The next compliance advantage will come from proving chemical control across formulations, production lines and wastewater—not merely declaring a product “PFAS-free”.
ZDHC has sharpened its position on per- and polyfluoroalkyl substances (PFAS), reiterating that they have no place in standard textile, apparel, footwear and leather manufacturing. Its latest statement is not a new stand-alone ban; rather, it moves the industry’s existing restrictions towards a more demanding implementation phase centred on definitions, detection and evidence.
The restriction begins with chemical inputs
The ZDHC Manufacturing Restricted Substances List (MRSL) already prohibits intentional use of restricted substances in commercial formulations used in wet processing—including dyes, auxiliaries, coatings, detergents, inks, adhesives and finishing agents. For fashion, sportswear, outdoor apparel, footwear and home textiles, formulations based on or containing PFAS are not permitted.
That puts the operational focus on the chemical recipe, not only the finished garment. Fluorinated durable-water-repellent, oil-repellent and stain-resistant finishes should be immediate priorities for review. Certain legally or contractually mandated technical end uses—including some medical, protective and transport applications—remain difficult cases, but ZDHC classifies PFAS-based formulations as MRSL-non-conformant.
Testing becomes more exacting
ZDHC recognises that improved testing methods and broader regulatory definitions are finding PFAS in articles made with formulations that had previously appeared compliant. This does not necessarily establish deliberate use; it can reflect analytical advances, trace contamination or a change in the applicable definition.
The organisation now intends to provide clearer definitions, greater alignment on testing and screening methods, and more explicit guidance on interpreting results. Under MRSL 3.1, certifiers may test recognised PFAS marker chemicals, screen for total fluorine and then use confirmatory testing where warranted.
The factory response
For dyehouses, laundries, printers and mills, the sensible response is a disciplined PFAS-control programme: map every formulation and substrate; verify supplier declarations and MRSL-conformance documentation; identify fluorinated finishes and legacy stocks; investigate any positive screen before assigning root cause; and retain auditable records of substitution decisions.
The wastewater dimension is also tightening. ZDHC’s current wastewater guidance signals that substances added in MRSL 3.1 will be included in Version 3.0 testing for wastewater and sludge.
The next challenge is not declaring a PFAS phase-out. It is building a traceable system that can demonstrate whether PFAS were intentionally used, unintentionally present, or introduced through an upstream input—and then act on that evidence.
