CEC calls for clear rules on proposed EU Universal PFAS restriction

The European Footwear Confederation (CEC) is calling for clear rules on responsibility and compliance under the proposed EU Universal PFAS restriction, while supporting the transition towards PFAS-free footwear and leather goods
In a position paper published on the 19th of October, the CEC expressed support for the European Union’s objective of reducing emissions and exposure to per- and polyfluoroalkyl substances (PFAS), as well as the progressive elimination of intentionally used PFAS in the manufacturing of footwear and leather goods.
The organisation also supports the replacement of PFAS with safer alternatives wherever it is technically and economically feasible to do so, provided that these alternatives meet the required standards for performance, durability, and safety.
However, it also argues that the forthcoming restriction must distinguish clearly between the intentional use of PFAS, the presence of PFAS in supplied materials and components, the subsequent treatment of finished articles, and incidental contamination.
The CEC maintains that the responsibility for intentionally introducing PFAS into an article should rest with the economic operator. This includes activities such as waterproofing and stain-repellent treatments, as well as repairs, refurbishment, and replacement of components.
According to the organisation, “A manufacturer producing a shoe without intentionally using PFAS should not be regarded as having used PFAS when a PFAS substance was subsequently introduced by an independent operator”. It adds that ordinary transport, storage, distribution and retail handling should not constitute PFAS use or create regulatory responsibility in themselves.
The position paper also addresses the potential presence of PFAS in supplied materials, including treated leather, coated textiles, waterproof membranes, surface coatings, and adhesives. To manage this risk, the CEC recommends mainly relying on supplier declarations and technical documentation, supported by risk assessments and targeted analytical testing where justified. The organisation argues that systematically testing every component would place an unnecessary burden on the supply chain.
Furthermore, the Confederation stresses that total fluorine measurements should be treated as a screening tool rather than as conclusive evidence of the presence of PFAS or of regulatory non-compliance. Where a screening threshold is exceeded, companies should be permitted to demonstrate that the detected fluorine originates from a non-PFAS source before further targeted analysis is required.
The CEC acknowledges that suitable safer alternatives are not yet available for all applications, and that those that are may not offer the required level of performance, durability or safety. This is particularly relevant for protective, professional and high-performance footwear. The organisation therefore “calls for justified, time-limited transition periods” to enable the development, validation and adoption of alternatives.
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