The American Apparel & Footwear Association (AAFA) has recently urged Canadian Minister of Environment and Climate Change, Terry Duguid, to incorporate PFAS exemptions in textiles for products that test below the 100 ppm total organic fluorine (TOF) threshold. These exemptions are aimed at addressing regulations on intentionally-added per- and polyfluoroalkyl substances (PFAS) in the textile industry.
In the United States, states like California and Vermont have implemented TOF limits to regulate PFAS in textile products, creating a clear and standardized framework across the sector. Over the years, AAFA members have diligently worked to comply with California’s 100 ppm TOF limit to ensure consistent adherence to these regulations.
While it is feasible to manufacture general consumer goods without intentionally adding PFAS, AAFA highlighted the difficulty of completely eliminating trace contamination in textiles, apparel, and footwear due to the complexity of production processes. To further support the industry’s transition to sustainable practices, AAFA also called on Canada to exempt products containing at least 50% recycled content from PFAS regulations. Such PFAS exemptions in textiles would play a crucial role in encouraging circular sourcing and production models.
In its letter to Minister Duguid, AAFA emphasized the importance of worker safety and recommended the exclusion of personal protective equipment (PPE) from the proposed Phase 2 prohibition of PFAS in textiles. The comments were part of AAFA’s feedback on Canada’s “risk management approach” for PFAS, excluding fluoropolymers.
Although the Canadian framework suggests that alternatives to PFAS for waterproofing textiles, including PPE, are widely available, AAFA pointed to a decision made by the Washington State Department of Ecology. The department declined to restrict PFAS in PPE last year due to the lack of safer alternatives. Similarly, states like California have implemented blanket exemptions for PPE in their PFAS regulations.
AAFA noted that maintaining exemptions for PPE fosters regulatory consistency and harmonization, simplifying compliance for both manufacturers and buyers.
