PFHxA Restriction Under REACH
What is the PFHxA restriction under REACH?
The PFHxA restriction is entry 79 of REACH Annex XVII. Commission Regulation (EU) 2024/2462 of 19 September 2024 added it [1]. It does not ban PFHxA outright. It sets two limits: 25 ppb for the sum of PFHxA and its salts, and 1 000 ppb for the sum of PFHxA-related substances. These limits apply to the consumer uses and firefighting-foam uses listed below, and they come in on staggered dates [2]. As of today (13 October 2026), the main consumer-product limits have just started to apply, on 10 October 2026.
Approach: I read entry 79 in the current consolidated REACH text, Regulation 2024/2462 and its recitals, and ECHA's Annex XVII restrictions list. The entry wording in ECHA's list matches the legal text.
What substances are covered
The entry covers PFHxA, its salts, and PFHxA-related substances that have either:
- a linear or branched C5F11- perfluoropentyl group directly attached to another carbon atom, or
- a linear or branched C6F13- perfluorohexyl group.
Three things are excluded:
- C6F14;
- C6F13-C(=O)OH, C6F13-C(=O)O-X′ or C6F13-CF2-X′;
- substances where C6F13- is attached to an oxygen atom at a non-terminal carbon.
"PFHxA-related" means any substance whose molecular structure could degrade or transform to PFHxA (para. 9) [2].
Where the limits apply and from when
Both limits (25 ppb and 1 000 ppb) apply in every case. For the uses in paragraphs 1 and 2 they are measured in homogeneous material.
| Para. | Use | Applies from |
|---|---|---|
| 4 | Firefighting foams and concentrates used for training and testing (functional system testing is exempt if all releases are contained) | 10 April 2026 |
| 4 | Firefighting foams and concentrates used by public fire services (exempt when they respond to industrial fires at sites covered by the Seveso III Directive 2012/18/EU and use the foam and equipment only for that) | 10 April 2026 |
| 1 | Consumer clothing and related accessories made of textiles, leather, furs and hides | 10 October 2026 |
| 1 | Consumer footwear | 10 October 2026 |
| 1 | Paper and cardboard food contact materials under Regulation 1935/2004 | 10 October 2026 |
| 1 | Mixtures sold to the general public | 10 October 2026 |
| 1 | Cosmetic products under Regulation 1223/2009 | 10 October 2026 |
| 2 | Other consumer textiles, leather, furs and hides (not clothing or accessories) | 10 October 2027 |
| 5 | Firefighting foams and concentrates for civil aviation, including civilian airports | 10 October 2029 |
Source for the table: [2]
Exemptions and transition rules
- Not covered by paragraphs 1 and 2:
- category III personal protective equipment (points (a), (c) to (f), (h) and (l) of Annex I to Regulation 2016/425);
- medical devices under the MDR (2017/745);
- in vitro diagnostic devices under the IVDR (2017/746);
- construction textiles.
- Not covered by paragraphs 1, 2, 4 and 5: substances with C6F13- attached to a sulphur atom that are already prohibited under Annex I of the EU POPs Regulation 2019/1021 (para. 6).
- Stock already on the market: paragraph 1 does not apply to articles and mixtures placed on the market before 10 October 2026, and paragraph 2 does not apply to articles placed on the market before 10 October 2027 (paras 7 and 8).
Source: [2]
Background
- Proposal: Germany submitted the restriction dossier on 20 December 2019. It proposed the same 25 ppb and 1 000 ppb limits but a much broader ban, with a general 18-month transition [3].
- ECHA committees: RAC (opinion of 3 June 2021) and SEAC (opinion of 8 December 2021) both found the proposal as drafted had not been shown to be the most appropriate measure [4][5]. SEAC backed restricting the specific uses that ended up in the final entry and proposed a 36-month transition instead of 18 months.
- Hazard basis: PFHxA "by far exceeds" the "very persistent" criterion in Annex XIII and is mobile in water. PFHxA itself is not registered in the EU, but its ammonium salt and several related substances are [6].
Other PFAS restrictions that interact with it
- PFAS in firefighting foams (entry 82, Regulation 2025/1988): this entry restricts all PFAS in firefighting foams above 1 mg/L from 23 October 2030. PFHxA uses already restricted under entry 79 are carved out of entry 82's ban, but PFHxA still counts toward entry 82's "sum of all PFAS" [7]. Entry 82's recitals explain that this carve-out covers the uses in paragraphs 4 and 5 of entry 79 [8].
- Universal PFAS restriction: Regulation 2024/2462 itself notes that PFHxA uses not caught by entry 79 also fall within the broader "PFAS in all other uses" restriction proposal, which was still pending when it was adopted [9].
When does it start applying?
The PFHxA restriction (REACH Annex XVII entry 79) has no single start date. It comes in four stages between 10 April 2026 and 10 October 2029. Two stages are already in force today (13 October 2026): firefighting foams from 10 April 2026, and the main consumer-product limits from 10 October 2026 [2].
Approach: I re-read entry 79 in the current consolidated REACH text (version of 11 May 2026).
| Applies from | Scope | Status today |
|---|---|---|
| 10 April 2026 (para. 4) | Firefighting foams and concentrates used for training and testing, and by public fire services. Exceptions: functional testing where all releases are contained, and Seveso-site industrial fires. | In force |
| 10 October 2026 (para. 1) | Consumer clothing and accessories (textiles, leather, furs, hides), consumer footwear, paper and cardboard food contact materials, mixtures for the general public, and cosmetics | In force since 3 days ago |
| 10 October 2027 (para. 2) | Other consumer textiles, leather, furs and hides | Not yet |
| 10 October 2029 (para. 5) | Firefighting foams and concentrates for civil aviation, including civilian airports | Not yet |
Source: [2]
The limits are the same at every stage: 25 ppb for the sum of PFHxA and its salts, and 1 000 ppb for the sum of PFHxA-related substances.
Stock already on the market: the 10 October 2026 limits do not apply to articles and mixtures placed on the market before that date. Likewise, the 10 October 2027 limits do not apply to articles placed on the market before that date (paras 7 and 8). Stock placed on the market before the cut-off can therefore keep being sold. The firefighting-foam stages (paras 4 and 5) have no equivalent derogation [2].
Does it cover cosmetics and food packaging?
Yes for cosmetics. For food packaging, only paper and cardboard. From 10 October 2026, paragraph 1 of entry 79 bans placing on the market or using PFHxA at or above 25 ppb (sum of PFHxA and its salts) or 1 000 ppb (sum of PFHxA-related substances), measured in homogeneous material, in two relevant product groups:
- point (e): cosmetic products as defined in Article 2(1)(a) of Regulation (EC) No 1223/2009;
- point (c): paper and cardboard used as food contact materials within the scope of Regulation (EC) No 1935/2004.
Approach: I re-read entry 79 of REACH Annex XVII in the current consolidated text (version of 11 May 2026).
Points to note
- Only paper and cardboard food packaging is covered. Entry 79 names only paper and cardboard food contact materials. It does not list plastic, coated-metal or other food contact materials, so those are outside this restriction.
- Cosmetics are covered by their legal definition. The ban applies to any product that meets the Cosmetics Regulation definition. Entry 79 does not limit this to consumer products, unlike the clothing, footwear and mixtures points, which are limited to the general public.
- Stock already on the market can still be sold. Under paragraph 7, paragraph 1 does not apply to articles and mixtures placed on the market before 10 October 2026. Cosmetics and paper or board packaging already on the market before that date can therefore stay on sale.
- Exemptions in paragraph 3 don't apply here. Paragraph 3 exempts category III PPE, medical devices, IVDs and construction textiles. None of these affects cosmetics or food packaging.
- The POPs carve-out still applies. Under paragraph 6, substances with C6F13- attached to a sulphur atom that are already banned under Annex I of the POPs Regulation (EU) 2019/1021 are excluded from entry 79. This holds for these uses too.
If it would help, I can next check whether other EU instruments restrict PFAS in food contact materials or cosmetics.