The CEC has published a position paper on the proposed EU Universal PFAS Restriction, setting out recommendations for its implementation in the footwear and leather goods industries.
The organisation supports the EU’s objective of reducing emissions and exposure to per- and polyfluoroalkyl substances (PFAS), as well as progressively eliminating their intentional use in footwear and leather goods production. Where technically and economically feasible, intentionally used PFAS should be replaced with suitable safer alternatives, provided these meet the required standards for performance, durability and safety.
However, the CEC argues that the regulation needs to distinguish clearly between the intentional use of PFAS, their presence in supplied materials and components, subsequent treatment of finished products and incidental contamination.
A key principle, according to the confederation, should be that responsibility follows intentional use. A footwear manufacturer that has not deliberately used PFAS should not be considered responsible for their use if the substances are subsequently introduced by an independent operator, for example during waterproofing, impregnation, repair or refurbishment. The same should apply to PFAS contamination resulting from ordinary transport, storage, distribution or retail handling.
The CEC also points to the complexity of footwear supply chains. PFAS may enter finished footwear through treated leather, coated textiles, waterproof membranes, adhesives, surface coatings or finishing systems, even if the footwear manufacturer has not directly used the substances.
Rather than requiring exhaustive testing of every component, the CEC is therefore advocating a risk-based due diligence system. Compliance should primarily rely on supplier declarations and technical documentation, supplemented by targeted analytical testing where identified risks justify it.
Testing methods themselves should also be proportionate. According to the CEC, total fluorine measurements should serve as a screening tool rather than automatically being regarded as proof of PFAS presence or regulatory non-compliance. Where thresholds are exceeded, companies should be given the opportunity to demonstrate that the fluorine detected comes from a non-PFAS source before further targeted analysis is required.
The confederation also warns that suitable safer alternatives are not yet available for every application. This is particularly relevant for protective, professional and high-performance footwear, where materials must meet specific performance, durability and safety requirements.
For applications where viable substitutes are not yet available, the CEC is calling for justified, time-limited transition periods to allow alternatives to be developed, validated and adopted.
