Building the business case for reusable period underwear
Outline
- New EU green claims rules now apply to period products
- Unverified claims can trigger turnover-based fines
- Absorbency figures mean little without a defined method
- PFAS test reports must be able to measure the REACH limits
- Biocide treatments add labelling duties and health questions
- Sourcing regions differ on visibility, lead time and risk
- A practical checklist for your next RFP
Key takeaways
- Supplier self-declarations are no longer enough
- Every on-pack environmental claim needs evidence you hold
- Specify the absorbency test method, not just the number
- Check that PFAS test limits match the REACH limits
- Treat biocide-free as a specification, not a slogan
- Judge sourcing regions on total risk, not unit price
- Write compliance evidence into the RFP before contracting
Introduction
For most buying teams, a supplier's test report has long been the end of the compliance conversation. Send the specification, receive the certificate, file it and move on. For reusable period underwear, that habit now carries real risk.
Three things have changed in quick succession. Since 27 September 2026, the EU's new green claims rules have applied across member states, putting generic environmental claims on pack under much tighter scrutiny. From 10 October 2026, a REACH restriction on PFHxA, one of the PFAS "forever chemicals", applies to clothing sold to the public, at limits so low that the test method matters. And as the category grows, so does scrutiny of the performance and hygiene claims printed on the box. Other markets, including the UK and several US states, are also tightening the rules on green claims and on PFAS in clothing.
In each case, much of the exposure sits with the brand or retailer whose name is on the pack, not with the factory that issued the paperwork. This article sets out where self-declarations fall short, what independent evidence to ask for and how to build those requirements into your next request for proposal (RFP).
The EU's new green claims rules now apply to period products
Directive (EU) 2024/825, known as EmpCo, amends the EU's Unfair Commercial Practices Directive and member states must apply it from 27 September 2026 (Bird & Bird). It bans generic environmental claims such as "eco-friendly", "green" or "sustainable" unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. It also tightens the rules on durability claims and sustainability labels.
That matters for reusables because the environmental story is often the headline: less waste, fewer disposables, a greener choice. A pack that says "sustainable period underwear" with no recognised certification behind it is now a compliance question, not just a copywriting one. The same applies to durability claims, such as a stated number of washes.
The penalties are significant. Under the EU's Omnibus Directive, member states must allow fines for widespread cross-border consumer law infringements of at least 4% of the trader's annual turnover in the member states concerned (EUR-Lex). The practical step is simple: ask every supplier for the evidence behind each claim you plan to print, before artwork is signed off.
Why your absorbency figures may not be comparable
Ask three suppliers how much their gusset absorbs and you may get three numbers that cannot be compared. Test methods vary between laboratories and suppliers, so a number tells you little until you know how it was measured.
Many reported figures come from static tests, where a sample is laid flat and saturated. That measures total capacity. It does not show how the garment performs on a body that sits, stands, walks and lies down, or whether fluid stays locked in under pressure. A product can post an impressive capacity figure and still leak in use, and leaks drive the complaints and write-offs covered in the previous article in this series.
In your RFP, specify the claim and the method together:
- Liquid retention under bodyweight pressure, not only total capacity
- Leakage resistance in realistic positions, ideally on a mannequin or body-form rig
- Performance after a defined number of washes and tumble dries at the care-label temperature
- Results from an independent laboratory, with full test conditions, so you can compare suppliers like for like
Check how PFAS was tested
PFAS have historically been used to make fabrics water-repellent, which makes the leakproof layer of period underwear an obvious place to check. From 10 October 2026, REACH Annex XVII Entry 79, introduced by Regulation (EU) 2024/2462, prohibits placing clothing on the EU market that contains 25 ppb or more of PFHxA and its salts, or 1,000 ppb or more of PFHxA-related substances. The limits are measured in each homogeneous material, so a barrier membrane is assessed on its own rather than averaged across the whole garment (Beveridge & Diamond).
Before you rely on a "PFAS-free" result, check two things on the test report: the method and the reporting limit. A test with a reporting limit above 25 ppb cannot show that a material is below 25 ppb.
If the report does not make this clear, ask the laboratory whether its method can measure PFHxA at or below 25 ppb in each material, including the leakproof layer. Make this a condition in your RFP.
Why biocide-free should be a specification, not a slogan
To manage odour and bacteria, some manufacturers treat period underwear with biocides such as silver chloride. Germany's Federal Institute for Risk Assessment (BfR) notes that these substances fall under the EU Biocidal Products Regulation, and that claims such as "antimicrobial" or "odour-reducing" trigger labelling and information requirements. It also cautions that, depending on use and concentration, biocides can cause allergic reactions or disturb the skin flora, while data remains limited (BfR).
For a buying team, that means extra labelling work, a harder product story to tell and exposure if health concerns gain traction with shoppers. Write biocide-free into the material specification: no silver, nanosilver, silver chloride or other antimicrobial finishes, confirmed by chemical declarations and spot-checked by independent testing. Odour control should come from construction and fibre choice, not added chemistry.
Weighing sourcing regions on risk, not just price
Where a product is made shapes how easily you can verify it, but no region is automatically compliant or non-compliant. The real questions are how much effort it takes to see inside the supply chain, how quickly you can react when a test fails and how long stock sits in transit before you find out. Production close to your market shortens all three. A manufacturer that owns factories in more than one region can match production to each market and specification, while keeping one quality system and one set of test evidence.
A checklist for your next period underwear RFP
- Evidence for every environmental, durability and performance claim on pack
- Absorbency and leakage results with the full test method and conditions
- Construction details, including how the leakproof layer is attached and whether any stitching passes through the absorbent zone
- PFAS test reports that state the method and reporting limit, ensuring that each material is tested separately, including the PU membrane
- A written biocide-free material specification, independently verified
- Wash and tumble-dry durability data at the temperature printed on the care label
- Reports from accredited independent laboratories, not supplier self-declarations
- Traceability to the factory making your SKU, including who owns it and which quality system covers it
- The number of manual cutting and sewing steps in each garment, as a guide to how consistent sizing and quality will be
Frequently asked questions
How can I ensure my PFAS testing complies with REACH?
Check the testing method and reporting limit on the report, and if you’re not sure, ask the laboratory.
Does EmpCo apply to period underwear?
Yes. It covers environmental claims made to consumers in the EU, including on absorbent hygiene products, from 27 September 2026.
How do I compare absorbency claims from different suppliers?
Ask each supplier for results from an independent laboratory. Test methods vary, so your RFP should define the method and test conditions alongside every performance claim.
Next steps
Before your next tender, audit the claims and certificates for any reusable line already on shelf or in development. For each claim, ask what evidence sits behind it, which method produced it, and whether it would stand up if a regulator asked. Then rewrite your RFP so those answers are required up front, not chased after launch.
The next blog in this series shows what a successful launch looks like once you have a supplier that can meet this standard. If you missed the start of the series, read Opportunities for growth in the feminine hygiene category and Building the business case for reusable period underwear.
How do I get started with reusable period underwear?
Confitex Technology manufactures reusable period underwear for retail and brand partners. Contact us to see the independent test evidence behind our products: https://confitex.com/contact/
About the author
Helga Bjork Jonsdottir, Global Key Account Director, Confitex Technology
Helga leads client onboarding and product development for Confitex Technology’s retail and brand partners, overseeing a team responsible for taking each product order from initial briefing to production-ready specification. Since joining Confitex in 2021, she has developed a deep expertise in regulatory compliance as it applies to reusable absorbent hygiene products, and the testing required to ensure that product performance and durability meets retailer claims and consumer expectations. An experienced project manager, Helga has worked across the public, private and humanitarian sectors. Before Confitex, she held corporate communications and project management roles in Hong Kong, China and Denmark and now she is based in Phuket, Thailand. Connect with Helga on LinkedIn.
