PFAS Compliance: The End of Forever?

Retailers and manufacturers of consumer products are facing mounting pressure to eliminate per- and polyfluoroalkyl substances (PFAS) , known as forever chemicals, from their products and supply chains. These substances, valued for their durability and resistance to water, oil and stains, are now at the center of a sweeping regulatory and public backlash due to their extreme persistence in the environment, proven health risks and widespread contamination. What was once considered an innovative material solution has become a growing liability, and the road to compliance is proving to be anything but simple.

The fragmented PFAS regulatory landscape

One of the most daunting challenges lies in the fragmented regulatory landscape. In the U.S., a patchwork of state laws has emerged, each with its own scope and timeline. States such as California, New York, Maine, Vermont and Minnesota have enacted PFAS bans or disclosure requirements covering a range of products, including apparel, cosmetics, cookware, food packaging and menstrual products. Some bans are already in effect, while others will phase in over the next few years.

Meanwhile, the U.S. federal government enacted a one-time reporting and recordkeeping requirement under Section 8(a)(7) of the EPA’s Toxic Substances Control Act (TSCA). Currently, no federal bans or restrictions exist on PFAS in consumer products. The U.S. Food and Drug Administration (FDA) has facilitated the voluntary removal of PFAS grease-proofing agents from food packaging. U.S. federal agencies including the Environmental Protection Agency (EPA) and Consumer Product Safety Commission (CPSC) have also requested information on PFAS in consumer products, but have not yet implemented specific bans or regulations targeting PFAS.

Outside the U.S., the European Union is moving toward sweeping restrictions under its Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) chemical regulations, and countries like France and Denmark have regulations in place that will be enacted respectively in January and July 2026 to pursue full bans on PFAS in consumer goods by the end of the decade.

For companies that operate in multiple jurisdictions, staying ahead of these various requirements is a complex and ongoing task.

The importance of supply chain transparency to eliminate PFAS from your supply chain

Even when a company resolves to eliminate PFAS from its products, execution presents challenges. Supply chain transparency remains a major hurdle, as PFAS can enter materials in unexpected ways through coatings, dyes or even contaminated manufacturing equipment. Identifying the presence of PFAS often requires expensive and sophisticated testing for total fluorine or specific PFAS compounds. For brands making claims of “PFAS-free” or complying with low-threshold state bans, robust verification is essential, yet many suppliers are either unable or unwilling to certify compliance with confidence.

Adding to the challenge is the difficulty of finding suitable alternatives. PFAS have become deeply embedded in product design because of their unique properties, and replacing them with safer, effective and economically viable substitutes is not always possible in the short term. Many companies are experimenting with silicone-based coatings, waxes, advanced polymers or even bio-based treatments, but these options can come at a higher cost and may not yet match the performance of PFAS-treated materials.

Also, an awareness of the risk of “regrettable substitution” is growing. Replacement chemicals may turn out to present their own environmental or health hazards. Some U.S. states are now mandating that manufacturers conduct detailed analyses of potential alternatives before making claims about the safety of replacement chemicals.

At the same time, companies must grapple with the legacy of existing inventory. Products manufactured before bans took effect may still contain PFAS, leaving retailers and brands with unsellable stock in certain states. Disposing of these goods presents both logistical and financial headaches. And looming over all of these operational concerns is the risk of litigation. Manufacturers, retailers and even suppliers have been named in lawsuits over alleged misrepresentation of “non-toxic” or “clean” products, as well as contamination of the environment.

The transition away from PFAS

Consumer expectations are rising alongside regulatory scrutiny. Shoppers are increasingly aware of the risks associated with PFAS and are demanding safer products. Many retailers have responded by pledging to phase out PFAS from private-label products and by adding “PFAS-free” labels to attract customers. But these claims invite their own scrutiny and must be backed by credible testing and documentation.

For many companies, compliance with PFAS regulations has become not just a legal necessity but a business imperative. Managing the associated costs, timelines and risks requires more than a simple substitution strategy; it demands a coordinated, long-term approach that integrates supply chain audits, rigorous testing protocols, research into alternatives, transparent communication with consumers and diligent monitoring of regulatory changes around the world.

The transition away from PFAS is one of the most significant product safety and sustainability challenges facing retailers and manufacturers today. Those who act early and thoughtfully to align their products and practices with emerging expectations will be better positioned to protect their reputation, maintain market access and meet the growing demand for safer, more sustainable consumer goods. Companies that succeed will be those able to navigate this complex and evolving landscape with foresight and integrity.