EU Comprehensive Ban: A Belated "Chemical Warfare" and the Restructuring of Global Industrial Chains
20/01/2026
In January 2025, the Carrefour Group quietly launched an experiment in France: for the first time, it labeled nearly 70 products under its own clothing brand Tex with an ecological score. Similar to a food nutrition score, this label quantifies the environmental impact of an organic cotton T-shirt at 510 points, while a similarly priced non-organic fast-fashion T-shirt scores over 1000 points. By scanning a QR code, consumers can see the score calculated based on parameters such as water consumption, greenhouse gas emissions, toxicity, and microplastic release. Carrefour claims to be the first in the industry to test this approach, but its statement contains a crucial caveat—the measure remains voluntary for now, aiming to await the finalization of mandatory environmental information disclosure rules at the EU level.
Almost simultaneously, another piece of news emerged from the EU headquarters in Brussels, seemingly unrelated yet closely connected. EU Environment Commissioner Jessica Rosenworcel admitted at a press conference that the comprehensive ban proposal on per- and polyfluoroalkyl substances (PFAS), often referred to as "forever chemicals," is likely not to be completed as originally planned by 2026. This extensive legislative project, prioritized by the EU, is now facing delays due to awaiting the complex socio-economic impact assessment from the European Chemicals Agency (ECHA). The final text may not be released until the end of 2026 or even later.
From an eco-label on a T-shirt to a century-spanning ban covering over ten thousand chemicals, two news threads converge to outline a radical and complex green regulatory landscape that the European Union is vigorously advancing. The PFAS ban is far from a simple product recall; it is a chemical warfare aimed at reshaping the foundational chemical architecture of modern industry. Its very delay exposes the immense difficulty and global impact of this battle.
From Invisible Threat to Political Priority: The Urgency and Complexity of the Ban
PFAS is not a single substance, but a vast family comprising over 10,000 types of synthetic chemicals. Their common characteristic is the exceptionally strong carbon-fluorine bond, which grants them outstanding water resistance, oil resistance, stain resistance, and high-temperature durability. However, this also makes them extremely difficult to degrade in the environment and the human body, allowing them to persist for hundreds of years, hence the name "forever chemicals." From outdoor jackets, non-stick pans, stain-resistant carpets, and food packaging to firefighting foam, semiconductors, and medical devices, PFAS have penetrated almost every corner of modern life.
The news that Commissioner Rosewall himself tested positive for PFAS symbolically reveals the pervasiveness of the issue. Chronic exposure to low doses of PFAS has been extensively linked by scientific research to liver damage, high cholesterol, reduced immune response, low birth weight in newborns, and various cancers such as kidney and testicular cancer. This ubiquitous invisible pollution has rapidly elevated regulatory action from a scientific issue to an urgent public health and political matter.
The EU's proposal is ambitious, aiming to restrict the use of the vast majority of PFAS in consumer products, with exceptions only for a few critical areas such as medical devices. This regulatory approach of "prohibition in principle, exceptions require justification" reflects the EU's strong stance on the precautionary principle. However, it is precisely this comprehensiveness that constitutes the biggest obstacle in the legislative process. Assessing the environmental and health risks of over 10,000 chemical substances is already challenging, and comprehensively evaluating their socioeconomic impact on the entire European and even global industrial chain is an unprecedented and enormous undertaking.
The risk assessment report by the European Chemicals Agency is expected to be completed in March 2025, while the socioeconomic assessment will not be available until the end of 2026. This means that the European Commission will struggle to present a mature legislative draft before obtaining the key decision-making basis. Rothwell acknowledges that drafting the legal text is complex but feasible, and points out that the industry is already preparing. This not only demonstrates external determination but also serves as an advance notice for the prolonged internal negotiations.
The Global Game Behind Delays: Industrial Shocks and Geopolitical Considerations
The delay of the ban is by no means due to inefficiency in the EU's administrative processes, but rather profoundly reflects the intense internal and global struggles and trade-offs of interests.
Firstly, the ban will directly impact the core industrial competitiveness of Europe. The chemical industry is one of the pillar industries in Europe, with many PFAS serving as key components in high-performance materials. For example, in green technologies such as wind turbine blade coatings, hydrogen energy electrolyzer sealing materials, and electric vehicle battery components, PFAS currently remain difficult to fully replace. A one-size-fits-all rapid ban could potentially weaken the traditional chemical sector while inadvertently hindering Europe's strategic industries in green transformation. Lobbying from the industry and repeated evaluations of technical feasibility are significant forces driving the postponement of the timeline.
Secondly, the global nature of supply chains means any regional ban has spillover effects. The EU is one of the world's largest single markets, and its standards often become de facto global standards. Once the PFAS ban takes effect, all goods exported to the EU globally must comply with the new regulations, which will force major manufacturing countries such as China, the United States, and India to adjust their production processes. This Brussels Effect represents the EU's regulatory influence but also raises concerns about trade friction. The EU needs to find a balance between advancing its environmental agenda and maintaining an open trade environment.
From a deeper perspective, the PFAS ban is a crucial battle for the EU in competing for global green rule-making power. From the Carbon Border Adjustment Mechanism (CBAM) to the new battery regulations, and now the PFAS ban, the EU is attempting to define the rules of the game for future global trade by setting the highest environmental and health standards. The delay, to some extent, is to make these rules more rigorous and flawless, thereby enhancing their global legitimacy and potential for widespread adoption. The eco-score pilot at Carrefour can be seen as a preparatory exercise at the corporate level to adapt to this future mandatory, full product life-cycle regulation.
From Voluntary to Mandatory: Reshaping Corporate Strategies and Consumer Behavior
The Carrefour case provides a window for observing the micro-level impact of the PFAS ban. Although mandatory eco-labeling regulations at the EU level have not yet been introduced, leading companies have already begun to take proactive action. Behind this lies a shrewd business logic: shaping a green brand image in advance, accumulating data and experience, and influencing standard-setting to gain a head start in future mandatory regulations.
The emergence of third-party evaluation applications like Clear Fashion reflects the market's spontaneous demand for transparency. The model where consumers scan QR codes to obtain product environmental and social impact scores is transforming previously hidden chemical substance issues in the supply chain backend into intuitive market signals that influence purchasing decisions. When low PFAS or zero PFAS may become a key bonus point in future ecological ratings, the direction of corporate R&D and procurement will inevitably undergo a fundamental shift.
This bottom-up market pressure is converging with top-down regulatory pressure. Even if the legislative process for PFAS bans faces delays, the pressure from investors, consumers, and business partners will not disappear. An increasing number of brands, especially those targeting high-end and environmentally conscious customer groups, have begun committing to phasing out PFAS. This creates a forcing mechanism where market action precedes formal regulation.
However, the challenges remain immense. As fair trade advocate Valeria Rodriguez pointed out, the current voluntary eco-labels lack unified standards and mandatory requirements, particularly in considering social dimensions such as labor rights. Establishing a scientific, comprehensive, greenwash-proof assessment system that includes social responsibility is a critical issue the EU must resolve before introducing mandatory labeling. The complexity of the PFAS ban is a microcosm of this broader challenge.
Forward Look: A Protracted Battle Reshaping the Chemical Era
Overall, the delay in the EU's PFAS ban should not be interpreted as a weakening of action, but rather signals that a deeper and more enduring transformation is brewing.
First, the race for alternative technologies has already begun. The ban has created a massive market gap, stimulating global R&D investment in PFAS alternatives worldwide. From fluorinated polymers to new materials based on silicon and hydrocarbons, the outcome of this innovation race will determine which industries and regions can seize the high ground in green chemistry in the future. The EU's delay, objectively speaking, has bought valuable time for local companies to develop substitutes.
Secondly, global regulatory coordination and divergence will simultaneously deepen. The U.S. Environmental Protection Agency (EPA) has also strengthened its regulation of several PFAS, but its piecemeal approach differs significantly from the EU's comprehensive ban strategy. As a major chemical producer, China is also closely monitoring and intensifying related research. In the future, different PFAS regulatory paradigms may emerge globally, and companies will face a more complex compliance environment. The competition for standards on platforms such as the International Organization for Standardization (ISO) will become increasingly intense.
Ultimately, the PFAS issue compels us to re-examine the relationship between modern industrial civilization and chemical safety. This represents a systematic correction to the traditional development model of "produce first, assess later." Future regulatory trends will increasingly emphasize preventive and full lifecycle management, meaning thoroughly assessing the long-term environmental and health risks of new chemicals before they enter the market. The ultimate goal of this chemical warfare in the European Union may be to establish a completely new chemical substance management system, one built upon the foundation of safety and sustainability.
Returning to the initial T-shirt with the eco-score label. Behind its score, there may be an assessment of whether PFAS-type waterproofing agents were used in the production process. When the EU's PFAS ban is ultimately implemented, this score might become legally mandated information for disclosure, and a failing score could mean the product cannot enter the EU market.
Therefore, the new timeline for 2026 is not an endpoint, but the beginning of a more decisive phase. The twists and turns in the legislative process precisely demonstrate the breadth of interests involved and the depth of the transformation. Regardless of when the final bill is passed, a global reflection initiated by the European Union on how to coexist with chemical substances, along with the restructuring of industrial chains, has already accelerated irreversibly. This long-awaited ban will ultimately define the industrial rules and the boundaries of life safety for the next era.
Reference materials
https://www.lalsace.fr/economie/2026/01/19/carrefour-premier-a-tester-l-eco-score-pour-ses-vetements