PFHxA Restrictions for Footwear: What to Check with Your Adhesive Supplier

A shoe factory may have an adhesive SDS, a supplier declaration and a laboratory report on file. The useful question is whether those documents cover the formula, batch and materials actually used in the shoe. Here is a practical starting point for EU-bound production.

Which footwear is covered from 10 October 2026?

Since 10 October 2026, REACH Annex XVII Entry 79, introduced by Commission Regulation (EU) 2024/2462, restricts PFHxA, its salts and related substances in footwear for the general public. This includes everyday, sports and children’s shoes, regardless of where they are manufactured.

Specific exemptions include PPE protecting against the Category III risks listed in Entry 79(3)(a); safety footwear is not automatically exempt. Articles placed on the EU market before the deadline benefit from a derogation. An earlier manufacturing date alone does not establish that status.[1]

Read the limits at material level

For covered footwear, placing on the market or use is prohibited at or above either concentration below, measured in homogeneous material. PFHxA-related substances include substances that can degrade or transform into PFHxA.[1]

In practical terms, a homogeneous material has a uniform composition. A whole shoe contains different materials, so its average concentration cannot establish compliance for each one. Entry 79 does not set out a detailed footwear separation procedure. Agree with the laboratory how cured adhesive, coatings and inseparable layers will be sampled, and have the tested portions identified in the report.[4]

Check the adhesive and the treated materials

Review the adhesive system, including primers and hardeners, alongside leather, fabric, coatings and water-repellent treatments. A declaration for the glue does not cover chemicals added by a tannery or fabric finisher.

Prioritize water-, oil- and stain-repellent finishes and ask what chemistry provides those properties. AFIRM identifies these as useful warning signs when reviewing PFAS use.[3] Likewise, “water-based” or “solvent-based” describes an adhesive technology; neither label establishes PFHxA compliance.

Understand what each document can establish

SDS disclosure rules do not require every constituent to be listed.[2] “Not intentionally added” also leaves the possibility of contamination. A PFHxA-only test or total-fluorine screening alone cannot establish compliance with both restricted groups.[3]

Identify the formula and batches when requesting evidence

Give the adhesive supplier:

• The product code, grade, formulation revision or agreed version identifier, and manufacturing site.
• The trial and production batch numbers, production dates and purchase-order references.
• The primer, hardener and other added products, with their batch numbers and mixing ratios.
• The shoe materials, intended EU market and the customer’s restricted-substance requirements.

Ask which batches the evidence covers and how formula or raw-material changes will be communicated. Confirm whether the tested sample was liquid adhesive, a dried or cured film, or a bonded assembly. AFIRM’s sampling guidance distinguishes liquid chemical samples from the solid material after drying; the results should not be treated as interchangeable.[4]

Keep the finished shoe in the assessment

Map the supplier evidence to the final bill of materials and resolve gaps with a qualified laboratory. Include treatments added after bonding, production substitutions and contamination risks. Agree representative sampling and suitable reporting limits with the laboratory and EU customer.

If you are evaluating Fokis 444 PU shoe adhesive, share the exact materials and compliance requirements when asking about samples and available documentation. For bonding trials, our guide to sending materials for adhesive testing explains how to prepare samples. Bonding performance trials and PFHxA chemical assessment answer different questions; both need to match the actual production materials.