Global PFAS regulations are accelerating worldwide as governments respond to growing evidence of long-term health and environmental harm. This acceleration creates more complications for compliance teams, as requirements vary by market, product category, and the PFAS lists referenced in each regulation. For manufacturers, brands, and retailers, the challenge goes beyond identifying PFAS. It’s keeping pace with changing restrictions, disclosure rules, and enforcement trends across the United States, the European Union, and other key markets.
With new PFAS compliance requirements taking effect in 2026 and 2027, companies must develop a clear compliance plan to prevent supply chain disruptions, delayed product launches, and unnecessary regulatory risk. Recent France-specific restrictions further underscore the need for companies selling into the European Union to monitor PFAS developments and prepare for upcoming deadlines.
PFAS: forever chemicals
PFAS (poly- or per-fluoroalkyl substances) are a large group of chemicals used in consumer, commercial, and industrial products that repel water, grease, and dirt. PFAS compounds break down exceptionally slowly, which means they accumulate in people, animals, and the environment over time, including food, water, soil, and the air. Because of this trait, PFAS substances are often referred to as “forever chemicals.” According to current regulatory and scientific assessments, there are more than 12,000 known PFAS compounds in use globally.
PFAS exposure poses significant risks to human health and the environment, and, due to their widespread use, most people have been exposed to PFAS during their lifetimes. PFAS can be found in thousands of everyday products, including:
- Non-stick cookware such as frying pans
- Waterproof clothing such as raincoats and water-repellent fabrics such as those used to make tents
- Stain-resistant fabrics such as those used in upholstery
- Food packaging such as greaseproof paper
- Firefighting foams
- Personal care products like shampoo
- Electronics such as cables
- Cleaning products such as laundry detergents
In response, the use of PFAS in consumer products continues to come under scrutiny, resulting in more restrictions worldwide each year. As a result, governments are moving beyond isolated substance controls toward broader phaseouts, reporting obligations, and product-specific restrictions, setting the stage for expanded PFAS regulations in 2026 and beyond.
U.S. EPA PFAS regulations
The U.S. Environmental Protection Agency (EPA) has taken key actions at the federal level through reporting requirements, new use controls, and reforms to chemical review processes. For companies manufacturing, importing, or selling PFAS-containing substances, mixtures, or articles, planning will require close attention to both finalized rules and proposed revisions that could affect scope and timing.
PFAS reporting under TSCA
Under Section 8(a)(7) of the Toxic Substances Control Act (TSCA), manufacturers and importers are required to report on PFAS they have produced or imported since 2011. The rule applies to PFAS listed on the CompTox list, the Public List of TSCA PFAS, and the CDX 8(a)(7) SRS list. These lists are non-exhaustive, meaning any substance that meets the structural definition of PFAS falls within scope.
Companies must gather and report all known or reasonably ascertainable information related to PFAS, including chemical identity, production volumes, industrial and consumer uses, worker exposure, hazards, and disposal methods.
Current reporting milestones remain in effect:
- April 13, 2026: Start of the official PFAS reporting period
- October 13, 2026: Final reporting deadline for most manufacturers and importers of PFAS and PFAS-containing articles
- April 13, 2027: Final reporting deadline for small businesses that exclusively import PFAS-containing articles
At the same time, the EPA has proposed revisions intended to reduce unnecessary or duplicative reporting burdens while preserving the agency’s ability to collect critical PFAS use and safety data. The proposed approach includes potential exemptions for:
- PFAS manufactured or imported at concentrations at or below 0.1%
- Research and development chemicals
- Non-isolated intermediates and impurities
- Certain byproducts
- Imported articles, which would eliminate the need for a streamlined reporting form specific to article importers
The proposal would also shorten the PFAS submission window to begin 60 days after the final rule’s effective date and last for three months. While these revisions are not yet finalized, companies preparing TSCA PFAS reporting should plan based on the current milestones while monitoring how the final rule may adjust reporting scope, thresholds, or timelines.
Significant New Use Rule for Inactive PFAS
In early 2024, the EPA finalized a Significant New Use Rule (SNUR) that prevents the manufacturing or processing of inactive PFAS without an EPA review and risk determination. An “inactive” designation means that a chemical substance has not been manufactured (including imported) or processed in the United States since June 21, 2006. This SNUR is a key action under the PFAS Strategic Roadmap and applies to all PFAS that are designated as “inactive” on the Toxic Substances Control Act (TSCA) Inventory and are not already subject to a SNUR.
The EPA has aligned the rule with reporting requirements for the Active-Inactive rule. If a company wants to use any of the 329 PFAS, they must first notify the EPA. Upon notification, the agency will conduct a robust review of health and safety information under the 2016 law to determine if the new use may present an unreasonable risk to human health or the environment and establish any necessary restrictions before the use can restart. Any new uses of PFAS are evaluated under the framework that was announced in June 2023.
New EPA TRI Reporting Requirements for PFAS
All PFAS chemicals listed under the Toxics Release Inventory (TRI) are classified as “chemicals of special concern.” The supplier notification requirement for PFAS starts immediately when they are added to the TRI. Supplier notifications must begin with the first shipment of the calendar year when the chemical addition to TRI is effective.
Additionally, there is no longer a reporting exemption allowing small concentrations of PFAS chemicals to be omitted from reporting. On January 3, 2025, nine PFAS were added to the TRI-listed chemicals, bringing the total number of reportable PFAS to 205 for the 2025 reporting year. This rule took effect on March 21, 2025. Reporting forms are due by July 1, 2026. The nine additional PFAS include:
- Ammonium perfluorodecanoate [CAS #:(PFDA NH4) (3108-42-7)]
- Sodium perfluorodecanoate [CAS #:(PFDA-Na) (3830-45-3)]
- Perfluoro-3-methoxypropanoic acid [CAS #: (377-73-1)]
- 6:2 Fluorotelomer sulfonate acid [CAS #: (27619-97-2)]
- 6:2 Fluorotelomer sulfonate anion [CAS #:(425670-75-3)]
- 6:2 Fluorotelomer sulfonate potassium salt [CAS #: (59587-38-1)]
- 6:2 Fluorotelomer sulfonate ammonium salt [CAS #: (59587-39-2)]
- 6:2 Fluorotelomer sulfonate sodium salt [CAS #: (27619-94-9)]
- Acetic acid, [(γ-ω-perfluoro-C8-10-alkyl)thio] derivs., Bu esters [CAS #: (3030471-22-5)]
The EPA’s Reformed New Chemicals Review Process
In late 2024, the EPA strengthened its new chemicals review process under TSCA to better address risks posed by PFAS and other persistent, bioaccumulative, and toxic substances. The revised approach removes exemptions that previously allowed certain PFAS to undergo abbreviated reviews based on low production volumes or limited exposure.
As a result, companies face increased scrutiny of environmental persistence and human exposure potential before new PFAS can be approved for manufacture or import, raising the compliance bar for introducing new substances into the U.S. market.
U.S. State-level PFAS Regulations
Several states have implemented PFAS regulations in recent years. With the growing public awareness regarding PFAS, especially PFAS found in consumer products, state-level regulations are expected to continue expanding in the years to come.
Several states are advancing PFAS requirements that companies should monitor as part of 2026 compliance planning:
- New Mexico has proposed rules to implement its PFAS Protection Act, which would prohibit products containing intentionally added PFAS, require labeling and reporting, and establish phased product bans between 2027 and 2032. Manufacturers would be required to submit reports by January 1, 2027, with updates due within 30 days of significant changes.
- Maine has finalized decisions on currently unavoidable use requests for products subject to its 2026 PFAS sales prohibition. Of eleven requests submitted, nine were rejected. Two approvals were granted for specific cleaning product components and will remain in effect until January 1, 2031.
- Pennsylvania has introduced House Bill 2145, proposing a ban on intentionally added PFAS in select consumer products. If enacted, the law would prohibit the manufacture or sale of covered products containing intentionally added PFAS beginning January 1, 2028, with exclusions for used products, FDA-approved pharmaceuticals, and federally regulated medical devices. Manufacturers would be required to provide sellers with a signed certificate of compliance and notify vendors of any noncompliant products by July 1, 2027, while the Department of Environmental Protection would oversee enforcement.
Let’s take a closer look at the PFAS regulation requirements in Minnesota, Maine, and Colorado.
Minnesota: Amara’s Law (Sec. 116.943 MN Statutes)
Minnesota has extended the initial reporting deadline for Amara’s Law, which bans intentionally added PFAS in certain products. Manufacturers now have until July 1, 2026, rather than January 1, 2026, to submit required reports. The extension is intended to give companies additional time to establish supplier reporting arrangements and become familiar with the state’s reporting platform.
By January 1, 2032, the sale of any product containing intentionally added PFAS will be prohibited unless deemed a currently unavoidable use by the commissioner. Products listed in the initial ban cannot qualify for this exemption. The commissioner may identify specific product categories where PFAS use is unavoidable under current technology and alternatives.
Maine: PFAS in Products Law
Maine’s PFAS in Products law establishes a phased approach to restricting intentionally added PFAS in consumer products. Recent legislative updates removed the broad reporting requirement that was originally scheduled for January 1, 2025, and replaced it with targeted sales prohibitions for specific product categories. These prohibitions will phase in and culminate in a statewide ban on intentionally added PFAS in any product sold in Maine beginning January 1, 2032, unless the use is approved as a currently unavoidable use (CUU).
Implementation of Maine’s PFAS in Products law requires additional clarification to support consistent compliance across regulated product categories. Key timelines and milestones include the following:
- January 1, 2026: Sales prohibitions take effect for several product categories, including cookware, fluorinated containers, and most textile articles, with limited exceptions.
- January 1, 2031: The two approved, time-limited CUU determinations are set to expire.
As enforcement dates approach, manufacturers should closely evaluate product applicability, monitor CUU developments, and prepare documentation to demonstrate compliance with Maine’s evolving PFAS requirements.
Colorado: Perfluoroalkyl and Polyfluoroalkyl Chemicals Consumer Protection Act
The Perfluoroalkyl and Polyfluoroalkyl Chemicals Consumer Protection Act bans the sale and distribution of products containing intentionally added PFAS chemicals. The ban will roll out in phases. The important deadlines to know for 2026 compliance include:
- January 1, 2027: Ban on outdoor textile furnishings and outdoor upholstered furniture.
- January 1, 2028: Ban on all outdoor apparel for severe wet conditions and textile articles primarily used in households and businesses, including accessories, apparel, backpacks, and handbags containing intentionally added PFAS.
The regulation has already phased out PFAS across a wide range of consumer products. As of January 1, 2024, PFAS were prohibited in carpets and rugs, fabric treatments, food packaging, juvenile products, and oil and gas products. Cookware containing PFAS is allowed only with mandatory disclosure labeling and without “PFAS-free” claims unless no PFAS were intentionally added. The restrictions expanded further on January 1, 2025, when PFAS were banned in cosmetics, indoor textile furnishings, and indoor upholstered furniture.
Products without PFAS are designated as "environmentally preferable" for state procurement, promoting safer, sustainable alternatives.
EU PFAS regulations
The European Union is advancing PFAS regulation through both targeted, sector-specific restrictions and a proposed broad restriction under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) framework. Together, these efforts signal a clear direction toward reducing PFAS use across the EU market, with 2026 serving as a critical year for consultation, planning, and compliance preparation.
Updated proposal to restrict the use of PFAS under EU REACH
The European Chemicals Agency (ECHA) has released an updated proposal to restrict the use of PFAS under the EU’s REACH regulation, setting the stage for key developments in 2026. Following the completion of its review of more than 5,600 consultation comments in August 2025, ECHA published an updated Background Document that now forms the basis for ongoing scientific.
In 2026, attention is shifting to the next procedural step. ECHA is preparing for a second public consultation expected by March 2026, designed to collect targeted input using a streamlined, survey-based format. The consultation will run for 60 days, focus on the original 14 use sectors, and limit supporting materials to ensure consistent evaluation. Guidance released in late 2025 and early 2026 is intended to help companies prepare and participate effectively.
Input from this consultation will directly inform the opinions of ECHA’s Risk Assessment and Socio-Economic Analysis committees and ultimately support the European Commission’s decision on the final structure and scope of the PFAS restriction.
Expanded scope
The revised proposal identifies eight additional sectors not explicitly included in the initial submission:
- Sealing applications
- Printing applications
- Technical textiles
- Wider industrial uses (e.g., solvents and catalysts)
- Machinery applications
- Other medical uses (e.g., pharmaceutical packaging and excipients)
- Military applications
- Explosives
These sectors are expected to be addressed in later regulatory stages, making early supply chain visibility critical.
Alternative restriction options
Beyond a full ban or temporary exemptions, authorities are evaluating options that would allow PFAS-related activities to continue where risks can be adequately managed. These include:
- PFAS manufacturing
- Electronics and semiconductors
- Energy sector uses
- Sealing applications
- Transport
- Machinery applications
- Technical textiles
Next steps
ECHA’s Committee for Risk Assessment (RAC) and Committee for Socio-Economic Analysis (SEAC) are reviewing the proposal. Their opinions will inform the European Commission, which—together with EU Member States—will make the final decision on PFAS restrictions.
PFAS Restrictions in Firefighting Foams
The EU has adopted binding measures to phase out PFAS in firefighting foams across Europe. Under amendments to Annex XVII of EU REACH, firefighting foams containing more than 1 mg/L of PFAS will be prohibited for sale and use in the EU by October 23, 2030.
The regulation establishes a transitional period with phased compliance obligations, including requirements to prevent releases, manage PFAS-containing waste, and implement PFAS management plans for most firefighting foam users. Earlier phase-outs apply to certain uses, such as training and testing, while limited derogations remain available for critical applications, including offshore installations and defense-related uses, under strict conditions extending into the 2030s.
This amendment confirms a Europe-wide commitment to eliminating PFAS in firefighting applications and provides companies with a defined timeline for substitution and operational planning.
PFHxA and PFOA restrictions under EU REACH and the EU POPs Regulation
The EU's regulations to limit PFHxA applications in firefighting foams were effective as of October 10, 2024. However, there are additional deadlines companies should be aware of in the process of restricting PFHxA and PFOA in firefighting foams. Additional restriction deadlines include:
- April 10, 2026: Ban on firefighting foams for training, testing, and public fire rescue services (excluding COMAH industrial chemical sites) containing PFHxA over 25 ppb.
- October 10, 2029: Ban on firefighting foams for civil aviation containing PFHxA over 25 ppb.
Portable and fixed systems remain outside this regulation, as they are addressed by a separate restriction yet to be published by ECHA.
EU REACH restriction on PFAS in firefighting foams
The EU has adopted Commission Regulation (EU) 2025/1988, amending Annex XVII of EU REACH to phase out PFAS in firefighting foams. The regulation establishes new compliance obligations over a transitional period. These obligations include:
- Measures to prevent leaks and releases
- Proper collection and treatment of PFAS-containing foams and waste
- PFAS management plans for firefighting foam users, excluding portable extinguishers, and labeling for affected products and waste.
Early phase-outs for certain categories:
- Until 2026–2027, portable extinguishers may be placed on the market, depending on their specific composition.
- Until 2027, PFAS may be used for training and testing purposes.
- Until 2030, fire extinguishers that have already been sold may still be used
Key compliance dates:
- October 23, 2030: Sale and use of firefighting foams containing more than 1 mg/L PFAS are prohibited.
- Through 2035: Limited derogations remain available for critical applications such as offshore installations, military uses, and civilian ships under strict conditions.
Together, these phased requirements signal a clear shift toward eliminating PFAS in firefighting applications. Companies should begin preparing now for the associated operational, documentation, and substitution changes.
France PFAS restrictions
France has confirmed new national restrictions on PFAS-containing products that will take effect beginning January 1, 2026. The requirements were formalized through Decree No. 2025-1376 of December 28, 2025, adopted as part of France’s broader PFAS legislation passed in February 2025.
Under the decree, the manufacture, import, export, and placing on the market of products containing PFAS above regulated limits will be prohibited in France. The scope of the restrictions includes a wide range of consumer products, notably:
- Cosmetics
- Ski waxes
- Clothing and footwear
- Surface-treatment products
- Waterproofing agents
Certain uses are explicitly excluded from the France PFAS ban. These include specific personal protective equipment, defense and security applications, and some textile and footwear products that incorporate a minimum share of post-consumer recycled materials, provided they meet the conditions set out in the decree.
To allow time for transition, products manufactured before January 1, 2026 may continue to be sold or exported for a 12-month sell-through period. After this transitional window, full compliance with the PFAS restrictions will be required.
French authorities have indicated that these measures are intended to accelerate the phaseout of PFAS in consumer products. Companies placing affected products on the French market are expected to assess PFAS content, confirm applicable thresholds, and adjust supplier declarations and sourcing strategies ahead of the 2026 deadline.
Canada
Canada is advancing a phased approach to managing PFAS, with a current focus on firefighting foams. Canada’s Phase One plan aims to progressively prohibit the manufacture, import, and use of PFAS-containing firefighting foams that are not already regulated.
However, ECCC has allowed organizations to request extensions to this deadline. Upon submission of a valid request prior to the original due date, some entities were granted extensions of up to six months, effectively moving their reporting deadline to as late as July 29, 2025.
Once in force, transition periods will vary by sector. Municipal fire services and portable extinguishers are expected to have an 18-month transition period, while aviation and most industrial uses would have up to three years. Defense, offshore oil and gas, and other high-hazard industries may be granted transition periods of up to six years.
The proposal also includes disclosure and labeling requirements intended to improve transparency around PFAS content in firefighting products. Companies operating in or supplying the Canadian market should begin evaluating PFAS use and alternatives well ahead of formal enforcement.
New Zealand
New Zealand is continuing its efforts to phase out PFAS through restrictions on cosmetics. The Environmental Protection Authority has proposed a ban on PFAS ingredients in cosmetic products, with a phased implementation through the end of 2028.
Key compliance deadlines include:
- December 31, 2026: Importing or manufacturing cosmetics containing PFAS ingredients will be prohibited
- December 31, 2027: Selling cosmetic products containing PFAS ingredients will no longer be allowed
- June 30, 2028: Any remaining cosmetic products containing PFAS ingredients must be disposed of
These requirements create clear market access restrictions for companies selling cosmetics into New Zealand and require early coordination with suppliers to confirm PFAS content and reformulation timelines.
Why PFAS compliance requires a scalable approach
PFAS compliance is not a one-time reporting exercise. Requirements vary by jurisdiction, product category, and PFAS list, and they continue to evolve as regulators expand scope and tighten enforcement. For many organizations, the most significant challenge is not understanding the rules, but executing them consistently across complex supply chains.
Manual data collection and spreadsheet-based tracking struggle to keep pace with changing thresholds, overlapping obligations, and fragmented supplier responses. Without centralized, validated data, teams face increased risk of late reporting, non-compliant products entering the market, and limited defensibility during audits or customer inquiries.
As PFAS regulations expand globally, companies need scalable systems that support ongoing supplier engagement, data validation, and rapid reporting across multiple markets.
Meet PFAS Reporting Requirements with Source Intelligence
Managing PFAS compliance requires more than tracking regulatory updates. Companies must collect accurate supplier declarations, validate data against multiple PFAS lists, and maintain documentation that stands up to regulatory and customer scrutiny. Without dedicated systems and expertise, these requirements can quickly overwhelm internal teams.
Source Intelligence supports PFAS compliance by helping organizations operationalize supplier engagement, data validation, and reporting across global markets. Our approach is designed to improve response rates, reduce data gaps, and strengthen defensibility as PFAS requirements continue to evolve.
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Our PFAS coverage includes, but is not limited to:
- U.S. EPA PFAS lists
- TSCA PFAS reporting lists
- Canada’s CEPA PFAS lists
- OECD PFAS lists
- EU REACH-related PFAS lists
By centralizing PFAS-related data across chemicals, parts, and finished goods, Source Intelligence enables teams to respond more quickly to reporting deadlines, audits, and customer requests. Our combination of software, managed services, and in-house regulatory expertise helps organizations reduce risk, improve efficiency, and stay prepared as PFAS regulations expand. Discover how our PFAS solution can help you manage compliance and reduce risk with confidence.
