The intersection of fast fashion and environmental regulation is under increasing scrutiny, with particular focus on the use of per- and polyfluoroalkyl substances (PFAS), often referred to as “forever chemicals.”

The widespread use of PFAS in textiles has led to intense regulatory and public scrutiny because of their potential capacity to persist in a wide range of environments and alleged health risks – from manufacturing and washing through the disposal of garments. This has prompted calls for stricter regulation and pressure for greater transparency across the fashion industry.

As regulators move to address the alleged risks associated with PFAS, companies in the fashion sector face a rapidly evolving compliance landscape.

For fashion companies, this is more than just a regulatory issue. As governments worldwide – from the EU and UK to the United States and beyond – develop their own approaches to PFAS regulation, the industry faces a fast-changing and fragmented compliance landscape. The global nature of supply chains only compounds the challenge, making PFAS a test case for how fashion balances performance, affordability, and sustainability.

PFAS in fast fashion

In the context of textiles, PFAS are a group of synthetic chemicals prized for their durability, water and stain resistance, and ability to repel oil and grease. They are commonly used in fashion for water-repellent outerwear and sportswear, stain-resistant treatments for garments and footwear, and durable coatings for accessories and bags. 

However, PFAS are also classified as so-called “forever chemicals” that are difficult to break down and that remain in the environment. Their widespread but often hidden presence in clothing means that what looks like a performance feature may give rise to consumer and regulatory concerns about alleged long-term health and environmental costs; and because fast fashion supply chains are complex and opaque, with patchy regulation across countries, it is difficult for brands and consumers alike to know whether harmful levels of PFAS are being used.

Although understanding the link between “performance fabrics” and “forever chemicals” helps consumers make more informed choices, it also puts pressure on brands to adopt safer, more transparent practices.

Regulatory and policy developments

European Union

The EU remains at the forefront of PFAS regulation, with several significant initiatives. The EU’s broader sustainability agenda, including the Green Deal and the Circular Economy Action Plan, is driving further scrutiny of potentially hazardous chemicals in consumer goods, with textiles identified as a priority sector.

PFAS are more specifically addressed in the EU Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) regulation, which requires producers and importers of chemical substances or mixtures to ensure their safe use and to provide information on toxicity, ecotoxicity, and the fate of the substance in the environment. The EU already restricts specific PFAS, such as perfluorooctanoic acid (PFOA) and perfluoro octane sulfonate (PFOS) in textiles and other products.

Various other EU legislation indirectly addresses PFAS in textiles. The proposed EU Strategy on Circular and Sustainable Textiles aims to make textiles more sustainable, but does not include a specific focus on PFAS. However, there have been recent proposals from some EU member states for a universal restriction in the EU to reduce PFAS in textiles throughout the value chain. 

The EU’s regulatory direction signals a tightening environment for PFAS use. For brands, this means higher compliance costs, supply chain challenges, and potential reputational risks if they lag behind. For consumers, it means growing pressure on retailers to offer PFAS-free alternatives. Globally, the EU often sets the standard, and this means that EU policy could reshape practices across the wider fashion industry.

United Kingdom

The UK has adopted a precautionary approach to PFAS regulation post-Brexit, aligning closely with EU standards. Coverage of PFAS in the UK includes the UK REACH regime, which currently restricts certain PFAS, such as PFOA and its derivatives, and perfluorinated silane, in line with EU restrictions. 

The UK General Product Safety Regulations 2005 imposes requirements on the safety of products for consumers. It does not specifically ban PFAS but sets out an obligation to only place products on the market that are “safe” (i.e., that do not present any risk or only minimum risk compatible with the product’s use, consistent with a high level of protection of health and safety). While PFAS are not explicitly banned, noncompliance could trigger penalties, requirements for warning labels, or suspension or withdrawal from the market.

For UK businesses, the lack of an explicit PFAS ban does not mean a free pass. Companies that fail to anticipate regulatory scrutiny or consumer pressure could still face significant commercial and reputational risks if their products come to be perceived as tainted or allegedly unsafe by regulators or the public.

United States

The U.S. regulatory landscape is multilayered, with action at both federal and state levels. While the position in the United States may vary between states, there is a clear move toward the prohibition of PFAS intentionally added into clothing. These regulatory changes will impact clothing businesses operating within the United States. 

Several states have enacted or proposed bans on PFAS in textiles, with varying implementation timelines. For example, since January 2025, California’s AB 1817 has prohibited the sale of most PFAS-treated textiles. Manufacturers must certify that their clothing products do not contain regulated PFAS substances. New York has restricted PFAS in clothing, phasing in restrictions under section 37-0121 of the Environmental Conservation Law with a ban applying beginning in 2028. In Colorado, which is proposing a ban on PFAS, products using PFAS can be sold at present if they contain the notice, “made with PFAS chemicals.”

The United States has generally seen a surge in litigation related to alleged PFAS contamination and consumer protection, with fashion brands increasingly targeted for alleged misrepresentation or failure to disclose PFAS content. 

Noncompliance with PFAS restrictions can result in product recalls, fines, and loss of market access, particularly in the EU and in those U.S. states with stringent bans. Managing reputation risk through compliance management is an important element in addressing PFAS in the fashion supply chain.

Legal and compliance risks

The evolving regulatory landscape presents a range of legal and compliance risks for companies in the fast fashion sector. Fast fashion’s global supply chains make it challenging to monitor and control PFAS use, increasing the risk of inadvertent noncompliance. Public awareness of PFAS risks is growing, and brands associated with forever chemicals may face consumer backlash and negative media coverage.

The end of forever chemicals in fashion?

Fast fashion can no longer ignore PFAS. Mounting regulatory scrutiny, lawsuits, and consumer demand for transparency mean the industry must act now. Proactive engagement with suppliers, robust compliance programs, and investment in PFAS-free alternatives are not just risk mitigation strategies; they are the key to staying competitive and relevant in the fashion market of the future.