Policy Alert | PFHxA Restriction Now in Force + TSCA PFAS Reporting Window Shifted: Dual Compliance Pressure for Exporters (Oct 11, 2026)

Policy Monitoring Daily Report — October 11, 2026 (Policy Alert)

Overall Risk Level: HIGH — The EU PFHxA restriction entered into force on October 10, and the US PIP (3:1) article distribution ban is due October 31. Advanced-materials exporters face simultaneous EU and US compliance deadlines.

1. EU REACH: PFHxA Restriction Now in Force (Risk: HIGH)

REACH Annex XVII Entry 79 restricting PFHxA (perfluorohexanoic acid), its salts and related substances took effect on October 10, 2026 for textiles, leather, hides, furs and footwear in apparel and related accessories available to the public: PFHxA and its salts must be below 0.025 mg/kg, and the sum of PFHxA-related substances below 1 mg/kg.

Enforcement is already ahead of the deadline: per EU Safety Gate (Aug 28, 2026), a waterproof mattress protector sold in Ireland was recalled for PFHxA-related substances above 100 mg/kg — at least 100 times the limit. DWR (durable water repellent), oil-repellent and stain-resistant finishes are the main sources of PFHxA; outdoor textiles and functional coatings are high-risk categories.

2. EU REACH: SVHC Candidate List Grows to 253 Substances (Risk: MEDIUM-HIGH)

ECHA added n-hexane and bisphenol AF (BPAF) and its salts in the 36th batch, bringing the candidate list to 253 substances; the BPF proposal was withdrawn, and resorcinol remains pending. Obligations already apply:

• SVHC >0.1% (w/w) in articles: duty to communicate safe-use information down the supply chain and to consumers (Article 33);
• SVHC >0.1%: SCIP database notification to ECHA (Waste Framework Directive);
• SVHC >0.1% and >1 tonne/year placed on the market: ECHA notification within 6 months of listing (the February 4, 2026 batch window is closing).

Dual control warning: BPAF is on both the SVHC list and Annex XVII (notification duty + ban). TBBPA has been banned at 0.1% as a Cat. 1B carcinogen since September 2025. Copper-clad laminates, epoxy resins, electronic encapsulants and fluoropolymers are directly affected.

3. US EPA TSCA: PFAS Reporting Window Shifted + PIP (3:1) Deadline (Risk: HIGH)

1. TSCA Section 8(a)(7) PFAS reporting: under the current 40 CFR 705.20, the reporting window opens no later than January 31, 2027 with a six-month submission period; small manufacturers importing PFAS only as part of articles have until April 13, 2027. EPA proposed de minimis exemptions (0.1%, PFAS in articles, byproducts, impurities) in November 2025, but as of October 7, 2026 no final rule has been published — article importers remain in scope until it is. The lookback covers all manufacture/import activity since January 1, 2011.

2. PIP (3:1) article distribution ban: October 31, 2026. Distribution of articles containing PIP (3:1) is prohibited after that date (circuit boards, wire harnesses and their sleeves, connectors and tapes are exempt until November 20, 2034). PIP (3:1) is widely used in wire and cable sheathing, adhesives, sealants and hydraulic fluids — only three weeks remain.

Also note: on October 3, EPA published NAM-based inhalation risk assessment guidance for surfactants (Triton X-100, oleoyl sarcosine reference values), which will shape TSCA Section 5 PMN assessments.

Impact Analysis

• Textile/leather/functional coating exporters: the PFHxA restriction is in force and EU market surveillance is active; water- and oil-repellent products risk delisting and recall without supplier compliance evidence.
• Electronic materials/CCL/epoxy producers: BPAF and TBBPA dual control plus the PIP (3:1) ban require inventory and customer action before October 31.
• US-bound exporters: the PFAS reporting window opens by January 31, 2027 at the latest; chemical identity, use and volume data for all PFAS-related shipments since 2011 must be compiled now.

Action Recommendations

1. Immediately (this week): obtain PFHxA test reports from textile, leather and coating suppliers; hold EU shipments of any product without evidence of compliance with the 0.025/1 mg/kg limits.
2. Before October 31: screen wire/cable, adhesive and sealant products for PIP (3:1) (<0.1% unintentional is exempt); finalize inventory distribution plans and confirm in writing with US customers.
3. This month: screen the full product line against the 253-substance SVHC list, file SCIP notifications for articles above 0.1%, and verify ECHA notifications for the February 2026 batch.
4. Q4: build a PFAS data ledger covering US-bound products since 2011 to prepare for TSCA 8(a)(7) reporting before January 31, 2027; track EPA’s pending de minimis final rule.

Sources: ECHA, EU Safety Gate, EPA eCFR (40 CFR 705/751), Federal Register, and public compliance advisories.