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When the U.S. Environmental Protection Agency (EPA) published its final per- and polyfluoroalkyl substances (PFAS) reporting rule under Section 8(a)(7) of the Toxic Substances Control Act (TSCA) in late 2023, it provided a working definition of PFAS, stating that it covered over 1,400 chemicals. However, this represents just the tip of the PFAS iceberg. Thousands of other substances are in active use outside the U.S., and many emerging regulations include PFAS chemicals that may not be registered yet. If manufacturers only pay attention to PFAS covered by the latest TSCA update, their PFAS program is only protecting them from a fraction of the risks presented by these “forever chemicals.”

Manufacturers have limited time and resources to spend on PFAS management, and they need to start planning to gain visibility into which substances in their parts and products require immediate attention. Hidden PFAS in supply chains not only pose enormous risk to consumer and environmental health, they also present risks like unplanned product redesigns and legal liability. Knowing where to focus your efforts on identifying PFAS use is crucial to reducing risk.

Think Globally

Although the recent federal TSCA ruling has been garnering the most attention, PFAS reporting requirements and restrictions have existed for many years on the global stage. In addition, numerous U.S. states have enacted their own PFAS legislation, with Maine and Minnesota issuing their own reporting rules. This patchwork approach to regulations can be overwhelming, made worse by global regulators that haven’t consistently defined PFAS.

For example, the EU Registration, Evaluation, Authorisation, and Restriction of Chemicals (REACH) Registry includes approximately 1,400 PFAS, while the TSCA Inventory contains over 2,600. There’s some overlap between the two, but not much. REACH contains PFAS in both the Candidate List of substances of very high concern (SVHCs) and the Annex XVII Restricted Substances List. Meanwhile, California Proposition 65 lists only a few PFAS.

Don’t Forget Operational Risks

Knowing which PFAS require attention isn’t just about regulatory compliance. In fact, for many manufacturers, operational risks like unplanned obsolescence present a separate issue. A robust PFAS program will include lists from non-governmental organizations (NGOs) as well.

PFAS can be hidden in facilities and operations, putting manufacturers at risk for disruption. For example, 3M, one of the world’s largest PFAS manufacturers, is ceasing PFAS production in 2025. A proactive PFAS program should therefore monitor PFAS that are at risk of obsolescence, like the nearly 25,000 3M products that will be discontinued in the near future.

It’s Time to Prioritize PFAS

Overall, a PFAS program should be as comprehensive as possible without adding undue strain on a company’s internal team or supply chain partners. That means asking suppliers for PFAS declarations that can be used for multiple purposes. To reduce supplier fatigue, a single, standardized survey should be implemented, requiring manufacturers to understand and clearly identify their PFAS priorities to suppliers.

A strong PFAS program, part of a company’s larger supply chain sustainability management program, should not just be a snapshot against today’s regulations. Instead, it should evolve continuously and drive efficiency through ongoing regulatory and risk monitoring. PFAS risks and requirements are only going to rise over the coming years. The time to establish a program is now.