Do you know your PFAS blind spots?

Existing and future PFAS restrictions around the world are likely to impact the products you manufacture and rely on. While some PFAS uses may already be on your radar, the chances are that others will not. TSG's regulatory and scientific experts can help you uncover your PFAS blind spots.

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PFAS (per- and polyfluoroalkyl substances) have been used in various products and applications, from semiconductors, fabrics and o-rings, to space craft and medical devices, to cookware and cosmetics. However, identifying PFAS in your products can be challenging considering the thousands of substances in scope, unreliable disclosure of information in complex supply chains and practical implications of testing. Potential for contamination during production, assembly and distribution may also cause problems.

Support with PFAS restrictions

TSG Consulting's team of scientific and regulatory experts can help you understand these challenges and navigate the emerging regulatory landscape to uncover your blind spots and ensure compliance with PFAS restrictions.

Our advisories and thought leadership articles below provide insight into the latest developments in PFAS restrictions. You can also sign up to our PFAS regulatory updates to receive news and articles direct to your inbox.

Learn more about our expert PFAS regulatory services here.

From a lack of labelling to complex supply chains, it can be challenging to know if your products contain PFAS. Our team of scientific and regulatory experts can help you uncover your blind spots and ensure compliance with PFAS restrictions around the world.

Get in touch for an introductory chat with our team

PFAS | Frequently asked questions

PFAS (per- and polyfluoroalkyl substances) is an umbrella term for many thousands of synthetic chemicals that have been used in industrial, professional and consumer products around the world since the 1940s. They all contain carbon-fluorine bonds and this chemical structure gives them highly useful properties such as heat resistance, oil/water repellence, friction reduction and stability and durability. However, these properties also give rise to concerns for the environment and human exposure for the same reason – they break down very slowly and accumulate in the environment. They can be measured in humans, food chains, groundwater, surface water and soil. For this reason, PFAS are often referred to as ‘forever chemicals’.

Given their properties, PFAS have been used in many and diverse applications including:

  • Food packaging and non-stick cookware: PFAS repel grease and prevent oil and grease soaking into paper and cardboard packaging. The non-stick surfaces on frying pans and paper food bags are just two examples of uses for such applications
  • Clothing and textiles: The ability for PFAS to resist heat and repel water and chemicals has resulted in their use in a range of specialty and durable materials, such as waterproof clothing, carpets, personal protective equipment (PPE) and performance fabrics
  • Industrial manufacturing processes: PFAS are used to make semiconductors, plastics, composite resins, and more
  • Coating and insulation: Their heat-resistant properties make PFAS useful in coatings for electrical cabling, lubricants in bike oil, or paints for corrosion protection
  • Firefighting: PFAS have historically been used in aqueous film forming foam (AFFF), which is effective at fighting flammable liquid fires such as fuel fires

The sheer number of PFAS means that very little is known about the hazards and risks of the vast majority of them. However, concerns from available data have driven concerns over health and environmental exposure and potential for related effects. The persistence of PFAS in the environment means that they are often measured in drinking water and the food chain. Certain PFAS are known to accumulate in animals, plants and humans. There is much discussion regarding the effects of exposure, but general agreement is that PFAS release and exposure should be minimized so far as possible. Concern for mounting PFAS exposure is driving interventions through regulatory control.

Determining whether your products contain PFAS can be a complex task, but there are steps you can take to gain clarity. Some products are more likely than others to contain PFAS. You can map PFAS in your supply chain and talk to your suppliers, who are also likely to be affected by existing and future PFAS restrictions. In some cases, testing for the presence of PFAS may be needed. Learn about the steps you can take to prepare for new PFAS restrictions.

There are several reasons why it’s hard to know if products contain PFAS. These include:

  • Lack of labelling: PFAS are not typically listed as ingredients on product labels, so companies may not know if they are present in their products
  • Complex supply chains: Many products contain components or ingredients that are sourced from multiple suppliers, making it difficult to track the use of PFAS throughout the supply chain
  • Limited testing: There are thousands of different PFAS compounds. Testing is expensive and expert input is needed to design appropriate strategies and interpret findings
  • PFAS contamination of raw materials: PFAS can be present in raw materials used to manufacture products, such as equipment, coatings, textiles, and packaging materials. If these raw materials are contaminated with PFAS, they can introduce PFAS into the final product without the company’s knowledge
  • Lack of regulatory requirements: In some regions, there are no specific regulations requiring companies to test for or disclose the presence of PFAS in their products. This can make it less of a priority for companies to proactively look for and report PFAS

We have many years’ experience with PFAS and support companies in undertaking PFAS impact assessments, helping them uncover their blind spots. Get in touch at [email protected] to find out how we can support you.

In short, ‘yes’. If passed in its current form, the restriction proposal would mark the biggest single ban on chemicals ever in the European Union (EU). It has a very broad scope, covering over 10,000 chemicals, with almost no exemptions. The proposal would see a full ban coming into force 18 months after the restriction becomes law. Some use-specific derogations are likely to be included to allow time for society to adjust to the effect of the ban. However, derogations are not exemptions – they only allow for extra time to adjust before the ban takes effect – and will be limited to certain sectors and applications.

PFAS | Advisories and thought leadership

Webinar | Mastering TSCA Compliance: Navigating PFAS Data Reporting

Chaired by Senior Regulatory Consultant Pete Stevenson and delivered by Principal Consultant Steven Buchanan and Regulatory...

26 April 2024

US EPA requires Toxics Release Inventory reporting for seven additional PFAS

For TRI Reporting Year 2024, reporting is required for these seven additional PFAS, bringing the total PFAS subject to TRI...

02 February 2024

TSCA Section 8(a)(7) Reporting Rule for PFAS

Under the rule, EPA requires all manufacturers and importers of PFAS and articles containing PFAS in any year since 2011 to...

20 October 2023

How to comply with PFAS regulations

PFAS, renowned for their exceptional properties like heat, water, and oil resistance, have found extensive applications in...

14 August 2023

PFAS: HSE publishes comprehensive analysis of PFAS and proposes future regulatory controls

HSE refers to its RMOA report as “the most comprehensive British analysis of these chemicals ever”. Their analysis sets...

12 April 2023

PFAS: Public consultations open on proposed PFAS restrictions in the EU and US

Our recent advisory highlighted the key headlines of the proposed restriction, aimed at reducing the risks that PFAS pose to...

22 March 2023

PFAS: Nine key headlines emerge from ECHA’s proposed restriction

While the information behind the proposals is extensive and will need to be evaluated carefully for each substance and use...

14 February 2023

EPA proposes Significant New Use Rule for the manufacturing or processing of 330 inactive PFAS

As it stands, companies are only required to submit a notification if they should choose to manufacture, import, or process a...

09 February 2023

Forever chemicals: how to get ready for the new PFAS restriction

Use of per- and polyfluoroalkyl substances (PFASs) will shortly be recast. New restrictions on use in the EU are imminent and...

17 January 2023

What can industry learn from existing PFAS restrictions ahead of further EU regulation of the substance group?

A restriction proposal on the import, manufacture, placing on the market and use of PFASs in the European Economic Area (EEA)...

09 January 2023