PFAS
The "forever chemical" compliance challenge
PFAS are a class of over 10,000 synthetic chemicals valued for their water, grease, and heat resistance. Found in non-stick coatings, waterproof textiles, electronic components, and industrial gaskets, PFAS are now subject to rapidly expanding regulation across every major market. The EU is pursuing a near-universal restriction, U.S. states are enacting product-specific bans, and customer-driven PFAS-free requirements are becoming standard across industries.
A snapshot of the live reporting dashboard our clients receive.
Real-time visibility across your PFAS compliance program - from substance screening to supplier declarations and substitution tracking.
PFAS Regulatory Coverage
Portfolio Screening Status
PFAS Screening Reports & Substitution Roadmaps
We deliver component-level PFAS screening reports that identify exactly where PFAS exists in your products, assess regulatory exposure across jurisdictions, and map substitution pathways with realistic timelines.
- Component-by-component PFAS presence screening across your bill of materials
- Regulatory mapping showing which PFAS rules apply to your products and markets
- Lab testing coordination for Total Organic Fluorine (TOF) and targeted PFAS analysis
- Customer-facing PFAS declarations and substitution timeline documentation
Complex supply chains, hidden exposure
Manufacturers, importers, and brands selling products that may contain PFAS in any form - including coatings, adhesives, lubricants, sealants, packaging, textiles, and electronic components.
PFAS exposure is often hidden deep in the supply chain, making compliance particularly challenging for companies with complex bills of materials. The EU universal restriction proposal and rapid U.S. state-by-state expansion have made proactive screening a commercial necessity, not just a regulatory one. Customers and major retailers are now requiring PFAS declarations before regulatory deadlines.
The regulatory obligations that matter
PFAS regulation is fragmented across jurisdictions with different scope definitions, timelines, and exemption frameworks. Understanding which rules apply to your products requires systematic mapping - not assumptions.
A universal restriction proposal under REACH Annex XV covering all PFAS defined by at least one fully fluorinated carbon atom, with limited use exemptions and staggered transition periods by product category.
Over 15 states have enacted or proposed PFAS restrictions targeting consumer products, food packaging, textiles, cookware, and firefighting foam - each with its own effective dates, thresholds, and product scope definitions.
Requires reporting of PFAS manufactured or processed in the U.S., or imported, since 2011. The initial reporting deadline has passed, but EPA enforcement and supplemental reporting obligations remain active.
Major OEMs and retailers now require PFAS-free declarations from their supply chain as part of responsible sourcing programs - often ahead of any regulatory deadline and with stricter scope than current laws.
Individual PFAS including PFOS, PFOA, and PFHxS are already restricted under the EU Persistent Organic Pollutants (POPs) Regulation or REACH Annex XVII, with binding obligations currently in force.
Critical PFAS Compliance Gaps
The most common failure points in PFAS compliance programs - and why companies get caught out.
Unknown PFAS in the Supply Chain
Most companies do not know where PFAS exists in their products. PFAS appear in adhesives, sealants, thermal interface materials, and industrial coatings - not only in obvious applications like non-stick surfaces or waterproof fabrics.
Unverified Supplier Declarations
Relying on declarations that say "no intentionally added PFAS" without laboratory testing or verification exposes manufacturers to downstream liability when those claims prove inaccurate under TOF or targeted analysis.
Rapid State-Level Expansion
Companies not actively tracking U.S. state-level ban activity are routinely surprised by new effective dates. The patchwork of state laws creates a moving compliance target that requires continuous monitoring.
Waiting for the EU Restriction to Finalize
Deferring compliance work until the EU universal restriction is formally adopted creates an impossible execution timeline. Screening, testing, and material substitution each require 12 to 24 months.
Inconsistent PFAS Definitions Across Regulators
The OECD, EPA, and EU restriction proposal do not use identical PFAS definitions. This creates genuine uncertainty about which substances are in scope and requires jurisdiction-specific scoping for each market.
Conflating "PFAS-Free" with "Below Detection Limit"
Not differentiating between "PFAS-free" and "below detection limit" in customer communications creates legal exposure and erodes customer trust when laboratory results show trace-level findings in supposedly clean products.
From screening to substitution - a complete PFAS program
Component-level screening across product portfolios, bills of materials, and supply chains to identify where PFAS exists and map highest-priority regulatory exposure.
Which PFAS rules apply to your specific products, markets, and customer requirements - covering U.S. state bans, TSCA reporting, EU restriction, and REACH/POPs obligations.
Structured supplier disclosure campaigns with managed follow-up, escalation logic, and declaration verification to achieve high response rates and audit-ready records.
Coordination of Total Organic Fluorine (TOF) analysis and targeted PFAS testing through accredited laboratories, with results interpretation and structured reporting.
Realistic substitution pathway planning with transition timelines, alternative material assessments, and qualification support for PFAS-free alternatives across component categories.
Preparation of accurate customer-facing PFAS declarations that clearly differentiate between PFAS-free, below detection limit, and active substitution statuses - with legal defensibility built in.
Continuous monitoring of new PFAS restrictions, state-level developments, and EU restriction milestones - with client-specific impact assessments as regulatory scope evolves.
All PFAS engagements are delivered at fixed fees with defined scope and audit-ready outputs. No hourly billing, no scope ambiguity - you know what you are paying for before work begins.
Need PFAS Compliance Support?
We screen your products, map your regulatory exposure, and build a plan to get ahead of restrictions - before your customers or regulators do it for you. Fixed fees. Audit-ready outputs.