12 questions PFAS manufacturers, importers and users should consider for continued market access, product viability and regulatory compliance in the fast-changing global PFAS regulatory landscape.
PFAS Identification & Use
1. Which PFAS are in my product or process?
2. Why are these PFAS used in my product or process?
PFAS (Per- and Polyfluoroalkyl Substances) are synthetic compounds containing -CF2- and/or -CF3 groups, as defined by the OECD. This broad category encompasses a wide range of substances, from low molecular weight species used as refrigerants to complex structures in medical applications and high molecular weight fluoropolymers employed in transportation and electronics. Their unique chemical and thermal stability, water and oil repellency, and biocompatibility make them indispensable across industries. However, these same properties contribute to environmental persistence and regulatory concerns, particularly as some PFAS, such as PFOA and PFOS, have demonstrated toxic effects. Understanding which PFAS are present in your products and why they are used is the first step toward ensuring regulatory compliance.
Global & Regional PFAS Regulations
3. Which territories regulate my product and process?
4. What PFAS legislation applies, and how can I demonstrate compliance?
Regulatory bodies worldwide are actively addressing PFAS usage, assessing appropriate restrictions and control measures. Substances such as PFOA, PFOS and PFHxS are already regulated under the Stockholm Convention, while aqueous film-forming foams (AFFF) face stringent restrictions in the EU. Now, regulators are shifting focus toward a broader range of PFAS chemicals, a group exceeding 10,000 substances.
The EU REACH regulation is at the forefront, introducing the Universal PFAS Restriction Proposal in January 2023. The European Chemicals Agency (ECHA) is currently evaluating this proposal, considering PFAS applications individually in various regulatory committee sessions. Meanwhile, country-specific regulations are also emerging, with some EU member states pursuing independent restrictions, and the UK formulating its distinct regulatory strategy.
In the USA, PFAS regulations vary by federal and state mandates, with the EPA’s PFAS Strategic Roadmap and enforceable drinking water standards for several PFAS, TSCA reporting requirements and multiple state level restrictions all enacted. Canada and Japan are amongst the other regions that are also developing their own PFAS legislation, reinforcing the global nature of this issue.
Challenges in PFAS Analysis & Detection
5. Which analytical techniques and extraction methods are pertinent to PFAS in my product or process?
6. Are there standard methods and reference materials available?
7. What is the limit of detection (LOD) required to demonstrate regulatory compliance?
A significant obstacle in PFAS management is accurately identifying their presence in products and processes. Even trace amounts of PFAS, such as coatings, can serve critical technical functions. However, detecting and quantifying PFAS, especially in complex articles, remains a formidable analytical challenge.
While established test methods exist for detecting several PFAS in water, they only cover a fraction of commercially relevant substances. Once extraction techniques are required, the availability of standardised testing methods diminishes further. Some industries have started to develop specific standards, but in many cases, a combination of targeted and non-targeted analytical techniques is essential, particularly when identifying by-products and degradation products.
Finding or Developing PFAS Alternatives
8. How can suppliers communicate PFAS presence and function?
9. What product declarations are required for regulatory compliance?
10. Are alternative materials available, or can they be developed?
To manage PFAS-related risks, companies must explore whether viable alternatives exist or if new solutions can be developed. Moving away from PFAS can reduce regulatory liability, minimize emissions, and mitigate supply chain disruptions. However, potential trade-offs, such as performance compromises and unforeseen risks, must be carefully assessed.
Collaboration across the supply chain is essential for evaluating PFAS alternatives and ensuring informed decision-making. Companies should work closely with suppliers to understand the benefits, risks, and regulatory implications of any changes.
PFAS Emissions & Liabilities
11. What are the PFAS emissions throughout product lifecycle and disposal?
12. What are the financial and legal liabilities related to PFAS use and emissions?
Looking ahead, the fate of PFAS chemistry remains uncertain. Will its reputation be permanently damaged due to environmental concerns and regulatory pressures, or will its irreplaceable role in critical applications drive the development of more sustainable PFAS solutions? Global regulations will continue to evolve, but the timeline for transitioning away from PFAS, or securing their continued use in essential applications remains uncertain.
Strategic PFAS Regulatory Support
Navigating PFAS compliance requires proactive assessment, regulatory awareness, and strategic planning. Engaging with regulatory bodies, industry groups, and suppliers is essential to stay ahead of evolving requirements and secure the future of PFAS-dependent applications.
Contact the Blue Frog Scientific PFAS regulatory experts to discuss how we can support your compliance strategy and help you answer these challenging PFAS-related questions.
