PFAS in textiles in Europe’s circular economy

The briefing is underpinned by a consultancy report, An assessment on PFAS in textiles in Europe's circular economy, which offers additional technical details.

How PFAS are used in textiles

It is estimated that more than 10,000 different PFAS compounds exist, but it is not known how many of these can be found in textiles. Both non-polymeric and polymeric forms of PFAS are used in textile products to provide properties such as water repellence, oil repellence, stain resistance, durability and thermal stability.

Textiles account for approximately 35% of total global PFAS demand. In line with this estimate, the WSP reports that one third of all PFAS in the EU — between 41,000 to 143,000 tonnes — are used in the textile sector (WSP, 2024). Textiles are one of the biggest sources of PFAS pollution in the EU. PFAS are used in clothing, home textiles, leather and technical applications. Polymeric PFAS constitute over 75% of PFAS in textile products and are used to provide functional properties (WSP, 2024). Both polymeric and non-polymeric PFAS can be released during a product’s lifespan, including when textiles are washed.

In 2020, the average European consumed 14.8kg of textiles (6.0kg of clothing, 6.1kg of household textiles and 2.7kg of shoes) per year (EEA, 2022). The growth in textile consumption, including through fast fashion, has led to significant amounts of PFAS entering waste streams, with over half of disposed textiles going to landfill or incineration (European Parliament, 2022).

The majority of textiles consumed in Europe are imported  from countries in Asia, which commonly apply less stringent chemicals legislation than EU manufacturers. This means that there is very little information about the content of PFAS in imported textiles. Sorting, reuse and recycling capacities in Europe are limited. Therefore, most used textiles collected in the EU are exported to Africa and Asia, including those containing PFAS, where they are sorted and then resold and recycled or dumped or burned in the local environment (EEA, 2023).

Environmental and human health impacts of PFAS in textiles

PFAS have the potential to contaminate drinking water, indoor environments and the wider ecosystem. The environment, wildlife and humans are exposed to a large number of PFAS compounds. Due to their high persistence they will accumulate over time, posing potential risks to human health and the environment (WSP, 2024).

These potential long-term impacts on environmental and human health will gradually increase over time if PFAS continue to be emitted. Other concerning properties that are present in some PFAS include the potential for bioaccumulation in living organisms, high mobility (they can move through the environment and pollute drinking water sources, for example), long-range transport potential  (they can pollute areas far away from emission sources), accumulation in plants (they can pollute food sources) and (eco)toxicological effects that may impact humans and the environment (BAuA et al., 2023).

Figure 1 summarises the potential environmental and human exposure to PFAS during different phases of the lifecycle of textiles. Workers and/or consumers are exposed directly via the manufacture, sale and use of textiles containing PFAS, and indirectly via the ingestion of food and water contaminated with PFAS released from textiles and textile production. Environmental exposure through releases to air and water happens during PFAS manufacturing, textiles manufacturing and sales, use and end of life, while release to soil typically happens at the end of life through landfill.

Figure 1. Environmental and human exposure to PFAS from different phases of the lifecycle of textiles

A recent initiative, Human Biomonitoring for Europe (HBM4EU) measured four of the most well-studied PFAS compounds (PFOS, PFOA, PFNA and PFHxS) in blood from teenagers in nine European countries. Long-term exposure to these PFAS has been shown to weaken the immune system, is associated with endocrine disruption and is suspected of increasing the risk of developing cancer. For the 2014 to 2021 study period, the risk of adverse health effects from the four PFAS could not be excluded, on average, for 14.3% of the tested teenagers (Figure 2) (EEA, 2024b).

The four measured PFAS are currently banned in textiles in the EU. However, since some of them were restricted quite recently (PFOS since 2008, PFOA since 2020, and PFNA and PFHxS since 2023) they may be present in textiles still in use that were sold before the restrictions entered into force.

Figure 2. Percentage of European teenagers with PFAS blood levels exceeding the health-based guidance value (2014-2021)

Note: Based on human biomonitoring data from the HBM4EU Dashboard.

The current level of knowledge about human toxicity and ecotoxicity is limited to a relatively small number of compounds (including the four PFAS mentioned above), as illustrated in Figure 3 below.

Until recently, regulatory authorities mostly focused on non-polymeric PFAS since these can be taken up by living organisms. In contrast, polymeric PFAS are generally not easily taken up by living organisms due to their larger molecular sizes (WSP, 2024). However, the degradation of both polymeric and non-polymeric PFAS into smaller, persistent and bioavailable compounds is an environmental and human health concern. Hence, the presence of polymeric PFAS in the environment may be a significant long-term source of non-polymeric PFAS (OECD, 2022).

Figure 3. Level of knowledge of human health and environmental impacts of PFAS

Overall, textiles are a major contributor to PFAS emissions to the environment due to their consumption by the textile industry. PFAS can be released by various processes during textile production, use, washing, handling and end-of-life treatment (WSP, 2024).

There is insufficient information to adequately assess the impacts of the majority of PFAS, including most of those that are currently used in textiles. However, there is growing concern about the harmful effects of the entire family of PFAS, given that impacts similar to the well-studied PFAS may be also expected for the less-studied substances (BAuA et al., 2023).

Longer use, reuse and recycling of textiles are beneficial from many environmental and climate perspectives. But this also amplifies the risk of exposure by extending the duration of PFAS in circulation, thereby prolonging potential environmental and health risks in the EU and in other regions of the world through used textiles exported by the EU. Although the prolonged use and reuse of textiles typically expose individuals and the environment to PFAS via similar pathways as during their initial use, repurposing these textiles may pose increased environmental and health risks. This is especially the case for vulnerable users (e.g. use for children or children’s toys may pose a greater risk than use for a specific technical application). Recycling heightens the risk of contaminating a broader range of products. This can result in the uncontrolled exposure to PFAS without a means of tracking their presence.

Implications of PFAS in textiles for the shift to a circular economy

The use and presence of PFAS in textiles presents some challenges to the shift to a more circular textiles economy in Europe. These challenges can be mitigated through a number of different strategies, including by:

• finding safe and sustainable alternatives for PFAS in textiles;
• tracing PFAS in textiles before and during use;
• identifying, separating and sorting PFAS after use or at end of life;
• better incineration techniques and avoiding landfill; and
• minimising impacts beyond the EU.

Each of these strategies are discussed below.

Finding safe and sustainable alternatives for PFAS in textiles

The dossier for a universal restriction of PFAS under REACH includes an assessment of alternatives that can be used to provide the desired properties to textiles. It is important to note that the evaluation was performed by the five national authorities that have submitted the dossier. The ongoing process will also need to consider the results from two public consultations before final opinions are issued by ECHA’s Committee for Socio-economic Analysis (SEAC) and Committee for Risk Assessment (RAC). It should therefore be considered a work in progress. Some of the initial conclusions concerning the availability of technically and economically feasible alternatives might change. Nevertheless, it currently provides the most comprehensive and up-to-date assessment of alternatives available.

According to the published restriction dossier, technically feasible alternatives are available to substitute PFAS in the majority of the different categories of textiles. These include home textiles, consumer apparel, professional sportswear and footwear; some, but not all, types of personal protective equipment; outdoor technical textiles; and leather and textile sprays.

However, for some categories of textiles, alternatives are currently lacking or there is inconclusive evidence to assess their technical and economic feasibility. These include some types of personal protective equipment (e.g. for firefighters), largely due to required flame retardancy functionalities. They also include high performance membranes and medical textile applications (e.g. to protect from exposure to body fluids) (BAuA et al., 2023). In conclusion, the available information indicates that alternatives are available for home and consumer textiles, whereas it will be more challenging to move away from PFAS for professional and technical textiles.

In the Chemicals Strategy for Sustainability, the European Commission described its vision for the Safe and Sustainable by Design (SSbD) approach, which is currently under development. SSbD will be a useful tool for industry that can be used in the design phase to identify and develop safe and sustainable chemicals and materials as alternatives to PFAS for those textile categories where alternatives are not yet available.

Tracing PFAS in textiles before and during use

Except for a few PFAS that have been identified as substances of very high concern (SVHC), it is often extremely difficult to get information on the presence and type of PFAS in textiles produced outside the EU that are sold in the EU. This is because the registration obligation in REACH does not extend to polymers or finished products (i.e. ‘articles’ in REACH terms), including textiles. There may also be a lack of technical understanding among suppliers and manufacturers outside Europe regarding PFAS, difficulties in controlling and communicating requirements up the supply chain, and hesitation among suppliers to disclose information about their products.

Regional differences in the importance placed on PFAS transparency, both within the EU and globally, hinder a unified drive for openness. Small and medium-sized enterprises (SMEs) often lack resources to trace and address PFAS in their supply chain, with competing regulatory demands taking precedence. Action tends to be taken only when legally required, as there is little incentive to invest resources in non-mandatory activity.     

Enhancing communication and information within the supply chain can be accomplished to some extent through voluntary initiatives, such as updating supplier policies and building stronger relationships with suppliers and buyers. Retailers and manufacturers can use existing guidance documents and tools to improve their understanding of their supply chain and relay this information downstream.

EU regulations that improve the tracking of substances of concern throughout the life cycle of products are an important step in providing greater transparency and visibility downstream (e.g. to waste handlers). This could be achieved, in particular through the implementation of the Ecodesign for Sustainable Products Regulation (ESPR) for certain products. These include textiles (as part of information conveyed through the digital product passport (DPP) while setting eco-design requirements) and ecolabeling (including digital labelling making use of technology, such as radio-frequency identification (RFID) tags, which are already being considered in the review of the Textile Labelling Regulation).

Identifying, separating and sorting PFAS after use or at end of life

When textiles reach the end-of-life stage, any available information on PFAS content has usually been lost. Performing chemical analyses to identify the textile waste containing PFAS is expensive and generally not feasible. Another option is to establish procedures for the visual identification and sorting of textiles that are likely to contain PFAS. Whilst this does not require significant investments in equipment, it does require resources for manual inspections. It is also highly uncertain if the results would be effective since it is very challenging to identify textiles containing PFAS by visual inspection.  

A more viable solution would be to develop procedures for semi-automatic or fully automated sorting based on digital information solutions on the presence of PFAS (such as the DPP and the digital label mentioned above) or based on X-ray fluorescence (XRF) machines. However, the implementation of such systems at large scale in waste handling facilities would come with a high cost.

When PFAS-containing textiles have been identified in textile waste, the two main options for removing the PFAS include: (1) destroying the entire product, or (2) sorting and removing PFAS components from the product for separate destruction. The latter, whilst technically and economically challenging, maximises textile recovery.

PFAS-containing textiles can in principle be identified and sorted after-use or at end of life, but this is rarely done in practice.

Better incineration techniques and avoiding landfill

When textiles reach the after-use phase, they are either resold, incinerated, landfilled, recycled or mostly exported to Asia or Africa after which they are either reused, recycled, dumped or burned in open landfills or elsewhere. Depending on which after-use route is taken, PFAS can be released to the environment via numerous mechanisms. Most textile waste in the EU is currently incinerated despite uncertainty as to whether this adequately eliminates PFAS, since the suitability of municipal incinerators for complete destruction is uncertain and high-temperature incineration has limited capacity. Further investigation of emerging techniques with lower environmental impacts is required to better understand these methods and develop the capacity to suitably destroy PFAS at scale in the EU.

Landfilling textiles with fluorinated polymers can result in the long-term degradation of polymeric PFAS compounds into smaller forms, with potential leachate release. In addition, non-polymeric PFAS used in textiles may also be released through leachate. This risk increases in regions with unregulated waste management systems, resulting in uncontrolled landfilling and open burning. This is common in countries receiving large quantities of used textile imports, such as many African and Asian countries.

Wastewater treatment plants in the EU receiving PFAS-contaminated wastewater from washing processes and landfill leachate cannot effectively remove PFAS. Instead, it is partitioned and either emitted to the environment via treated wastewater or accumulates in sludge, which is sometimes spread on land from where PFAS can contaminate food sources or leak into drinking water sources. Thus, innovation and investment in better technologies that enable the removal of PFAS is needed.

Minimising impacts beyond the EU

PFAS contamination is a global issue. Beyond the EU, transparency diminishes regarding the production of new textiles and the fate of used textiles. The export of used textiles from Europe, while contributing to jobs and economic added value in other regions of the world, negatively impact local environments, leading to the disposal of large quantities of poor-quality textiles in open dumps or through open burning. Less stringent safety and waste management regulations outside Europe exacerbate challenges in the longer use, reuse and recycling process seen within the EU.

While the EU has strict rules for its own internal market, influencing production and handling of used textiles practices and addressing environmental and social impacts beyond its borders is difficult despite relying heavily on imported textiles and exports of used textiles. Better transparency is needed to ensure that supply chains and after-use handling comply with EU regulations, especially if PFAS were to be restricted in the EU for textile products placed on the internal market, rendering the restriction enforceable for all such products irrespective of country of origin.

Conclusions

The use of PFAS in most types of textiles is not a technical necessity. Technological innovation has led to a good range of suitable alternatives for the textile sector. This allows for PFAS to be generally phased out, from a technical point of view, for most textiles. The exceptions would be for some speciality textile products, such as certain types of personal protective equipment (for example, for firefighters) and technical textiles, without major consequences for the functionalities of these products. This points towards concentrating preventive efforts upstream in the textiles supply chain rather than at the after-use stage, where it would be rather costly or not feasible.

On the after-use side, the EU obligation to collect textile waste separately from 1 January 2025 is key. Equally important is the investment in more and better sorting mechanisms, including automatic sorting that can detect and separate textiles with different recyclability potentials or challenges, and in improving and scaling recycling technology, ensuring that the PFAS containing textiles are not recycled.

Better tracing systems and implementation of regulation and sorting technology can help identify PFAS-contaminated products at end of life. This can also direct them to suitable treatment to prevent them from entering recycling streams while maximising safe textiles for recycling.

The presence of PFAS in some textiles is likely to impact the possibility to use, reuse and recycle some textiles for years to come, acting as a barrier to the EU’s objective to achieve a greater circular economy for textiles. Current practices are not sufficient to trace PFAS content in the after-use and waste stages. Moreover, the EU currently does not have technologies in place for general large-scale, efficient and cost-effective identification and sorting of textile waste containing PFAS.

At the same time, however, the textile categories for which suitable non-PFAS alternatives are not yet available are often used in specific occupational settings. For such uses, separate collection and destruction procedures could be put in place (if not already implemented) to ensure that these textiles are not mixed with the separately-collected textile waste for recycling, incineration or export.