PFHxA limits reach Brazilian consumer goods on 10 October

From 10 October 2026, an EU importer cannot place an in-scope product on the market if a homogeneous material reaches either of two limits: 25 ppb for the sum of PFHxA and its salts, or 1,000 ppb for the sum of PFHxA-related substances. The rule is entry 79 of REACH Annex XVII, added by Commission Regulation (EU) 2024/2462. It applies to consumer clothing and related accessories made from textiles, leather, fur or hide; consumer footwear; paper and board used as food-contact materials; mixtures supplied to the general public; and cosmetic products.

The scope needs reading with some restraint. This is not the proposed universal PFAS restriction, nor a ban on every use of PFHxA. The October 2026 wave is tied to the listed product uses and measures concentration in each homogeneous material, not as an average across the finished product. Protective equipment for specified category III risks, medical devices, in-vitro diagnostic devices and construction textiles are excluded from the clothing and textile paragraphs. Other consumer textiles, leather, fur and hides outside clothing and related accessories follow on 10 October 2027, while firefighting foams have their own timetable and derogations.

REACH puts the formal compliance burden on actors established in the EEA. For a Brazilian exporter, that usually means the EU importer must stop a non-compliant import or sale; there is no small-volume escape, because Annex XVII restrictions can apply even where REACH registration is not required. The commercial burden still travels upstream. An importer cannot defend a rain jacket, handbag, shoe, cosmetic or coated food carton with a product name or a broad statement that no PFAS was intentionally added. It needs evidence that addresses the substances, thresholds and material layers in the rule.

Start with the bill of materials and the functions most likely to hide fluorinated chemistry: durable water or stain repellence, oil- and grease-resistant paper coatings, surface treatments, inks, adhesives and formulated consumer products. Ask each relevant supplier to identify the chemistry and provide a declaration or competent laboratory report that separately addresses the sum of PFHxA plus its salts and the sum of PFHxA-related substances, against 25 ppb and 1,000 ppb in homogeneous material. Match that evidence to the exact material, colourway, formulation, production site and lot where those variables can change; the regulation does not turn a generic certificate into proof for every SKU.

With only days left, triage goods that will first enter or be placed on the EU market from 10 October, agree the evidence standard with the EU importer and hold any SKU whose material file is unresolved. Substitution, retesting and relabelling do not fit comfortably into a customs delay, so the useful decision is whether a shipment is demonstrably compliant before it moves. An Opportunity Scan can map the affected SKUs, the EU party carrying the legal duty and the evidence gaps before a promising order becomes an avoidable market-access problem.