Denmark Introduces National Ban on PFAS in Clothing and Footwear

SG 148/25

Denmark has announced a national ban on the use of per- and polyfluoroalkyl substances (PFAS) in clothing, footwear and certain consumer products with waterproofing agents, starting July 1, 2026.

In a major step toward environmental protection and public health, Denmark has announced a national ban on the use of PFAS in consumer products. Executive Order BEK No. 464, issued on May 2, 2025, introduces strict controls on PFAS in clothing, footwear and related products, with the regulation set to take effect on July 1, 2026.

Under the new law, the import and sale of clothing and footwear containing total fluorine levels at or above 50 mg F/kg will be prohibited. This threshold also applies to waterproofing agents used for these products. The ban applies to both commercial traders and private individuals, ensuring comprehensive compliance across the supply chain. However, if the source of fluorine is confirmed to be from non-PFAS substances, the ban does not apply.

The regulation states that those restricted PFAS are defined as “any substance that contains at least one fully fluorinated methyl (–CF₃) or methylene (–CF₂–) carbon atom, without any hydrogen, chlorine, bromine, or iodine atoms attached.”* This broad definition is intended to encompass a wide range of PFAS compounds that are known for their environmental persistence and potential health risks. 

* Note: The Executive Order does not cover PFAS, which contain only the following structural elements: CF_3-X or X-CF_2-Xˈ, where X = -OR or -NRRˈ and Xˈ = a methyl group (-CH₃), a methylene group (-CH₂-), an aromatic group, a carbonyl group (-C(O)-), -ORˈˈ, -SRˈˈ or -NRˈˈRˈˈˈ, and where R/Rˈ/Rˈˈ/Rˈˈˈ is a hydrogen atom (-H), a methyl group (-CH₃), a methylene group (-CH₂-), an aromatic group or a carbonyl group (-C(O)-)

To facilitate a smooth industry transition, the Danish government has implemented a grace period allowing businesses to sell off existing stock until January 1, 2027. This transitional window is intended to minimize economic disruption while giving manufacturers and retailers time to adjust their product lines and sourcing practices to meet the new legal requirements.

After this date, full compliance becomes mandatory. The Danish Environmental Protection Agency (EPA) will oversee enforcement and noncompliance may result in severe penalties, including fines or imprisonment for up to two years, particularly in cases involving environmental harm or financial gain. Companies can also be held criminally liable for violations under the new framework.

Despite the severity of the Executive Order, it does contain several exemptions to accommodate specific use cases and existing regulatory frameworks. These exemptions cover professional safety clothing, personal protective equipment (PPE) governed by EU Regulation 2016/425, medical devices and products already regulated under the EU’s REACH and Persistent Organic Pollutants (POPs) frameworks. Additionally, the ban does not apply to transit goods and recycled or reused clothing/footwear.

Through this Executive Order, Denmark sets a precedent for stringent chemical regulation, aligning with global sustainability objectives. Companies operating in or exporting to Denmark should begin preparing now to ensure timely compliance, including reviewing supply chains, reformulating affected products and updating compliance documentation.

Reference:

Executive Order BEK no. 464

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