Restricting the use of PFAS (poly- or per-fluoroalkyl substances) is recognized as a global priority due to their toxicity to humans, animals, and the environment. As a result, various laws and regulations have recently been implemented or proposed to restrict PFAS use and reduce exposure. In the United States (U.S.), the European Union (EU), and globally, there are several PFAS regulations that companies must be prepared for to remain compliant in 2025 and beyond.
PFAS: forever chemicals
PFAS 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 are prone to accumulate in people, animals, and the environment over time, including in food, drinking water, soil, and the air. Because of this trait, PFAS substances are often referred to as “forever chemicals.”
Unfortunately, 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 products continues to come under scrutiny, resulting in more restrictions worldwide each year. Here’s what to expect from the global PFAS regulatory landscape in 2025:
U.S. EPA PFAS regulations
The U.S. Environmental Protection Agency (EPA) has taken key actions at the federal level to address PFAS contamination. In 2025, companies must be aware of a few new PFAS reporting requirements.
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 goes into 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)]
PFAS Reporting under TSCA Section 8(a)(7)
The EPA finalized Section 8(a)(7) of the Toxic Substances Control Act (TSCA) on September 5, 2024, which means manufacturers and importers must be prepared to report on their use of PFAS since 2011 beginning in 2025. PFAS included on the CompTox list, Public List of TSCA PFAS, and CDX 8(a)(7) SRS list are subject to the rule.
Manufacturers must gather and report all known or reasonably ascertainable information about PFAS they have produced or imported, including:
- Chemical identity
- Production volumes
- Industrial and consumer products
- Worker exposure and hazards
- Disposal methods
The electronic reporting portal will open on July 11, 2025.
The EPA has extended the deadlines for two major compliance reporting rules, granting businesses additional time to submit the required data as the agency completes its PFAS data collection software. The final reporting deadline is January 11, 2026, for most businesses. Small manufacturers, as defined by the regulation, reporting solely on PFAS imported within articles will have until July 11, 2026. Additionally, the EPA mandates that manufacturers and importers submit detailed data on PFAS—including production volumes, chemical uses, disposal practices, and exposure pathways—by May 8, 2025.
The EPA’s Reformed New Chemicals Review Process
In late 2024, the U.S. EPA strengthened its new chemicals review process under TSCA to better address the risks posed by PFAS and persistent, bioaccumulative, and toxic (PBT) chemicals. The reformed process eliminates exemptions for low-volume and low-exposure PFAS and PBT chemicals and requires more detailed assessments of chemical risks, including evaluations of human exposure potential and environmental persistence. These changes ensure that new PFAS and PBT chemicals cannot be produced or marketed without thorough safety reviews. Historically, the EPA was allowed to grant safety review exemptions for the manufacturing of chemicals with low production quantities or exposures. These exemptions allowed some PFAS chemicals to undergo a shorter review and, thus, obtain approval for manufacture.
U.S. State-level PFAS Regulations
On December 4, 2024, the U.S. EPA finalized amendments to the New Chemicals Regulations under TSCA. Published on December 18, 2024, these updates will take effect on January 17, 2025, enhancing oversight of new chemical substances. At the state level, many states—California, Colorado, Connecticut, Hawaii, Maine, Maryland, Minnesota, New York, Vermont, and Washington—have implemented bans or restrictions on PFAS in various consumer and industrial products. Let’s take a look at the regulations in Minnesota, Colorado, and California as examples.
Minnesota: Amara’s Law (Sec. 116.943 MN Statutes)
Starting January 1, 2025, products containing intentionally added PFAS will face strict sales restrictions in the state. The ban applies to the following product categories:
- Carpets or rugs
- Cleaning products
- Cookware
- Cosmetics
- Dental floss
- Fabric treatments
- Juvenile products
- Menstruation products
- Textile furnishings
- Ski wax
- Upholstered furniture
The commissioner may expand the list of restricted products through additional rules. Any new prohibitions will have effective dates between January 1, 2025, and January 1, 2032, prioritizing categories that pose the greatest risk to the environment and natural resources.
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.
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 in phases:
- January 1, 2024: Prohibits PFAS in carpets, rugs, fabric treatments, food packaging, juvenile products, and oil and gas products. Cookware with PFAS must be labeled, listing the presence of PFAS chemicals with no "PFAS-free" claims unless no PFAS are intentionally added.
- January 1, 2025: Extends the ban to cosmetics, indoor textile furnishings, and indoor upholstered furniture.
- January 1, 2027: Includes outdoor textile furnishings and outdoor upholstered furniture.
Beginning January 1, 2025, Colorado will prohibit the sale, offer for sale, distribution for sale, or distribution for use in the state of outdoor apparel for severe wet conditions containing intentionally added PFAS unless the product contains a PFAS disclosure label is attached. From January 1, 2028, 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 will be banned.
Products without PFAS are designated as "environmentally preferable" for state procurement, promoting safer, sustainable alternatives.
California’s AB-1817 PFAS Bill
Starting January 1, 2025, California's AB-1817 will prohibit the manufacture, distribution, sale, or offering for sale of any new textile articles containing regulated PFAS, with limited exceptions. “Textile articles” can refer to any textile goods customarily used in households and businesses (i.e., apparel, draperies, furnishings, bedding, backpacks, etc.). Manufacturers must remove regulated PFAS using the least toxic alternatives available to comply with this law.
Additionally, manufacturers are required to provide a certificate of compliance to sellers and distributors, certifying that their textile articles meet these standards and do not contain regulated PFAS. This legislation builds on existing provisions of AB-1817, which already ban the sale or distribution of food packaging and juvenile products containing regulated PFAS. California textile manufacturers must take immediate steps to meet these requirements for the 2025 deadline.
EU PFAS regulations
EU Advances PFAS Restriction Proposal
The European Commission (EC) is progressing with a proposal to restrict per- and polyfluoroalkyl substances (PFAS), with a decision anticipated in 2025 following evaluations by the European Chemicals Agency’s (ECHA) scientific committees. Initially considered as an outright ban, the proposal now focuses on regulating over 10,000 PFAS substances across various sectors, aiming to balance environmental protection with industry feasibility. The assessment considers available alternatives, socio-economic impacts, and the potential for phased restrictions.
This initiative follows the January 2023 submission by authorities from Denmark, Germany, the Netherlands, Norway, and Sweden, which initiated the restriction process under the EU’s REACH regulation. ECHA’s Risk Assessment (RAC) and Socio-Economic Analysis (SEAC) Committees are currently reviewing the proposal, with their final opinions set to guide the EC’s decision-making process.
In November 2024, ECHA and the five national authorities released a progress update, highlighting that they are considering over 5,600 scientific and technical comments received during the 2023 consultation. These inputs have led to the identification of additional uses of PFAS not initially specified, such as in sealing applications, technical textiles, printing applications, and certain medical applications. Alternative restriction options, beyond a full ban or time-limited derogations, are also under consideration. Certain conditions that must be met to allow continued manufacturing, market placement, or use of PFAS, could postpone an outright ban until suitable alternatives become available.
PFAS Restrictions in Firefighting Foams
The EU has introduced new regulations to limit PFHxA applications in firefighting foams under Annex XVII of EU REACH, (EU) 2024/2462, published in the Official Journal on September 19, 2024, and effective October 10, 2024. Key restrictions 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.
PFOA, its salts, and related compounds are listed in Annex I of the EU POPs Regulation (EU) 2019/1021, with exemptions for firefighting foams set to expire on July 4, 2025. However, a proposal aims to:
- Extend the exemption to December 3, 2025.
- Introduce new concentration limits for unintentional trace contaminants.
This proposal, intended to provide companies more time to transition to fluorine-free foams and avoid hasty switches to other fluorinated alternatives, completed its feedback period on December 6, 2024. The European Commission's adoption decision is still pending.
Canada
In 2024, Canada advanced PFAS regulation with updated reports and a new section 71 mandatory survey notice under the Canadian Environmental Protection Act (CEPA). Issued on July 27, the notice, titled "Notice with respect to certain per- and polyfluoroalkyl substances," requires entities that manufactured, imported, or used PFAS in 2023 to report detailed information to Environment and Climate Change Canada (ECCC) by January 29, 2025.
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.
The updated Risk Management Report proposes a phased approach beginning with restricting PFAS not currently regulated in firefighting foams. It also proposes the class of PFAS, excluding fluoropolymers, to be recommended for addition to the List of Toxic Substances in Schedule 1 of CEPA. The Report also suggests that stakeholders explore options for phasing out PFAS in their operations, collaborate with trading partners to assess alternatives, and voluntarily disclose information on products containing PFAS to consumers.
New Zealand
New Zealand is advancing its efforts to phase out PFAS, with the New Zealand EPA proposing a ban on PFAS ingredients in cosmetics. The phased approach begins at the end of 2025 when the updated rules take effect. Key deadlines include:
- December 31, 2026: Importing or manufacturing cosmetics with PFAS ingredients will be prohibited.
- December 31, 2027: Selling cosmetics containing PFAS ingredients will no longer be allowed.
- June 30, 2028: Any remaining cosmetic products with PFAS ingredients must be disposed of.
Japan
In Japan, the regulation of PFAS is governed under the Chemical Substances Control Law (CSCL), which designates certain PFAS as Class 1 Specified Chemical Substances. This designation prohibits the manufacture, import, and use of these substances, as well as the import of products containing them.
Key regulatory updates include the following designations:
- February 1, 2024: PFHxS, its isomers, and salts.
- July 10, 2024: PFOA isomers, salts, and related compounds.
- August 1, 2024: PFHxS-related compounds.
- September 10, 2024: Perfluoro alkanoic acid (branched with 8 carbon atoms (PFOA isomers)) or their salts.
- January 10, 2025: PFOA-related compounds, including perfluorooctyl iodide, 8:2 fluorotelomer alcohol, and 138 additional PFOA-related compounds.
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