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Overview

PFAS Compliance Guidance on Risk Assessment for Manufacturers

A lack of PFAS compliance threatens your market access and bottom line due to regulation and restriction under numerous evolving regulations, including:

  • REACH
  • POPs
  • Proposition 65
  • TSCA
See PFAS Requirements by State

PFAS Compliance Requirements Are Evolving

New regulations are cropping up, and current regulations are expanding, either broadening pfas reporting definitions to include more substances, or outright banning them. It’s important to start collecting information now because it will take substantial time to collect all the data you need for your PFAS solution.

Take proactive compliance steps like:

  • Identifying PFAS in your supply chain
  • Staying up to date on the latest regulations
  • Redesign where needed
  • Plan for the future

Our PFAS Solution

Latest Tools and Resources for PFAS Compliance

Prepare and scope your PFAS risks with our latest guides, webinars and whitepapers.

Guide
How to Prepare for PFAS Risks

Changing rules around per- and polyfluoroalkyl substances (PFAS) are creating unforeseen risks for manufacturers. If you aren’t …

Global Product Compliance, PFAS, Product Compliance
On-Demand, Webinar
The PFAS Puzzle: A 360-View of PFAS’ Multidimensional Risks

This webinar will give you a full 360-degree view of your PFAS risks, including market access loss, supply chain disruptions, part …

PFAS, Product Compliance
Guide
PFAS Scoping Guide

Manufacturers that have per- and polyfluoroalkyl substances (PFAS) in their products, supply chain, or processes could face lawsui …

PFAS

Frequently Asked Questions About PFAS Compliance

Research and regulations around PFAS compliance are constantly being updated, making it hard to keep up. Here are some of the common questions about PFAS compliance.

How Many PFAS Are Tracked?

The PFAS family contains thousands of chemicals that are actively monitored or regulated, and there are many others no longer in use or that may not be monitored at the moment. In addition, because PFAS are synthetic, there is no ceiling to the number of PFAS that could hypothetically exist in the future without regulatory intervention.

A number of different regulatory bodies and NGOs around the globe track PFAS, and because each of them uses a different formal definition of what are PFAS chemicals, the number of PFAS chemicals can differ between regulations. There is no official list or number of PFAS chemicals. This can make it difficult for businesses and consumers to understand their responsibilities and restrictions while using PFAS.

For instance, the Organisation for Economic Co-operation and Development (OECD) maintains a list of over 4,700 PFAS substances. The U.S. Environmental Protection Agency (EPA) identifies over 16,000.

Rather than focusing on the total number of PFAS, manufacturers should identify which PFAS are regulated or restricted (or are being considered for future regulation) in their relevant markets.

Most Common PFAS

The PFAS family of chemicals contains substances that are often used in the manufacture of industrial and consumer goods. Here are some of the more common ones and just a few examples of what the PFAS is used for (note that these substances may have several uses beyond what’s listed here):

  • Fluorinated ethylene propylene (FEP): A flexible and chemically-resistant copolymer that is mainly used as a film for computer wiring and cables.
  • Fluoroelastomers: A synthetic rubber with oil and grease resistance, good temperature resistance, and strong chemical and acid resistance. It is often used for o-rings and seals in aerospace, automotive, and industrial manufacturing facilities.
  • GenX™: The trademarked, popularized name for the ammonium salt of hexafluoropropylene oxide dimer acid (HFPO-DA). It also refers to the group of chemicals used to manufacture it. Used as a replacement for PFOA for manufacturing other fluoropolymers.
  • Perfluorooctanoic acid (PFOA): A byproduct of fluoropolymer production; used as a surfactant in chemical processes and in manufactured goods.
  • Perfluorooctanesulfonic acid (PFOS): A stain-repellent commonly used in fabric protectors.
  • Polychlorotrifluoroethylene (PCTFE): A water-repellent chemical commonly used in films to protect against moisture. For example, it is used in pharmaceutical packaging and LCD panels.
  • Polytetrafluoroethylene (ePTFE): A hydrophobic and oleophobic (oil-repellent) PFAS useful for medical accessories like face masks, wound-care, and ostomy bags.
  • Polytetrafluoroethylene (PTFE): A hydrophobic (water-resistant) PFAS that is non-wetting and resistant to high temperatures. Primarily used for its non-stick properties.
  • Polyvinyl fluoride (PVF): A PFAS mainly used in flame-resistant coatings. Commonly found in airplane interiors, automobiles, metal sheeting, and raincoats.
  • Polyvinylidene fluoride (PVDF): A specialty plastic that is resistant to solvents, acids, and hydrocarbons. Widely used across numerous industries.

Where Are PFAS Found? Common PFAS Uses

PFAS are found in essentially every category of consumer goods on the market. PFAS can be found in industrial parts and materials as well. In some cases, there may be PFAS-free versions available, but some specialized materials may not exist without the use of PFAS to give them their unique properties.

So, where are PFAS found in different categories of goods and materials? Here is a list of some examples:

Consumer Goods Where PFAS Are Found:

  • Air purification systems
  • Artificial turf
  • Carpets and rugs
  • Cell phones
  • Computer monitors
  • Cosmetics and personal care products
  • Dairy products
  • Desk chairs
  • Desk finishes and coatings
  • Floor coatings
  • Food packaging, including pizza boxes and microwaveable popcorn
  • Household cleaners like floor or toilet cleaner
  • Laptops
  • Menstrual products
  • Non-stick cookware
  • Paper plates
  • Pesticides
  • Plumber’s tape
  • Sticky notes
  • Toilet paper
  • Waterproof and stain-resistant clothing, such as rain jackets

Industrial Goods Where PFAS Are Found:

  • Antifogging coatings and wipes
  • Electronics
  • Evaporation barriers (e.g., plating tanks)
  • Firefighting foam
  • Fuel-, oil-, and chemical-resistant components
  • Gaskets, o-rings, and seals
  • Heat-resistant coatings
  • Heat-resistant electrical insulation
  • Hoses and tubing
  • Non-reactive lubricants (oil, grease)
  • Non-wetting (hydrophobic) surface coatings
  • Oleophobic or lipophobic surface coatings
  • Oxygen sensors and related “breathable” membranes
  • Packaging materials
  • Paints and inks
  • Personal protective equipment (PPE)
  • Plastic-molded parts
  • Tape and adhesives

North American Regulatory Risks

  • TSCA: The Environmental Protection Agency (EPA) roadmap for PFAS, including a  proposal requiring PFAS reporting going back to 2011. The final rule is expected to include 1,300+ substances.
  • 30+ states have created or proposed legislation regulating PFAS substances, including the state of Maine, which will require reporting of all products containing PFAS beginning in January 2023.

EU PFAS Regulatory Risks

  • REACH, POPs, and the EU MDR restrict many PFAS.
  • C9-14 PFCAs will be restricted through REACH in 2023 as part of the Annex XVII Restricted List.
  • Five countries are preparing a REACH restriction proposal to include up to 4,700 PFAS chemicals, which is expected in 2023 and would take effect as early as 2025.

What Are PFAS Used For?

PFAS are widely used across various industries to achieve certain product benefits or allow certain manufacturing processes to take place. Because of their strong chemical bonds, they are resistant to water, stains, grease, and high temperatures. Businesses looking to determine what are PFAS used for in their processes should identify products or materials that have properties commonly associated with PFAS :

  • Non-stick
  • Electrical insulation
  • Flame-retardant
  • Thermal stability/heat resistance
  • Chemical resistance
  • Water-repellent
  • Anti-fogging
  • Oil- and stain-repellent
  • Ultraviolet resistance

In addition, the durability of PFAS makes them desirable in industrial sectors — including aerospace, automotive, construction, and electronics — and they play a critical role in the production of components that must withstand challenging environments.

How Do PFAS Chemicals Affect Human Health?

The same qualities that make PFAS so durable and resistant to heat and degradation also mean that PFAS do not break down over time and accumulate in the soil and drinking water, often bioaccumulating in the human body. In fact, according to national health authorities in the U.S., approximately 97% of Americans have PFAS in their bloodstreams. 

Studies have shown PFAS may have adverse human effects. They could lead to health conditions such as:

  • Increased risk of thyroid disease
  • Increased blood cholesterol levels
  • Decreased vaccine response
  • Decreased fertility in women
  • Lower infant birth weight

According to current research from the EPA, PFAS exposure can take place through many different routes:

  • Drinking water contaminated with PFAS
  • Eating certain foods that may contain PFAS, such as fish or dairy products
  • Breathing air contaminated with PFAS
  • Using products made with PFAS or that come in packages made with PFAS
  • Swallowing dust or dirt that contains PFAS
  • Working in environments that use PFAS, including chemical manufacturing or firefighting, and using PFAS chemicals

Why Are Governments Concerned About PFAS?

Regulators like the EPA and the European Chemicals Agency (ECHA) are increasingly concerned about PFAS. They are present in water sources, soil, and air, and in consumer and industrial products. They are also commonly used in manufacturing. This makes it difficult to avoid PFAS, so there is a high exposure rate for the everyday consumer and worker. 

Their persistent nature also makes PFAS difficult to remove from soil and drinking water, with traditional water-filtration technologies proving ineffective at mitigating PFAS contamination. However, there are a number of filtration methods that have been found effective by the EPA, including activated carbon treatment, ion exchange treatment, and high-pressure membranes.

Several lawsuits have been led by U.S. state and municipal governments against PFAS manufacturers over drinking water contamination. In addition, the EPA finalized the National Primary Drinking Water Regulation that sets PFAS contamination limits for six types of PFAS in drinking water.

On April 17, 2024, the EPA also classified thePFOA and PFOS as “hazardous” under the U.S. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.

For more information on PFAS regulations, visit our PFAS reporting and state requirements page.

Frequently Asked Questions About PFAS

Research and regulations around PFAS are constantly being updated, making it hard to keep up. Here are some of the common questions about PFAS compliance.

How Many PFAS Are Tracked?

The PFAS family contains thousands of chemicals that are actively monitored or regulated, and there are many others no longer in use or that may not be monitored at the moment. In addition, because PFAS are synthetic, there is no ceiling to the number of PFAS that could hypothetically exist in the future without regulatory intervention.

A number of different regulatory bodies and NGOs around the globe track PFAS, and because each of them uses a different formal definition of what are PFAS chemicals, the number of PFAS chemicals can differ between regulations. There is no official list or number of PFAS chemicals. This can make it difficult for businesses and consumers to understand their responsibilities and restrictions while using PFAS.

For instance, the Organisation for Economic Co-operation and Development (OECD) maintains a list of over 4,700 PFAS substances. The U.S. Environmental Protection Agency (EPA) identifies over 16,000.

Rather than focusing on the total number of PFAS, manufacturers should identify which PFAS are regulated or restricted (or are being considered for future regulation) in their relevant markets.

Most Common PFAS

The PFAS family of chemicals contains substances that are often used in the manufacture of industrial and consumer goods. Here are some of the more common ones and just a few examples of what the PFAS is used for (note that these substances may have several uses beyond what’s listed here):

  • Fluorinated ethylene propylene (FEP): A flexible and chemically-resistant copolymer that is mainly used as a film for computer wiring and cables.
  • Fluoroelastomers: A synthetic rubber with oil and grease resistance, good temperature resistance, and strong chemical and acid resistance. It is often used for o-rings and seals in aerospace, automotive, and industrial manufacturing facilities.
  • GenX™: The trademarked, popularized name for the ammonium salt of hexafluoropropylene oxide dimer acid (HFPO-DA). It also refers to the group of chemicals used to manufacture it. Used as a replacement for PFOA for manufacturing other fluoropolymers.
  • Perfluorooctanoic acid (PFOA): A byproduct of fluoropolymer production; used as a surfactant in chemical processes and in manufactured goods.
  • Perfluorooctanesulfonic acid (PFOS): A stain-repellent commonly used in fabric protectors.
  • Polychlorotrifluoroethylene (PCTFE): A water-repellent chemical commonly used in films to protect against moisture. For example, it is used in pharmaceutical packaging and LCD panels.
  • Polytetrafluoroethylene (ePTFE): A hydrophobic and oleophobic (oil-repellent) PFAS useful for medical accessories like face masks, wound-care, and ostomy bags.
  • Polytetrafluoroethylene (PTFE): A hydrophobic (water-resistant) PFAS that is non-wetting and resistant to high temperatures. Primarily used for its non-stick properties.
  • Polyvinyl fluoride (PVF): A PFAS mainly used in flame-resistant coatings. Commonly found in airplane interiors, automobiles, metal sheeting, and raincoats.
  • Polyvinylidene fluoride (PVDF): A specialty plastic that is resistant to solvents, acids, and hydrocarbons. Widely used across numerous industries.
Where Are PFAS Found? Common PFAS Uses

PFAS are found in essentially every category of consumer goods on the market. PFAS can be found in industrial parts and materials as well. In some cases, there may be PFAS-free versions available, but some specialized materials may not exist without the use of PFAS to give them their unique properties.

So, where are PFAS found in different categories of goods and materials? Here is a list of some examples:

Consumer Goods Where PFAS Are Found:

  • Air purification systems
  • Artificial turf
  • Carpets and rugs
  • Cell phones
  • Computer monitors
  • Cosmetics and personal care products
  • Dairy products
  • Desk chairs
  • Desk finishes and coatings
  • Floor coatings
  • Food packaging, including pizza boxes and microwaveable popcorn
  • Household cleaners like floor or toilet cleaner
  • Laptops
  • Menstrual products
  • Non-stick cookware
  • Paper plates
  • Pesticides
  • Plumber’s tape
  • Sticky notes
  • Toilet paper
  • Waterproof and stain-resistant clothing, such as rain jackets

Industrial Goods Where PFAS Are Found:

  • Antifogging coatings and wipes
  • Electronics
  • Evaporation barriers (e.g., plating tanks)
  • Firefighting foam
  • Fuel-, oil-, and chemical-resistant components
  • Gaskets, o-rings, and seals
  • Heat-resistant coatings
  • Heat-resistant electrical insulation
  • Hoses and tubing
  • Non-reactive lubricants (oil, grease)
  • Non-wetting (hydrophobic) surface coatings
  • Oleophobic or lipophobic surface coatings
  • Oxygen sensors and related “breathable” membranes
  • Packaging materials
  • Paints and inks
  • Personal protective equipment (PPE)
  • Plastic-molded parts
  • Tape and adhesives
North American PFAS Regulatory Risks
  • TSCA: The Environmental Protection Agency (EPA) roadmap for PFAS, including a  proposal requiring PFAS reporting going back to 2011. The final rule is expected to include 1,300+ substances.
  • 30+ states have created or proposed legislation regulating PFAS substances, including the state of Maine, which will require reporting of all products containing PFAS beginning in January 2023.
EU PFAS Regulatory Risks
  • REACH, POPs, and the EU MDR restrict many PFAS.
  • C9-14 PFCAs will be restricted through REACH in 2023 as part of the Annex XVII Restricted List.
  • Five countries are preparing a REACH restriction proposal to include up to 4,700 PFAS chemicals, which is expected in 2023 and would take effect as early as 2025.
What Are PFAS Used For?

PFAS are widely used across various industries to achieve certain product benefits or allow certain manufacturing processes to take place. Because of their strong chemical bonds, they are resistant to water, stains, grease, and high temperatures. Businesses looking to determine what are PFAS used for in their processes should identify products or materials that have properties commonly associated with PFAS :

  • Non-stick
  • Electrical insulation
  • Flame-retardant
  • Thermal stability/heat resistance
  • Chemical resistance
  • Water-repellent
  • Anti-fogging
  • Oil- and stain-repellent
  • Ultraviolet resistance

In addition, the durability of PFAS makes them desirable in industrial sectors — including aerospace, automotive, construction, and electronics — and they play a critical role in the production of components that must withstand challenging environments.

How Do PFAS Chemicals Affect Human Health?

The same qualities that make PFAS so durable and resistant to heat and degradation also mean that PFAS do not break down over time and accumulate in the soil and drinking water, often bioaccumulating in the human body. In fact, according to national health authorities in the U.S., approximately 97% of Americans have PFAS in their bloodstreams. 

Studies have shown PFAS may have adverse human effects. They could lead to health conditions such as:

  • Increased risk of thyroid disease
  • Increased blood cholesterol levels
  • Decreased vaccine response
  • Decreased fertility in women
  • Lower infant birth weight

According to current research from the EPA, PFAS exposure can take place through many different routes:

  • Drinking water contaminated with PFAS
  • Eating certain foods that may contain PFAS, such as fish or dairy products
  • Breathing air contaminated with PFAS
  • Using products made with PFAS or that come in packages made with PFAS
  • Swallowing dust or dirt that contains PFAS
  • Working in environments that use PFAS, including chemical manufacturing or firefighting, and using PFAS chemicals
Why Are Governments Concerned About PFAS?

Regulators like the EPA and the European Chemicals Agency (ECHA) are increasingly concerned about PFAS. They are present in water sources, soil, and air, and in consumer and industrial products. They are also commonly used in manufacturing. This makes it difficult to avoid PFAS, so there is a high exposure rate for the everyday consumer and worker. 

Their persistent nature also makes PFAS difficult to remove from soil and drinking water, with traditional water-filtration technologies proving ineffective at mitigating PFAS contamination. However, there are a number of filtration methods that have been found effective by the EPA, including activated carbon treatment, ion exchange treatment, and high-pressure membranes.

Several lawsuits have been led by U.S. state and municipal governments against PFAS manufacturers over drinking water contamination. In addition, the EPA finalized the National Primary Drinking Water Regulation that sets PFAS contamination limits for six types of PFAS in drinking water.

On April 17, 2024, the EPA also classified thePFOA and PFOS as “hazardous” under the U.S. Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.

For more information on PFAS regulations, visit our PFAS reporting and state requirements page.

Gaining Visibility Into Where PFAS Are Used in Supply Chains

As consumer and regulator scrutiny of PFAS grows, manufacturers must understand where PFAS are found in their parts, products, and supply chains.

Gaining visibility into the use of PFAS within their supply chains is crucial for manufacturers, primarily to ensure compliance with evolving regulations and to mitigate potential health and environmental impacts, and to avoid other business risks. Understanding what are PFAS used for in products, and knowing what are PFAS can help manufacturers anticipate supply chain factors that could affect their operations or necessitate costly reformulations of products. Furthermore, with increasing consumer awareness, manufacturers that demonstrate proactive management of PFAS may gain reputational benefits and competitive advantage as market trends shift towards transparency and sustainability.

Manufacturers can gain visibility into their PFAS use by engaging with their suppliers and surveying them about their PFAS use in the parts they provide. They should also familiarize themselves with the definition of what are PFAS used by the regulators in the markets they do business in.

How Assent Helps Manufacturers Identify PFAS Use

Assent simplifies the complex task of tracking and managing PFAS use in the supply chain. We automate supplier survey campaigns and improve the reporting process using a comprehensive software platform and secure supplier portal.

With our PFAS solution, manufacturers can gather and review detailed information about the components and materials suppliers provide. Real-time dashboards and reporting features deliver invaluable insights into the presence of PFAS in products, helping businesses meet their regulatory requirements and make informed decisions about sourcing and product development.

Assent also provides unmatched regulatory expertise into where PFAS are used. Our team of knowledgeable professionals stays current with the evolving landscape of global PFAS regulations, providing guidance to manufacturers navigating complex compliance channels. Through training, solution updates, and strategic program guidance, Assent ensures that manufacturers are equipped with the industry best practices they need to handle regulatory changes as they happen.

Learn how to identify and mitigate PFAS risks in your supply chain by visiting our PFAS solution page.

Discover Assent’s PFAS Solution

Identify PFAS in your supply chain and set yourself up for success.