On July 23, 2026, the Swedish Ministry of Climate and Enterprise launched a public consultation regarding a national ban on PFAS in certain consumer products. Stakeholders may submit comments until November 30, 2026. The ban is scheduled to enter into force on January 1, 2028. CIRS Group has collated and summarized the key contents as follows for your reference.
Background
PFAS (per- and polyfluoroalkyl substances) is a collective term covering more than 10,000 identified synthetic fluorinated compounds. All PFAS share the common trait of being extremely persistent in the environment. Studies have shown that PFAS exposure may be associated with certain types of cancer, thyroid disease, reduced immune function, liver disease, endocrine disruption, and osteoporosis, and that PFAS can be transferred from mother to fetus. Sweden faces severe PFAS contamination: as of January 2026, approximately 22,000 potential PFAS-contaminated sites have been identified.
Key Contents
1. Scope and Covered Products
The ban provides that the following products may not be made available to consumers on the Swedish market if they contain PFAS at or above the specified limit values:
- Clothing and footwear
- Waterproofing agents for clothing and footwear
- Cosmetic products (same definition as in the EU Cosmetics Regulation (EC) No 1223/2009)
- Kitchenware intended to come into contact with food
- Ski wax
The definition of PFAS is the same as in Article 5.5, second paragraph, of the EU Packaging Regulation (EU) 2025/40 (PPWR), covering fluoropolymers, perfluoropolyethers (PFPE), and polymers with fluorinated side chains.
2. Limit Values
The ban applies when the PFAS concentration (measured in homogeneous material) reaches any of the following limit values:
- Single non-polymer PFAS: ≥ 25 µg/kg (micrograms per kilogram)
- Sum of all non-polymer PFAS (including those formed from degradation of precursors): ≥ 250 µg/kg
- Sum of all PFAS: ≥ 50 mg/kg (milligrams per kilogram)
When the total fluorine content is ≥ 50 mg/kg, the fluorine content is presumed to originate from PFAS — unless the product provider can demonstrate that the fluorine comes from one or more non-PFAS substances. For kitchenware, the limit values apply only to the parts intended to come into contact with food.
3. Exemptions
The ban does not apply to the following:
- Clothing containing ≥ 20% recycled material from end-user waste
- Personal protective equipment (PPE) falling under Annex I to the EU PPE Regulation (EU) 2016/425
- Waterproofing agents for re-impregnation of the PPE referred to above
- Products that have been in use and are suitable for continued use (as-is or after repair)
4. Relationship with EU Legislation
The national ban ceases to apply once EU legislation takes effect: if a corresponding ban already follows from the REACH Regulation ((EC) No 1907/2006) or the POPs Regulation ((EU) 2019/1021), this national ban no longer applies. The limit values in the Swedish national ban are fully aligned with those proposed in the EU restriction proposal, to ensure future consistency.
CIRS Reminder
- Cosmetic companies should pay close attention: cosmetic products containing PFAS that exceed the limit values (25 µg/kg / 250 µg/kg / 50 mg/kg) may not be made available to consumers in Sweden from January 1, 2028.
- Screen formulas in advance: companies should screen their product formulas for PFAS-type ingredients and assess whether they meet the limit values; according to the promemoria, viable alternatives already exist for cosmetics and other covered categories.
- Distinguish “intentionally added” from concentration-based triggers: unlike some US state laws, the Swedish ban is not triggered by “intentional addition” but rather by whether the PFAS concentration in homogeneous material exceeds the limit values.
- Monitor the dual EU–Sweden timeline: the EU REACH PFAS restriction is not expected to apply until 2029 or later; Sweden's national ban is intended to take effect on January 1, 2028, and will automatically yield once EU rules apply — companies must track both tracks.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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