[Regulatory Update] Denmark's Ban on Importing and Selling PFAS-Containing Clothing and Footwear to Consumers Takes Effect on 1 July 2026 — Sales from Stock Allowed Until 1 January 2027

Under Executive Order No. 464 of 2 May 2025, issued by Denmark's Ministry of the Environment and Gender Equality, the prohibition on importing and selling clothing, footwear and certain waterproofing (impregnation) agents containing PFAS to consumers took effect on 1 July 2026. The Order itself entered into force on 1 July 2025, and the prohibitions were set to take effect one year later. The ban covers clothing and footwear for private use in which at least one article forming part of the product has a total fluorine content of 50 mg F/kg or more, and impregnation agents for clothing or footwear with a total fluorine content of 50 mg F/kg or more. Traders may not import or sell them, and private persons may not import them. Sales from traders' existing stocks remain allowed until 1 January 2027. The Order does not apply to the reuse or recycling of clothing and footwear; personal protective equipment intended to protect the user against the risks in risk category III (a) or (c) of Annex I to Regulation (EU) 2016/425; personal protective equipment whose PFAS content serves a safety function; impregnation agents for re-impregnating such equipment; medical devices; transit goods; or cases where the fluorine comes from a substance that is not PFAS. PFAS regulated under the REACH Regulation or the POPs Regulation are also outside its scope. The Danish Environmental Protection Agency (Miljøstyrelsen) supervises compliance and may grant exemptions in special cases. Violations are punishable by fines, and by imprisonment of up to two years where the violation is intentional or grossly negligent and involves harm or danger to human life or health, harm or danger to the environment, or economic gain.