ROHS Compliance

On May 2, 2025, Denmark’s Ministry of Environment announced new regulations restricting the import and sale of consumer products containing PFAS (per- and polyfluoroalkyl substances) in clothing, footwear, and certain waterproofing agents.

The regulation took effect on July 1, 2025, with core restrictions applicable from July 1, 2026. Businesses may continue selling existing stock until January 1, 2027.

🔹 Key Provisions

1. Definition of PFAS PFAS are defined as substances containing at least one perfluoromethyl (–CF₃) or perfluoromethylene (–CFâ‚‚–) carbon atom, excluding those with hydrogen, chlorine, bromine, or iodine atoms.

2. Scope of Restrictions

· Apparel and Footwear: Applies to all consumer products where any component exceeds 50 mg/kg of fluorine (as F).

· Waterproofing Agents: Applies textile or footwear waterproofing products for private use with ≥50 mg/kg fluorine content.

3. Exemptions

· Secondhand or refurbished apparel/footwear (for reuse or repair)

· Personal Protective Equipment (PPE) under EU Regulation (EU) 2016/425:

o Category III(a): Protection against chemical/biological hazards

o Category III(c): High-temperature or flame protection

· PPE where PFAS is essential for safety performance

· Waterproofing agents for refurbishing Category 3–4 PPE

· Medical devices

· Goods in transit not intended for sale in Denmark

4. Enforcement and Penalties Non-compliance may result in fines, and intentional or grossly negligent violations causing health or environmental harm could lead to imprisonment up to two years.

Businesses may apply for case-specific exemptions for technical or safety reasons by March 31, 2026. Exemption decisions are final and publicly disclosed

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