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. France-specific restrictions further underscore the need for companies selling into the European Union to monitor PFAS developments and prepare for upcoming deadlines.
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:
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.
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.
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 8(a)(7) CT 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:
The start of the official PFAS reporting window has been delayed from April 13, 2026, to 60 days following the effective date of the agency’s forthcoming revision to the PFAS 8(a)(7) rule.
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:
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.
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.
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.
The new additions to TRI this year include:
This adds PFHxS-Na to the TRI list with an effective date of January 1, 2026, bringing the total number of PFAS subject to TRI reporting to 206. Reporting forms are due by July 1, 2027.
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:
- Maine has finalized decisions on currently unavoidable use (CUU) 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. Proposals received before May 1, 2026, may be included in the 2026 rulemaking for CUU determinations. Proposals received after May 1, may be considered for a subsequent rulemaking, anticipated to be scheduled in 2027.
- Connecticut General Statutes section 22a-903c restricts the sale of certain consumer products containing PFAS. As of January 1, 2026, new outdoor apparel for severe wet conditions containing PFAS may only be sold if the product and any online listing carry a legible disclosure stating, "Made with PFAS chemicals," and sellers of turnout gear with intentionally added PFAS must give buyers written notice at the time of sale explaining why the PFAS was added. Beginning July 1, 2026, manufacturers must label covered products containing intentionally added PFAS, including apparel, carpets and rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, and upholstered furniture, and must notify Connecticut's Department of Energy and Environmental Protection (DEEP) before sale using the official reporting form on DEEP's PFAS in Products webpage.
Let’s take a closer look at a few state-specific examples.
New Mexico's PFAS Protection Act prohibits products containing intentionally added PFAS and establishes reporting and labeling requirements for products sold, offered for sale, or distributed in the state. Implementing regulations at 20.13.2 NMAC formalize these requirements, with phased product bans rolling out between 2027 and 2032.
The New Mexico Environment Department (NMED) has published guidance and FAQs to help manufacturers meet the law's reporting and labeling requirements. The Labeling Guidance covers label content and placement, available exemptions, and the process for requesting a label waiver, including approval to use a PFAS label already developed for another state where it satisfies New Mexico's requirements.
NMED has also launched the New Mexico PFAS Reporting System (NMPRS) to support compliance. Account registration opened in July 2026, and the state is rolling out additional functions, including manufacturer reports, Currently Unavoidable Use (CUU) proposals, reporting extensions, and label waiver requests, on a phased basis.
Manufacturer reports for products containing intentionally added PFAS are due by January 1, 2027, unless an exemption applies, with updates required within 30 days of any significant changes. Products subject to the labeling requirements must display the required PFAS label starting on that same date.
Minnesota has extended the initial reporting deadline for Amara’s Law, which bans intentionally added PFAS in certain products. Manufacturers now have until September 15, 2026, rather than July 1, 2026, to submit required reports. The extension follows feedback from companies facing challenges collecting PFAS data and using the state’s reporting system, PRISM. Manufacturers granted a 90-day extension must submit their reports by 14 December 2026.
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’s PFAS in Products law establishes a phased approach to restricting intentionally added PFAS in consumer products. Legislative updates removed the broad reporting requirement that was originally scheduled for January 1, 2025, replaced it with targeted sales prohibitions for specific product categories and established a new reporting program for those product categories that receive a Currently Unavoidable Use (CUU) determination. These prohibitions will be phased- in based on product category and will start to take effect on Jan 1, 2026.
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:
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.
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:
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.
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.
The EU Packaging and Packaging Waste Regulation (PPWR) became generally applicable on August 12, 2026, adding a new food-contact packaging restriction to the EU's PFAS landscape. Food-contact packaging containing PFAS at or above the limits set in Article 5 of the regulation can no longer be placed on the EU market, and the European Commission has confirmed there is no transitional period for exhausting stocks produced before August 12, 2026, if that packaging has not already been placed on the market. Any non-compliant packaging that hadn't already been placed on the market must be removed from circulation immediately.
Companies supplying food-contact packaging to the EU should confirm PFAS content against the Article 5 limits now. PPWR's remaining provisions, including a harmonized labeling system in 2028 and the bulk of packaging waste requirements in 2030, will phase in as separate compliance milestones over the coming years.
The European Chemicals Agency (ECHA) reached major milestones in its scientific evaluation of the proposed EU-wide PFAS restriction under the EU’s REACH regulation in March 2026. ECHA's Risk Assessment Committee (RAC) adopted its opinion, concluding its assessment of the risks to human health and the environment and the likely effectiveness and practicality of the proposed restriction. Shortly afterwards, the Committee for Socio-Economic Analysis (SEAC) agreed its draft opinion, assessing the proposal's socio-economic impacts and the availability of alternatives.
ECHA subsequently launched a 60-day consultation on SEAC's draft opinion, which ran from March 26 to May 25, 2026. The consultation sought further evidence on issues including the availability of alternatives, transition periods, costs and impacts on competitiveness. To support the consultation, ECHA published Guidance in early 2026 to help companies prepare and participate effectively. The consultation received 3,511 comments, which SEAC is now assessing as it finalizes its conclusions.
RAC's and SEAC's opinions will be formally submitted to the European Commission, which will use them to develop a restriction proposal for discussion and vote by EU Member States in the REACH Committee. SEAC is expected to adopt its final opinion by the end of 2026.
The revised proposal identifies eight additional sectors not explicitly included in the initial submission:
These sectors are expected to be addressed by the European Commission in later decision-making stages, making early supply chain visibility critical.
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 uses in the following sectors:
The EU regulation is driving a fundamental transition away from PFAS-based firefighting foams, combining targeted bans on substances (such as PFHxA) with a broad REACH restriction that will phase out most remaining uses over the coming years.
The EU's regulations to limit PFHxA applications in firefighting foams were effective as of October 10, 2024 under EU REACH. However, there are additional deadlines companies should be aware of in the process of restricting PFHxA, its salts and PFHxA-related substances in firefighting foams. Additional restriction deadlines include:
Portable and fixed systems remain outside this regulation, as they are addressed by the separate broad restriction published under EU REACH.
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:
Early phase-outs for certain categories:
Key compliance dates:
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 has confirmed new national restrictions on PFAS-containing products that took 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:
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 is advancing a phased approach to managing PFAS, with a current focus on firefighting foams. Canada’s Phase 1 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.
Canada's Prohibition of Certain Toxic Substances Regulations, 2025 entered into force on June 30, 2026, replacing the 2012 regulations and strengthening existing controls on PFOA, PFOS, long-chain perfluorocarboxylic acids (LC-PFCAs), their salts, and precursors. Most remaining exemptions for these PFAS have now been removed or made time-limited, including further restrictions on their use in firefighting foams. The regulations prohibit specified activities involving these and other toxic substances and products containing them, subject to defined exemptions and concentration limits.
New Zealand is continuing its efforts to phase out PFAS through restrictions on cosmetics. The Environmental Protection Authority’s updated rules came into effect on January 1, 2026 and include a ban on PFAS ingredients in cosmetic products, with a phased implementation.
Key compliance deadlines include:
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.
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.
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.
Source Intelligence delivers one of the most comprehensive PFAS compliance solutions available, with global coverage that spans the regulatory lists most frequently referenced across major markets.
Our PFAS coverage includes, but is not limited to:
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.