Introduction to PFAS

Definition: PFAS are a substance group of persistent, bio accumulative "forever chemicals".

Applications: Consumer goods (clothing, cosmetics), industrial uses (firefighting foam, electronic components), food packaging, medical devices, and other products requiring water resistance, heat resistance, or stain repellency.

Hazards:

Linked to health risks such as thyroid disease, fertility issues, and high cholesterol.

97% of Americans have detectable PFAS in their blood (based on U.S. health data).

Harm arises from environmental accumulation (water, soil, food chain) and long-term human exposure.

Global PFAS Regulations Overview

European Union (EU):

REACH Regulation: Restricts specific PFAS (e.g., PFOA, PFOS) in consumer products and requires SVHC (Substances of Very High Concern) notification.

POPs Regulation: Bans PFAS listed under the Stockholm Convention (e.g., PFOS, PFOA).

New Proposal: Phased expansion of restrictions (e.g., textiles, food contact materials) from 2024–2026, with potential comprehensive ban on perfluorinated substances (threshold: total fluorine ≤50 ppm).

Member State Actions: France (ban on PFAS in cosmetics and textiles by 2026), Denmark (implementation of limits by 2025).

United States:

Federal Level:

TSCA Regulation: Requires companies to report PFAS production/import data from 2011–2022 (submissions open July 2025, deadline January 2026).

State-Level Regulations:

States like California and Colorado have banned PFAS in food packaging, children’s products, etc. (phased implementation 2024–2026).

In 2024, PFAS-related bills accounted for 33% of state proposals (passage rate: 12.7%).

Canada:

CEPA Regulation: Classifies PFOS, PFOA, etc., as toxic substances and requires reporting of 2023 usage data (deadline January 2025).

Asia-Pacific:

China: 2023 "New Pollutants List" bans PFOS, PFOA, and others.

Japan: Prohibits specific PFAS (e.g., PFOA isomers).

Singapore: Bans PFAS in firefighting foam starting 2026.

Business Risks of PFAS

Supply Chain Disruptions: PFAS manufacturers (e.g.: 3M) are phasing out production, leading to shortages and price increases for PFAS-dependent components.

Litigation:

Surge in class-action lawsuits against companies using PFAS (e.g., Coca-Cola, Thinx, Colgate-Palmolive).

In 2023, 3M paid $10.3 billion in a drinking water contamination settlement.

Insurance Issues:

Insurers are excluding PFAS-related claims, forcing companies to justify PFAS use or switch to alternatives.

Brand Reputation:

Consumer distrust in "healthy" or "natural" labeling, with lawsuits over false claims.

Steps for PFAS Risk Management

Internal Audit: Review procurement records and manufacturing processes for PFAS usage.

Supplier Survey:

Collect chemical data from suppliers via standardized questionnaires (avoid relying solely on SDS/FMD).

Use automation tools (e.g., Assent platform) for efficiency.

Alternative Assessment:

Determine if PFAS can be replaced or if product redesign is necessary.

Plan ahead for component phase-outs and substitutions.

Product Recertification:

Redesigned products may require months to years for market reauthorization.

Documentation & Disclosure:

Centralize supply chain data, generate compliance reports, and disclose PFAS status on company websites or sustainability reports.

Value of Proactive Management

Benefits:

Early compliance with future regulations reduces costs.

Mitigates supply chain disruptions and enhances market competitiveness.

Enables rapid response to customer data requests, boosting brand trust.

Tool Support:

Platforms like Assent offer automated supplier surveys, global regulation tracking, and centralized data management.