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The countdown is on for per-and polyfluoroalkyl substances (PFAS) reporting. A federal PFAS reporting rule recently published under the Toxic Substances Control Act (TSCA) requires businesses that manufacture or import, or have manufactured or imported, PFAS since January 1, 2011, to submit over a decade’s worth of PFAS usage data[1].

PFAS can be hidden deep in supply chains, so how do you figure out if PFAS are present in your organization’s products and manufacturing processes? The following questions will help you understand the scope of PFAS exposure within your supply chain.

Do your parts or products have these properties?

• Non-stick
• Electric insulation
• Flame retardant
• Thermal stability/heat resistance
• Chemical resistant
• Water repellent
• Anti-fogging
• Oil and stain-repellent
• Fluorination (a process that treats plastic containers to make packaging more stable; frequently used for food packaging and pesticides)

Does your organization or its suppliers use any of these chemicals?

• PTFE (polytetrafluoroethylene) such as Teflon™, Hyflon®, Fluon®, or Polyflon® resins
• ePTFE (expanded PTFE) such as Gore-Tex®, Virtek®, or Durapore® membranes
• PVDF and PVF (polyvinylidene or polyvinyl fluoride) such as Kynar®, Solef®, Hylar®, or Tedlar® resins
• PCTFE (polychlorotrifluoroethylene) such as Neoflon®, Kel-F®, or Voltalef® resins
• PFA (perfluoroalkoxy) and FEP (fluorinated ethylene-propylene) such as Neoflon GP® or Everflon® FEP resins

If you answered “yes” to any of the items above, it’s highly likely you’re within scope of PFAS requirements. If you answered “no,” it’s possible you are not in scope of PFAS restrictions. However, it’s still advisable to periodically review your materials and supply chain to ensure that these chemicals are not present or introduced inadvertently.

How can organizations develop a PFAS Management program?

Manufacturers have limited time and resources to spend on PFAS management, and they need to start planning now to gain visibility into which substances in their parts and products require immediate attention. Beyond the realm of compliance, PFAS not only pose enormous risks to consumer and environmental health, they also present risks like unplanned product redesigns and legal liability. Recently, 3M announced the company would discontinue the manufacturing and use of PFAS across its product portfolio by the end of 2025, which means that the organization will reformulate or discontinue nearly 25,000 products[2].

Knowing where to focus your efforts on identifying PFAS use is critical to reducing risk. Overall, a PFAS program should be as comprehensive as possible without adding undue strain on a company’s internal teams or supply chain partners. That means prompting suppliers for PFAS disclosures that can be used for multiple purposes. Suppliers may not be ready to respond to the sudden influx of PFAS data requests, and collecting all that PFAS data can be intensely time-consuming. To lessen the strain and ease data collection, a standardized survey should be implemented, requiring suppliers to understand and clearly identify their PFAS priorities and impacts.

What’s next?

While the federal TSCA ruling has been in the spotlight most recently, PFAS reporting requirements and restrictions have been in existence for several years on a global scale. For example, the EU has regulated PFAS since 2008. REACH contains PFAS in both the Candidate List of substances of very high concern (SVHCs) and the Annex XVII Restricted Substances List. In addition, forty-six U.S. states have already passed or proposed their own PFAS legislation. This patchwork approach to regulations can be overwhelming, made more complex by variances among regulators’ definitions of PFAS. And PFAS regulations will only increase and grow more rigorous in the years to come as scrutiny and demand escalate. The time to prepare your product stewardship and sustainability management programs to address PFAS risks is now.

[1] TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances. 40 CFR Part 705. May 24, 2024. https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping

[2] Samora, S. (2024, January 30). 3M on track to sunset PFAS manufacturing by 2026. Manufacturing Dive. https://www.manufacturingdive.com/news/3m-on-track-to-exit-pfas-forever-chemicals-manufacturing/705881/