing approach that had not previously formed part of the relevant legal product assessments.
While the details of this specific case remain subject to differing interpretations, it illustrates an important point for the textile industry: changes in sample preparation and analytical methodology can significantly influence measured PFAS results.
Why PFAS Testing Results Are Changing
Per- and polyfluoroalkyl substances, commonly referred to as PFAS, are often called “forever chemicals” because of their high persistence in the environment. In textiles, PFAS have historically been used in durable water-repellent finishes to provide water, oil and stain repellency.
As regulators move towards broader PFAS restrictions, analytical methods are also evolving to detect these substances more comprehensively.
A key development is the European standard:
EN 17681-1:2025 – Textiles and textile products – Per- and polyfluoroalkyl substances – Part 1: Analysis of an alkaline extract using liquid chromatography and tandem mass spectrometry
This method introduces strongly alkaline methanol during sample preparation. This can hydrolyse certain fluorinated polymers and esters, releasing PFAS that can subsequently be measured using liquid chromatography-mass spectrometry.
As a result, substances that were not detectable to the same extent using previous sample-preparation methods may now be measured during analysis.
This means that:
- Products previously tested using older methods may show higher measurable PFAS levels when analysed using updated methods.
- The product formulation may not have changed, but the updated sample preparation can release PFAS that were not captured to the same extent by previous methods.
- Different analytical approaches can influence regulatory assessments, internal risk evaluations and market-surveillance results.
EN 17681-1:2025 is a European testing standard. However, the publication of a standard does not automatically make it a legally mandatory EU compliance method. Its legal relevance depends on whether it is referenced by applicable legislation, authorities, contractual requirements or certification systems.
Increasing Regulatory Pressure on PFAS
PFAS regulation is tightening rapidly worldwide. Several developments are already shaping the regulatory landscape for textile brands, retailers and manufacturers.
At EU level, the proposed universal PFAS restriction continues to progress through the REACH restriction process.
ECHA’s scientific committees support an EU-wide restriction with targeted derogations, but the final legal requirements, transition periods and application dates have not yet been adopted.
Companies should therefore continue monitoring the regulatory process rather than treating the proposal as final legislation.
At the same time, some countries are already introducing national restrictions on PFAS in consumer products.
France
For example, France introduced PFAS restrictions for consumer clothing textiles and footwear from 1 January 2026, subject to defined thresholds, exemptions and transitional provisions. Certain professional clothing, personal protective equipment and specialised products may fall outside the initial scope or qualify for exemptions. France intends to extend the restrictions to a broader range of textile products from 1 January 2030.
Denmark
Denmark’s national PFAS rules entered into force on 1 July 2025, followed by a 12-month transition period. The prohibition on importing and selling PFAS-containing consumer clothing, footwear and certain impregnation products has applied since 1 July 2026. Products already held in stock may, under the applicable transitional conditions, continue to be sold until 1 January 2027. Professional clothing, business-to-business sales, home textiles and certain personal protective equipment are not generally covered by the Danish consumer-product prohibition.
These national measures demonstrate that companies may face different requirements depending on the product category, intended use and target market.
Market Surveillance Is Also Evolving
Market surveillance by authorities and non-governmental organisations is increasing. Products already available on the market may be examined using current analytical methods, even when earlier compliance assessments used different testing approaches.
This creates a new challenge for companies. Products that previously passed internal checks may be reassessed using updated sample preparation, expanded substance lists or different analytical thresholds.
For this reason, historical test reports should not always be treated as sufficient evidence for future market access.
OEKO-TEX® Applies PFAS Testing Methods
OEKO-TEX® currently applies PFAS analysis in accordance with DIN EN 17681-1:2025 for OEKO-TEX® STANDARD 100, OEKO-TEX® ORGANIC COTTON, OEKO-TEX® LEATHER STANDARD and OEKO-TEX® ECO PASSPORT testing.
The method uses strongly alkaline methanol during sample preparation, enabling the hydrolysis of certain fluorinated polymers and esters and the subsequent release of measurable PFA
This proactive approach supports the assessment of products using current, state-of-the-art analytical methods that reflect evolving certification requirements and regulatory expectations.
Regular certification updates therefore help ensure that products continue to meet current OEKO-TEX® testing requirements and substance limits.
Maintaining valid OEKO-TEX® certification supports product safety and compliance management, but companies must also assess the specific legal requirements applicable to each product and target market.
Why Voluntary PFAS Pre-Testing Can Protect Brands
With testing methods evolving and regulations tightening, many brands and manufacturers are reassessing their PFAS compliance strategies.
Voluntary PFAS testing using current analytical methods can help companies:
- Identify potential PFAS risks before regulatory inspections, NGO investigations or market-surveillance activities occur.
- Assess products against new and upcoming regulatory requirements.
- Verify supplier declarations and chemical-management processes.
- Protect brand reputation and consumer trust.
- Reduce uncertainty when placing products on European markets.
- Identify materials or formulations that may require substitution.
In many cases, early testing gives companies time to adjust materials, coatings, membranes or chemical formulations before new regulatory deadlines become applicable.
Preparing for the Next Phase of PFAS Regulation
The textile industry is entering a period of significant regulatory and analytical change regarding PFAS.
Recent market cases demonstrate that compliance risks can arise not only from a product’s formulation but also from changes in the methods used to extract, detect and quantify substances.
For brands, retailers and manufacturers, two measures are particularly important.
1. Maintain Up-to-Date Certification
Certification schemes such as OEKO-TEX® STANDARD 100 require regular renewal and assessment against the applicable OEKO-TEX® criteria.
Maintaining valid certification supports regular assessment against the applicable OEKO-TEX® criteria but does not replace a market-specific legal compliance assessment covering the product category, intended use and country of sale.
2. Conduct Proactive PFAS Pre-Testing
Voluntary testing using current PFAS methods allows companies to identify potential risks before market-surveillance activities, regulatory inspections or public investigations occur.
A proactive testing strategy can help companies:
- Anticipate upcoming European PFAS restrictions.
- Prepare for national regulations such as the Danish import and sales restrictions applicable since 1 July 2026.
- Assess products using current analytical methods.
- Improve supplier communication and chemical traceability.
- Make informed decisions about material and chemical substitution.
- Strengthen documentation for customers and market authorities.
With regulatory pressure increasing and testing methods evolving, early testing and transparent chemical management are becoming essential elements of textile compliance strategies.
How OETI Can Support Your PFAS Strategy
OETI supports brands, retailers and manufacturers with PFAS testing using current analytical methods within the OEKO-TEX® scope.
In addition, we have developed an innovative Non-Targeted PFAS Analysis method. This approach uses high-resolution mass spectrometry and database screening to screen for more than 10,000 known, emerging and potentially unidentified PFAS signals.
Non-targeted analysis can help companies identify potential PFAS risks beyond conventional targeted substance lists and prepare for future regulatory and customer requirements.
Do not wait until an updated test method or new restriction exposes an unexpected compliance risk. Proactive PFAS testing can provide the data needed to protect market access, strengthen chemical management and build long-term trust.
Contact OETI to discuss the right PFAS testing strategy for your products and target markets.
