The consultation, opened by the Swedish Ministry of Climate and Enterprise on 23 July 2026, will remain open until 30 November 2026. If adopted, the proposed measures would enter into force on 1 January 2028, ahead of the expected application of the broader PFAS restriction currently being developed at EU level under the REACH Regulation.
Why PFAS continue to attract regulatory attention
PFAS comprise a large family of more than 10,000 synthetic fluorinated substances valued for their resistance to water, grease and heat. However, these same properties also make them highly persistent in the environment, leading to their widespread description as “forever chemicals.”
Scientific studies have associated exposure to certain PFAS with a range of adverse health effects, including impacts on the immune and endocrine systems, thyroid disorders, liver disease, reduced bone density and an increased risk of some cancers. Some PFAS can also cross the placental barrier, raising concerns about prenatal exposure.
Sweden has been particularly active in addressing PFAS contamination. According to national authorities, more than 22,000 sites across the country had been identified as potentially contaminated by PFAS as of January 2026, reinforcing the government’s efforts to limit future emissions from consumer products.
Products covered by the proposal
The proposed legislation would prevent certain products from being made available to consumers on the Swedish market if they contain PFAS above the specified concentration limits. The scope includes clothing, footwear, waterproofing agents for textiles and shoes, cosmetics, kitchenware intended to come into contact with food, and ski waxes.
For cosmetics, the proposal applies the same definition established under the EU Cosmetics Regulation (EC) No 1223/2009.
The proposal also adopts the PFAS definition introduced in the EU Packaging and Packaging Waste Regulation (PPWR), covering fluoropolymers, perfluoropolyethers (PFPE) and polymers with fluorinated side chains.
Compliance based on concentration thresholds
Unlike some PFAS legislation adopted outside Europe, the Swedish proposal does not distinguish products based on whether PFAS have been intentionally added during manufacturing. Instead, compliance would be determined by the concentration of PFAS measured in homogeneous material.
The proposed restriction would apply when any of the following thresholds are reached:
- 25 µg/kg for a single non-polymeric PFAS.
- 250 µg/kg for the sum of all non-polymeric PFAS, including substances formed through the degradation of precursor compounds.
- 50 mg/kg for the sum of all PFAS.
The proposal also establishes a presumption based on fluorine content. Where total fluorine reaches 50 mg/kg or more, it is presumed to originate from PFAS unless the product provider can demonstrate that the fluorine comes exclusively from one or more non-PFAS substances.
For kitchenware, these concentration limits would apply only to the components intended to come into contact with food.
Relationship with future EU legislation
The Swedish proposal has been developed while the EU-wide PFAS restriction under REACH is still progressing through the legislative process. Although that restriction is currently expected to apply from 2029 or later, Sweden’s proposal would introduce national measures earlier.
The national restriction is intended to coexist with EU legislation only temporarily. Once equivalent requirements become applicable under either the REACH Regulation or the Persistent Organic Pollutants (POPs) Regulation, the Swedish national ban would cease to apply. To facilitate this transition, the proposed concentration limits have been aligned with those currently under discussion at EU level.
What this means for the cosmetics industry
Although the proposal is still under consultation, it gives cosmetic manufacturers an early indication of future regulatory expectations in Sweden. If the measures are adopted, cosmetic products exceeding the proposed PFAS concentration limits could no longer be made available to consumers on the Swedish market from 1 January 2028.
Manufacturers may therefore wish to begin reviewing formulations and raw materials to identify potential PFAS sources and assess compliance with the proposed thresholds. According to the explanatory memorandum accompanying the proposal, viable alternatives are already available for cosmetics and several other product categories covered by the restriction.
For companies operating across Europe, the proposal also highlights the importance of monitoring both national initiatives and the ongoing EU restriction process, as the regulatory framework for PFAS continues to evolve.
