1. The "Pizza Box" Rule (Hidden Risk)
While most industry attention is focused on outdoor clothing, Paragraph 1(c) of Entry 79 explicitly restricts "paper and cardboard used as food contact materials". This is a massive disruption for the fast-food and bakery sectors.
Items like pizza boxes, burger wrappers, and popcorn bags—often treated with PFAS for oil/grease resistance—must comply with the strict 25 ppb limit by 10 October 2026. If your packaging relies on legacy C6 chemistry, you have less than 24 months to reformulate to PFAS-free alternatives.
The Precursor Trap
Passing the 25 ppb test for PFHxA is not enough. You must also pass the 1000 ppb limit for "PFHxA-related substances" (Precursors). Many products fail compliance because labs test for the acid but ignore the salts or precursors.
2. The Carpet Extension (2027)
The European Commission acknowledged that finding alternatives for heavy-duty interior textiles is technically challenging. Therefore, the regulation grants a 12-month extension for "textiles other than clothing" used by the general public.
The deadline of 10 October 2027 applies specifically to:
- Carpets and Rugs
- Curtains and Blinds
- Upholstery fabrics (Sofas, Chairs)
- Textile Wall Coverings
Warning: Rain jackets, shoes, and bags are classified as "Clothing/Accessories" and do NOT get this extension. They must be compliant by 2026.
3. The "Stockpile Shield" (Grandfather Clause)
Paragraphs 7 & 8 contain a critical legal nuance: The restriction applies to articles "placed on the market".
This means retailers do not need to destroy inventory sitting in EU warehouses on the deadline day. If an item was manufactured in the EU or imported (cleared customs) before midnight of the deadline (Oct 10, 2026/2027), it remains legal to sell indefinitely.
4. Critical Exemptions
Certain high-performance categories are totally exempt from this restriction due to safety requirements or lack of viable alternatives:
- PPE Category III: High-risk safety gear (e.g., firefighter suits, chemical protection).
- Medical Devices: Implantable devices are fully exempt.
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