Targeting Outdoor Textile Products: New US PFAS Regulations Implemented, How Can Export Enterprises Avoid Pitfalls?

Recently, the U.S. Environmental Protection Agency (EPA) announced that perfluorohexane sulfonate sodium (PFHxS-Na) will be automatically added to the Toxic Release Inventory (TRI) in October 2025, drawing widespread attention from the domestic outdoor textile product export industry.

According to a relevant analysis report from the China Technical Barriers to Trade Website, after the upgrade of control measures, the number of per- and polyfluoroalkyl substances (PFAS) regulated on the TRI list has reached 206. Coupled with local PFAS regulations enacted by over 30 states in the United States, domestic outdoor textile product export enterprises are facing unprecedented compliance pressure. How to accurately respond to regulatory changes and avoid export risks has become a core issue that the industry urgently needs to address.

The regulation of PFAS in the United States is tightening, with outdoor textile products becoming a key target area.

PFAS, known as "forever chemicals," have been widely used in the production and processing of outdoor textile products such as outdoor jackets, hiking pants, tent fabrics, and outdoor shoe materials due to their excellent water-resistant, oil-resistant, and heat-resistant properties. The recent inclusion of PFHxS-Na in the TRI list by the EPA under the National Defense Authorization Act of 2020 is not an isolated move but rather an important signal of the comprehensive upgrade of PFAS regulation in the United States.

From a regulatory perspective, the control of PFAS in the United States has gradually expanded from initial applications like firefighting foam and children's products to multiple areas including food packaging, textiles, household goods, and cosmetics. The textile sector, particularly outdoor textile products, has become a focal point for regulation. Notably, up to now, various states in the U.S. have collectively introduced multiple PFAS regulatory laws, with over 30 states imposing explicit restrictions on products containing PFAS. Some states are even advancing towards comprehensive bans on outdoor textile apparel containing PFAS, forming a dual regulatory network of "federal + state" controls. This comprehensive and stringent regulatory trend undoubtedly serves as a wake-up call for companies exporting outdoor textile products that rely on the U.S. market.

Export enterprises face multiple compliance challenges.

The update of the TRI list first imposes more stringent requirements on the compliant operation of enterprises. According to U.S. regulations, facilities in certain industries must annually report their release and waste management conditions to the EPA if they manufacture, process, or use TRI-listed chemicals exceeding set thresholds. These report data will be made public, subject to comprehensive supervision by the government, industry, and the public, directly affecting the enterprise's brand image and market position.

For domestic sports goods export enterprises, the potential risks are more specific. On one hand, if products are found to contain restricted PFAS substances such as PFHxS-Na, they may face consequences such as product withdrawal or recalls, and even face legal lawsuits and economic compensation for violating local regulatory laws. On the other hand, with the increasing environmental awareness among consumers, the dangers of PFAS as "forever chemicals" have garnered widespread attention. Continuing to use related materials will directly harm the company's green image and weaken the competitiveness of its products in the international market. According to research data from Quanzhou Customs, Jinjiang City, as an export base for China's sports industry, has an annual sports industry export value of about 40 billion yuan, and local enterprises have generally felt the export pressure brought about by the upgrading of PFAS controls.

Upstream enterprises need to solve the problem of obtaining "no PFAS" certification.

The compliance pressure in the textile supply chain has become one of the main challenges faced by sports goods export enterprises. The use of PFAS in sports goods is primarily concentrated in functional textile materials for waterproofing and oil resistance. To fulfill TRI reporting obligations, U.S. customers trace the PFAS content of raw materials back to upstream textile enterprises, requiring them to provide proof of "PFAS-free" materials.

The traceability mechanism significantly increases the management complexity of the entire textile supply chain. On one hand, upstream companies need to conduct a comprehensive investigation of raw materials and production processes, establish detailed records of raw material components, and closely monitor the use of PFHxS and its salts and derivatives. On the other hand, there are differences in PFAS regulations across various states in the U.S., requiring companies to accurately adapt to the regulatory requirements of different regions, further complicating compliance efforts. Previously, products such as jackets from international brands like Arc'teryx faced market controversies for being exposed to contain PFAS, which has led downstream brands to impose higher demands on upstream supply chain management of PFAS.

Enterprises need to strengthen compliance defenses and promote green transformation.

Faced with increasingly stringent PFAS regulatory barriers, domestic sports goods export companies need to formulate response strategies from both short-term compliance measures and long-term strategic planning to strengthen their export defenses.

In the short-term compliance context, enterprises should prioritize a comprehensive investigation of raw materials and textile processes, conduct PFAS component screening for functional materials such as waterproof, oil-proof, and coatings, and establish a raw material component archive. Meanwhile, they should strengthen research on TRI reporting requirements and PFAS regulations across various U.S. states. It is recommended to collaborate with professional organizations to conduct product compliance assessments and certifications, and to prepare in advance the various materials needed for audits to avoid export obstructions due to compliance issues. The sports product technical trade measures research and evaluation base established by Quanzhou Customs in conjunction with relevant organizations has effectively assisted local enterprises in tackling some compliance challenges by providing services such as information collection, standards and regulations research, consultancy, and training.

In terms of material substitution and technological upgrading, promoting the research and application of non-PFAS alternative materials has become crucial. Currently, there are various fluorine-free waterproof and breathable materials on the market. For example, the Chinese outdoor sports brand Camel has launched an ePE membrane fluorine-free jacket, which uses expanded polyethylene material to achieve waterproof and breathable functions. It is lighter and more environmentally friendly compared to traditional fluorinated materials. The international fabric giant Gore has also announced that by the end of 2025, most of its consumer fabric products will use PFAS-free ePE film technology. Domestic companies can actively collaborate with suppliers to accelerate the application of alternative materials such as fluorine-free water repellents, including acrylic, polyurethane, and silicone-based products, gradually phasing out the use of PFAS substances. Leading domestic brands like Anta and Li Ning have already outlined plans to respond to environmental policies by increasing the proportion of sustainable products and eliminating long-chain fluorochemicals, setting a benchmark for transformation in the industry.

Establish a regulatory monitoring and rapid response mechanism.

From a long-term development perspective, companies need to establish a comprehensive regulatory monitoring mechanism to closely follow the PFAS regulatory trends in major export markets such as the EPA and the EU, and to promptly obtain policy alerts and professional interpretations. On this basis, they should build a rapid response mechanism to ensure timely adjustments in production strategies and supply chain management when regulations change, thereby seizing market initiative.

It is worth noting that the tightening of PFAS regulations has become a global consensus. China has also included PFOS, PFOA, and PFHxS compounds in the "List of Key Controlled New Pollutants (2023 Edition)." Export enterprises in the sports goods sector should actively grasp the trend of green transformation, integrating compliance management into every stage from raw material procurement to product export. By systematically enhancing product compliance, they can build core competitiveness and achieve high-quality development in the face of technical trade barriers.