This chapter will teach you about typical “red flags” indicating that PFAS could be in a product. You will also find suggestions on how to communicate about PFAS in the supply chain and what to do if you do not get the answers you need from your suppliers, or want to verify them.

A basic understanding of the properties of PFAS and the functions they can provide helps you understand if your product is likely to contain PFAS chemicals. The unique properties of PFAS chemicals provide several useful functions in many products. For example, they can be added as a surface treatment or as an ingredient in paint, mascara or ski wax.

PFAS are also often used in the form of polymers, which is the basic building blocks of plastics. Therefore, an entire material, like a waterproof textile, an electric cable, or a non-stick coating, can be made out of a PFAS polymer.

Typical PFAS uses

One of the most common uses of PFAS chemicals is to make materials and surfaces water, dirt and grease repellent.Examples include outdoor clothing and equipment such as rain jackets, tents and awnings. Food packaging such as pizza boxes or hamburger wrappings may be treated with PFAS to keep grease from soaking into the paper. Textiles in furniture or flooring can be treated with PFAS for stain protection.The possibility to make a surface both repellent to water and fatty substances, including dirt, is unique for PFAS chemicals.

Waterproof, stain or grease repellent?

The non-stick properties of PFAS make them ideal for coatings of kitchen utensils. One of the most well-known uses of PFAS is Teflon frying pans. But many additional products have been made non-stick with the help of PFAS. For example, baking paper, cupcake forms or any other kitchen item with a non-stick claim is likely to contain PFAS.PFAS are also used to reduce friction or as lubrication. Ski waxes and bicycle oils are typical uses. But this property is also used in cosmetics, for example, in foundation or nail polish to achieve smooth coverage.

Non-stick and lubrication

Large amounts of PFAS are used in paints and coatings. In paints, PFAS are added to lower the surface tension, allowing for an even flow and a glossy finish. PFAS can also achieve additional properties such as dirt and waterproofing and decrease paint bubbles. PFAS are commonly used in powder coatings, where in addition to the properties above, they can achieve fire, UV-light and corrosion protection. Also, metal coatings typically include PFAS chemicals. In wood lacquers, PFAS increase water and stain repellency and act as a matting agent. In addition, PFAS are used in inks for printing and photographic films.

Paints, prints and coatings

A “quick and dirty” test for PFAS is the <a target="_blank" href="https://www.ecocenter.org/test-your-products-pfas-water-droplet">so called droplet test.</a> A droplet placed on a surface treated with PFAS will bead, and will not be absorbed into the material.

PFAS are used in surface sealers for porous materials such as stone, tiles, concrete and ceramics. The sealing property can also be used to protect outdoor surfaces, including windows, from e.g. dirt, graffiti or ice. PFAS are also used in seals to stop leaks and in gaskets and O-rings.PFAS are also added to adhesives to increase the wettability and penetration of the substrate, resulting in a stronger bond. This property is utilized, for example, in adhesives to glue floor tiles and in different tapes for electrical, plumbing and construction work.

Sealers and adhesives

Large amounts of PFAS are used in the electronics industry, and both polymeric and non-polymeric compounds are used throughout the electronic industry supply chain. Key properties making PFAS useful in electronics are flame retardancy, chemical inertness, water and dirt repellence and tolerance for high temperatures and high voltages.These properties are helpful in different electronic components, including cables, displays, capacitors, printed circuit boards, batteries, solar panels, speakers and microphones. PFAS are also commonly used for cleaning and packaging of electronics.

Electronics

PFAS are used in personal protective clothing and equipment, including workwear. PFAS protect from fires and spills of oils or other chemicals.In the healthcare sector, PFAS can be used in clothes for laboratory or surgical work to protect from viruses and bacteria. Often, protective clothing needs to be re-impregnated with PFAS regularly, e.g., after washing, which increases the amount and exposure of PFAS from such surface treatment.PFAS are also used in firefighting foams because they can form a foam that can suffocate the flames.

Protection from fire, chemicals or pathogens

The obvious way to investigate if your products contain PFAS is to ask your suppliers. While this may seem straightforward, there are a few different things you need to consider. For example, how do you currently communicate with suppliers? Do you have a complex supply chain? It could be a good idea to coordinate requirements and questions with other companies within your industry, since you most likely have many similar suppliers. Working together is an excellent way to leverage your impact among suppliers.

Supply chain communication

Since using most PFAS is not against any law (yet), it can be challenging for you to demand that your suppliers remove it from production. Speaking with suppliers, you will most likely hear variations of the answer &quot;the chemicals in use are following legal requirements&quot;. But you, of course, know that simply following the law, in this case, is not good enough.You need to prepare for argumentation, mention the ongoing regulatory initiatives, and in the worst case, flex your financial muscles to obtain the information you need. Discarding a supplier due to it not helping you map your chemicals is sometimes necessary. Hopefully, the pure threat of losing a customer will make your supplier more collaborative.

You may need to be a bit tough

Many companies use a Restricted Substances List (RSL) that explains their specific chemical requirements in the supply chain. If you have one, you should put PFAS on that list.From a supplier perspective, it can be challenging if many customers have very different requirements in their specific RSLs. Therefore, it is a good idea to work with other companies and use a joint RSL. Is there already such a collaboration in your industry that you can join?Lastly, many large companies with advanced chemicals management have public RSLs on their website. A simple way is to identify such a company within your industry and copy the RSL.

Restricted Substances List (RSL) 

<ol start="1"><li>Why you want to address PFAS. Be clear that you want to address these problematic substances ahead of regulation</li><li>How you define PFAS. Refer to the <a target="_blank" href="https://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=ENV/CBC/MONO(2021)25&docLanguage=En">OECD definition (p.18)</a> and/or use the <a target="_blank" href="https://sinsearch.chemsec.org/">SIN List</a> to provide a list of relevant CAS numbers.</li><li>Ask for information about the presence and the levels of PFAS that are:</li></ol><ul><li>Intentionally added to products supplied to you</li><li>Used in the production process of your products</li><li>Used in the production facilities and therefore may contaminate your products.<h3>You are welcome to use the <a target="_blank" href="https://cms.pfas.chemsec.org/storage/spreadsheets/supply-chain-questionnaire-230228.xlsx">template questionnaire</a>.</h3></li></ul>

Checklist for supply chain communication

ChemSec&#039;s PFAS Movement gathers over 100 companies. By joining the group, you acknowledge that PFAS are a main problem, you support a group ban of PFAS and you have an ambition to phase out PFAS in your own business. By becoming a member, your company also helps create a demand for alternatives to PFAS. The more companies that require PFAS-free products and better information on PFAS content, the easier it will be.As a member of the PFAS Movement, you also get access to resources supporting your PFAS phase-out, e.g. webinars and meetings with experts.

Join the PFAS Movement!

If you do not get the answers you need from your supplier or want to verify them, you can perform a chemical analysis of your product to find out if it contains PFAS. For this, you need to contact a laboratory to discuss possible options for the specific type of product/material you want to investigate. There are several different methods available for measuring PFAS. They differ in cost, specificity and detection limits.

Chemical analysis

Targeted methods mean that you look for a specific chemical in your sample. For example, liquid chromatography (LC-MS/MS) can measure a particular PFAS chemical in very low concentrations. Unfortunately, the method is not available for all PFAS chemicals but only for the most common ones. The advantage of a targeted method is that you get an excellent and accurate measure of the specific PFAS that you are looking for. The disadvantage is that you search for only one of the thousands of PFAS chemicals on the market.

Targeted methods

Non-targeted methods aim to give a picture of the PFAS content in general. No method measures &quot;PFAS&quot;, but analysing the content of organic fluor makes a good proxy for the PFAS content. AOF and EOF (absorbed or extracted organic fluorine) are methods to measure the total fluorine content in a sample. These tests tell you how much organic fluorine is in there — most likely from PFAS — but not which specific PFAS chemicals.If you want to check a product for PFAS, it is a good idea to use a non-targeted method first. Then later, when you want to verify which exact PFAS chemical you have (you may, for example, want to check for the ones that are regulated), you need to use a targeted method.

Non-targeted methods

If you find PFAS in your product, you need to consider if this was intentionally or unintentionally added, for example, via cross-contamination in the production process. Unintentionally added PFAS are also a reason for why you may want to test a product even if your supplier says it is free from PFAS.The problem with PFAS is that they are found everywhere. There is a background level of PFAS chemicals in the environment and humans. In some areas, it may be quite high. If your product is produced in an area with high contamination of PFAS, e.g. in the water, PFAS may end up in your product.

Impurities and contamination

There is no general approach to investigate PFAS content that works for all different types of products. For some product categories, including textiles and food packaging, there are standards available mentioning specified test methods. For most product categories however, one will need to explore which of the possible methods would be the most appropriate. A good overview and advice are found in the report “<a target="_blank" href="https://pub.norden.org/temanord2022-510/">Analytical Methods for PFAS in Products and the Environment”</a> from The Nordic Council (2022).In addition, the EU PFAS restriction proposal includes an <a target="_blank" href="https://echa.europa.eu/documents/10162/f6ca8c47-eb72-28b5-4819-2d555086deee">attachment</a> on which specified test methods that can be used for different product categories.

Testing of different product categories

Investigate

PFAS continue to be used on a broad scale despite their adverse health effects, linking them to issues such as cancers and infertility. Since theses “forever chemicals” do not degrade, they are now found all over the planet in our environment and in the blood of every single human being.

The common problematic property of all PFAS substances is persistence. The strong molecular fluor-carbon bonds make them nearly resistant to degradation, thus the nickname “forever chemicals”. The molecular stability led to the spread of PFAS chemicals all over the globe. Every area of the world and every person or animal now has measurable levels of PFAS, and scientists have concluded that we have exceeded the planetary boundary. Even rainwater in the most remote areas contains PFAS above the proposed safe levels for drinking water. Once these chemicals are in the environment, there is no way to take them back, and as long as they are still used and produced, the levels will increase.

What are the problems with PFAS?

The PFAS group is diverse in terms of structure, and there is a debate to whether it is correct to regulate the whole group. Especially polymeric PFAS and PFAS in gas form — “F-gases” — have been suggested they get a different treatment. Polymers, the building blocks of plastics, have so far also often escaped regulation. But this is about to change. The production of fluoropolymers is especially problematic and the areas around the production sites are heavily polluted with PFAS. The waste phase is hard to control and leads to pollution. When it comes to <a target="_blank" href="https://chemsec.org/what-the-f-gases/">F-gases,</a> a main problem is that they break down into TFA, a PFAS that is found in increasingly high amounts in the aquatic environment. In short, the diversity of PFAS is important to consider when looking into how to replace them. But when it comes to regulation, there are no safe PFAS.

Are all PFAS the same?

There are many studies that have measured levels of PFAS in human blood, breast milk or urine. In all humans, in all studies, PFAS is found. 
PFAS are linked to a number of health issues, including different cancers, infertility and impaired immune function. There is a constant flow of new publications linking PFAS exposure to health and environmental problems, meaning we are only beginning to understand what a paramount problem we are facing with PFAS pollution. 

PFAS and human health

PFAS affect reproductive organs and have effects such as reduced sperm count, increased time to pregnancy and increased risk for miscarriage. PFAS are transferred from the mother to the child via the placenta in the womb and through breast milk when born. The risks for the unborn child include low birth weight, accelerated puberty, bone variations and behavioral changes.PFAS also interfere with other parts of the hormone system. PFAS disrupt the functioning of the thyroid, alter cholesterol levels and are associated with obesity.

Reproduction and development

PFAS are associated with a number of different types of cancer, and the most well studied PFAS — PFOA — is classified as a possible carcinogen by the International Agency for Cancer Research (IARC). The classification is based mainly on the association with kidney cancer and testicular cancer. These two are the cancer types with most evidence linked to PFAS. There are also studies linking PFAS to ovarian and breast cancer, prostate cancer, thyroid cancer and childhood leukemia.

Cancer

Among the most established health effects of PFAS is an impairment of the immune system, including reduction in antibodies following PFAS exposure. PFAS have also been linked to increase in bronchitis and pneumonia in children, as a consequence of the lowered immune response.A linked effect is a lowered response to vaccines and there is a concern that PFAS have worsened the effects of Covid-19, both because of reduced immune response and because decreased effectiveness of vaccines. When the EU’s food agency set the new limit value for food, it concluded that the immune response is the most critical parameter for establishing a new Tolerable Weekly Intake.

Impaired immune system

The same or similar effects that we see from PFAS in humans can also be expected to occur in wildlife, as we share much of our biology with other species. High levels of PFAS have been measured in a number of different animals, also in the most remote areas. In the polar regions PFAS are found in polar bears, seals, foxes, orcas and otters. PFAS are also taken up by and accumulated in plants. When it comes to studying PFAS in the environment, most studies focus on what this means for humans. There is a rising awareness that meat from both wild and domestic animals may exceed the limit values for safe consumption. And even for plant-based options, there are studies finding high levels of PFAS in both beer and tea.

PFAS in the Environment

Concern

Many industries use PFAS in some way or another for a variety of functions and purposes. These uses can be hard to find at a first glance. In this part of the guide, we publish reports with information on PFAS use and substitution with relevance for specific industry sectors. These reports have been published by a number of different organisations. ChemSec is not responsible nor liable for the content in them.

<a target="_blank" href="https://chemsec.org/reports/check-your-tech-a-guide-to-pfas-in-electronics/">Check Your Tech: A guide to PFAS in electronics</a><a target="_blank" href="https://www.spiedigitallibrary.org/journals/journal-of-micro-nanopatterning-materials-and-metrology/volume-21/issue-1/010901/Review-of-essential-use-of-fluorochemicals-in-lithographic-patterning-and/10.1117/1.JMM.21.1.010901.full?SSO=1">Overview of uses within semiconductor industry</a><a target="_blank" href="https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/per-and-polyfluoroalkyl-substances-alternatives-in-coatings-paints-varnishes.pdf">OECD report on Paints, Coatings and Varnishes</a><a href="https://chm.pops.int/Portals/0/download.aspx?d=UNEP-POPS-POPRC.10-INF-7.English.pdf">POPs report on PFAS in etching processes</a><a target="_blank" href="https://saferalternatives.org/assets/documents/A4-PFAS-Electronics-August-2023.pdf">Using Alternatives Assessment to Support Informed Substitution of PFAS in the Electronics Industry</a>

<a target="_blank" href="https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/PFASs-and-alternatives-in-food-packaging-paper-and-paperboard.pdf">OECD (2020), PFASs and Alternatives in Food Packaging (Paper and Paperboard) (OECD, 2020)</a><a target="_blank" href="https://apps.ecology.wa.gov/publications/documents/2204007.pdf">Per- and Polyfluoroalkyl Substances in Food Packaging Second Alternatives Assessment (Washington State Department (2022)</a><a target="_blank" href="https://www.cleanproduction.org/images/ee_images/uploads/resources/Alternatives_Food_Packaging_PFAS_Fact_Sheet_CPA_1-23-18_v2_FINAl_with_logos.pdf">Alternatives to PFAS coated food packaging (CPA)</a><a target="_blank" href="https://documents.packagingcovenant.org.au/public-documents/PFAS+in+Fibre-Based+Packaging">PFAS in fibre-based packaging (Australian Packaging Covenant Organisation 2021)</a><a target="_blank" href="https://apps.ecology.wa.gov/publications/documents/2104004.pdf">Washington State Report 1 on Food Packaging Alternatives</a>

Food packaging

<a target="_blank" href="https://www.ri.se/sites/default/files/2022-09/PFAS_Substitution_Guide_for_Textile_Supply_Chains.pdf">PFAS Substitution Guide for Textile Supply Chains (RISE 2022)</a><a target="_blank" href="https://www.kemi.se/publikationer/pm/2022/pm-2-22-pfass-in-chemical-products-and-textiles">PFASs in chemical products and textiles (KEMI 2022)</a><a href="https://dtsc.ca.gov/wp-content/uploads/sites/31/2022/05/Public-PFAS-Treatments-Alternatives-Summary_accessible.pdf">Potential Alternatives to PFASs in Treatments for Converted Textiles or Leathers (DTSC 2022)</a><a target="_blank" href="https://www2.mst.dk/Udgiv/publications/2015/05/978-87-93352-16-2.pdf">Alternatives to PFAS in textiles</a>

Textile

<a target="_blank" href="https://www.oecd.org/chemicalsafety/portal-perfluorinated-chemicals/per-and-polyfluoroalkyl-substances-alternatives-in-coatings-paints-varnishes.pdf">Per- and Polyfluoroalkyl Substances and Alternatives in Coatings, Paints and Varnishes (CPVs) (OECD 2022)</a>

Paints, coatings and varnishes

<a target="_blank" href="https://www.kemi.se/publikationer/pm/2021/pm-9-21-pfass-in-cosmetics">PFAS in Cosmetics (KEMI, 2021)</a>

Cosmetics

<a target="_blank" href="https://greensciencepolicy.org/docs/pfas-building-materials-2021.pdf">Building a better world. Eliminating unnecessary PFAS in building materials (Green Science Policy Institute 2021)</a>

Construction

<a target="_blank" href="https://www.ri.se/sites/default/files/2020-12/POPFREE%20Final%20report%20public.pdf">Promotion of PFAS-free alternatives (POPFREE 2020)</a><a target="_blank" href="https://substitution-perfluores.ineris.fr/sites/substitution-perfluores/files/documents/best-available-techniques-pfos-substitution_2022_uba.pdf">Best available techniques for PFOS substitution in the surface treatment of metals and plastics and analysis of alternative substances to PFOS when used in equipment for chromium plating and plastic etching (UBA 2020)</a><a target="_blank" href="https://echa.europa.eu/documents/10162/28801697/pfas_flourine-free_alternatives_fire_fighting_en.pdf/d5b24e2a-d027-0168-cdd8-f723c675fa98">The use of PFAS and fluorine-free alternatives in fire-fighting foams (ECHA/DG ENV 2022)</a><a target="_blank" href="https://echa.europa.eu/sv/information-on-chemicals/active-substance-suppliers">Non-fluoride containing pesticides</a><a target="_blank" href="https://norden.diva-portal.org/smash/get/diva2:1118439/FULLTEXT01.pdf">PFAS in products</a><a target="_blank" href="https://climate.ec.europa.eu/system/files/2022-06/f-gases_external_preparatory_study_en.pdf">Overview of F-gases and alternatives</a><a target="_blank" href="https://www.ri.se/sites/default/files/2020-12/POPFREE%20Final%20report%20public.pdf">Report including Ski wax alternatives</a><a target="_blank" href="https://chm.pops.int/Portals/0/download.aspx?d=UNEP-POPS-POPRC.10-INF-7.English.pdf">POPs report on PFAS in etching processes</a><a target="_blank" href="https://www.spiedigitallibrary.org/journals/journal-of-micro-nanopatterning-materials-and-metrology/volume-21/issue-1/010901/Review-of-essential-use-of-fluorochemicals-in-lithographic-patterning-and/10.1117/1.JMM.21.1.010901.full?SSO=1">Overview of uses within semiconductor industry</a><a target="_blank" href="https://www2.mst.dk/udgiv/publications/2011/06/978-87-92779-10-6.pdf">Alternatives to PFAS in hard chrome plating</a>

Other

Sector

To phase out PFAS you need to find a way to achieve the same functionality without them. The most straightforward approach is to simply replace one chemical with a safer one. But this can be tricky. Other ways include changing materials, technologies or production processes.

Substitution is rarely only about switching one chemical for another. A successful substitution requires an in-depth analysis to ensure all possible solutions are thought through. 
The best substitute can turn out to be a different material or to adjust the production process. It could even be the case that PFAS are not actually needed at all and can be removed without being replaced. In any case, it is crucial to have done an assessment of the alternative, to make sure you do not end up with a regrettable substitution.

Substitution as a method for phase-out

PFAS chemicals are extremely multifunctional. They can be used for anything from fire safety to waterproofing to electric insulation. There is no single replacement for all PFAS uses, but the substitute will depend on the function that PFAS provide in each specific case.In the section “typical PFAS uses”, you can get a basic understanding of the different properties that PFAS provide, but you might probably also need to ask your supplier about why PFAS are added in a specific case. When you understand why, you need to consider if this function is really necessary for the product. And if the answer is yes, you can start investigating alternative approaches to obtain the same function.

Identify the function 

If we look at PFAS in cosmetics and bicycle oils, PFAS could perhaps be removed without needing to be replaced. PFAS are sometimes added to reduce friction, but most customers would not notice a difference. The same goes for other products such as ski waxes, surfer shorts, dental floss, and guitar strings. PFAS could most likely be removed from these products without any replacement.An area where many PFAS alternatives have been developed over the last decade is the waterproofing of textiles used in rain jackets. A critical insight for companies that were early adopters of these alternatives was the understanding that even if the alternatives do not repel dirt as well as PFAS, the alternatives can still provide water repellence, which is the key function for rain jackets.When it comes to replacing PFAS in cookware, different methods are used. One is to use a different material, e.g. cast iron with added grease for frying. There are also alternative non-stick coatings, like ceramic coatings.

Some examples

Substitution as a phase-out method

It can be a tricky task to find alternatives. Here you will need to consider a number of different methods. Again, an obvious step is to ask your supplier and as awareness increase about the PFAS problem, it is likely that e.g. trade associations or similar have some knowledge on the issue. ChemSec offers the ChemSec Marketplace where providers of alternatives can publish information about their alternatives to hazardous chemicals.

Find, evaluate and compare alternatives

When you have identified one or more alternatives, you need to assess them. One key aspect is to look at the hazard properties of the alternatives. “Regrettable substitution” is a term referring to the many cases where one hazardous chemical has been replaced by an alternative that turned out to be equally problematic. There are many examples of this, especially when it comes to PFAS. PFOA and PFOS were the first to be targeted for phase-out, but they were replaced by a number of other PFAS, for example GenX, PFBS and PFHxA and so forth. Technically, it is easier to replace a chemical with a structurally similar one. From a safety point of view though, same structure often means same hazardous properties.On the <a target="_blank" href="https://echa.europa.eu/sv/home">ECHA website</a> you can find more information about hazardous properties, as well as if the substance is under regulatory scrutiny and whether or not it has been registered under REACH for use in the EU.Aside from a hazard assessment of alternatives, you also need to consider functionality. Availability and cost are, of course, also important as well as other potential environmental impacts of the alternative.

Alternatives assessment

<ul><li>Hazard assessment</li><li>Functionality of alternatives</li><li>Availability of alternatives</li><li>Costs</li><li>Changes to processes</li><li>Life-cycle considerations: energy, waste/discharge, CO2 emissions, etc.</li></ul>

The following aspects can be considered when assessing alternatives

If the aim of substitution is to reduce the use of hazardous chemicals, then the hazard assessment is where you should start. Once you are sure that you have one or more alternatives that are less hazardous than the substance you are substituting, you can look at the other aspects.Assessment of alternatives is widely discussed, and new and better methodologies are under development. The OECD has worked with stakeholders to create a toolbox that is designed to help you choose a method of alternatives assessment that suits your competence and requirements.<a target="_blank" href="https://www.oecd.org/chemicalsafety/risk-management/substitution-of-hazardous-chemicals/">Read more.</a>

Different methods

One of the most comprehensive methods for assessing alternatives is called the GreenScreen for safer chemicals. The methodology is provided by the organisation Clean Production Action and provides a rigorous comparative hazard assessment based on 18 different hazard endpoints. Care has been taken to assure that the criteria align with existing and upcoming regulations and standards. Chemicals are benchmarked on a scale of 1 to 4, which makes the comparison visible and easy. While the methodology is freely available for anyone to use, it requires expertise and understanding of toxicology and scientific literature. There are accredited consultants that are trained to perform these assessments. The GreenScreen methodology and benchmark system is also built in to some standards for the building, textiles and electronics sector.

GreenScreen for safer chemicals

ChemSec Marketplace is a unique resource to find safer alternatives. Producers of alternatives are invited to advertise their solutions. Companies looking for alternatives can browse the site and advertise for alternatives. ChemSec makes a very simple hazard assessment before publication, but encourages advertisers to share the assessments available for the product, e.g. GreenScreen assessments. Every day, two contacts are made between companies looking for safer alternatives and companies providing safer alternatives. There is a wide range of safer PFAS alternatives available on Marketplace.

ChemSec Marketplace

Even after thorough assessments, evaluations and comparisons of alternatives, things may occur that you could not foresee. It is therefore always wise to do a practical pilot test before implementing full-scale substitution.A good thing to keep in mind is that over time, as the demand for alternatives increases and they are being tested by more and more users, functionality tends to improve and prices tend to go down.

Don’t forget the pilot

Phase out

It has taken some time, but regulation is now finally stepping up to address this vast and problematic family of chemicals. A comprehensive PFAS ban is expected in the European Union within the coming years and a range of regulatory actions are in the pipeline in other regions as well.

So far, regulation on an EU level is in force only for a few PFAS chemicals. The first regulations came into force in 2006 and 2017 respectively, mainly targeting the PFAS chemicals PFOS and PFOA as well as other PFAS that break down into these. In February 2023, a restriction covering about 200 PFAS came into force. This restriction covers PFAS of a specific molecular chain length (C9-14). There are also restriction proposals for the PFAS chemicals PFHxA and PFHxS as well as chemicals that degrade into these. In addition, there is a restriction proposal for all PFAS use in firefighting foams.

In the European Union

The proposal for a so-called <a target="_blank" href="https://echa.europa.eu/it/registry-of-restriction-intentions/-/dislist/details/0b0236e18663449b">“universal” PFAS restriction</a> was published in February 2023. The starting point for this is that all PFAS, including fluoropolymers and F-gases, should be restricted in all applications.Five EU member states are behind the proposal, which will now be discussed over a couple of years until it is expected to come into force in 2025 or 2026. The main discussions forward will consider the proposed derogations from the restriction for certain applications where alternatives are not yet available. The derogations will be time-limited to 5 or 12 years. There are several consultation periods where stakeholders can provide input on the proposal. Information that is particularly valuable is information on the availability of alternatives for the applications that are proposed to be exempted from the restriction.

Upcoming universal PFAS restriction

In the absence of federal regulations of PFAS in the US, several individual states have taken initiatives to regulate PFAS. Some regulations target specific product groups, other focus on especially vulnerable population groups such as small children or workers. There are also reporting requirements, for example to disclose intentionally added PFAS in products. California, Main and New York already have some PFAS bans in place, and all of these have more regulations to enter into force in the coming years. Until 2028, also Washington, Minnesota, Vermont, Maryland, Colorado, Connecticut, and Hawaii will have introduced PFAS regulations.

Internationally, several PFAS are globally regulated through the Stockholm Convention, including PFOA, PFAS and PFHxS.

In the United States

A summary of upcoming PFAS regulation in the US. <a target="_blank" href="https://www.martenlaw.com/news-and-insights/pfas-in-consumer-products-are-targeted-by-state-regulators-and-class-action-plaintiffs">Read more.</a>

PFAS Guide

Are there PFAS chemicals in your product?

Possible PFAS hotspots

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