PFAS Compliance in 2025: A Guide to the Global Regulatory Landscape
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Governments worldwide are tightening PFAS regulations to address environmental and health concerns. Staying up-to-date on deadlines while monitoring new requirements is crucial for maintaining compliance and preventing supply chain disruptions. As of early 2025, here are the key deadlines to know:
U.S. PFAS Regulations and Compliance Deadlines
Federal Regulations
- Significant New Use Rule (SNUR) (Early 2024): Companies must notify the EPA before manufacturing or processing 329 inactive PFAS, triggering a risk assessment.
- TRI Reporting (March 21, 2025): PFAS will be listed under the Toxics Release Inventory (TRI), requiring supplier notification upon first shipment. The exemption for small PFAS concentrations has been removed, and nine PFAS have been added, bringing the total to 205. Reporting will be due by July 1, 2026.
- TSCA Section 8(a)(7) Reporting (September 5, 2024 – January 11, 2026): Manufacturers and importers must report PFAS use dating back to 2011 (covering production volumes, uses, worker exposure, disposal). Reporting will start July 11, 2025, with final submission due January 11, 2026 (small manufacturers have until July 11, 2026). Additional data is due May 8, 2025.
- Reformed Chemical Review Process (Late 2024): The EPA has eliminated exemptions for low-volume PFAS and PBT chemicals, requiring detailed risk assessments before approval.
State Regulations
- Minnesota (January 1, 2025 – 2032): As of January 1, 2025, PFAS is banned in several products, including carpets, rugs, cleaning products, cookware, cosmetics, and menstruation products. By 2032, all PFAS-containing products will be banned unless deemed essential.
- Colorado:
- 2024: PFAS is banned in carpets, rugs, fabric treatments, food packaging, juvenile products, and oil/gas products. Cookware with PFAS must be labeled.
- 2025: PFAS will be banned in cosmetics, indoor textiles, and upholstered furniture.
- 2027–2028: PFAS will be banned in outdoor textiles and all outdoor apparel.
- California (January 1, 2025): PFAS is banned in textiles (including apparel, draperies, bedding, and backpacks). Manufacturers must use safer alternatives and certify compliance.
Global PFAS Regulations and Deadlines
European Union
- PFAS Restriction Proposal (2025): The European Commission is reviewing restrictions on more than 10,000 PFAS, with a decision expected in 2025.
- Firefighting Foam Restrictions:
- 2026: PFAS will be banned in PFHxA foams for training, testing, and public fire rescue.
- 2029: PFAS will be banned in PFHxA foams in civil aviation.
- PFOA-Containing Foams (2025): PFOA-containing foam exemptions expire in 2025, though an extension to December 2025 is under review.
Canada
- 2024 Reporting Requirement: Canada mandated reporting on 2023 PFAS use under CEPA, with filings due by January 29, 2025.
- Firefighting Foam Restrictions: A phased approach to restricting unregulated PFAS in firefighting foams began in 2013; additional phases will add most PFAS to CEPA’s List of Toxic Substances.
New Zealand
- 2026: PFAS will be banned in manufacturing and importing cosmetics.
- 2027: PFAS will be banned in selling cosmetics.
- 2028: Deadline for disposal of remaining PFAS-containing products.
Japan
- 2024–2025: Japan is banning PFHxS, PFOA, and related PFAS compounds under the Chemical Substances Control Law (CSCL).
Leveraging PFAS Compliance for Supply Chain Sustainability
Tightening PFAS regulations pose significant risks—such as supply chain disruptions and potential lawsuits—but also offer opportunities to enhance sustainability and build trust. To stay ahead, supply chain managers and manufacturers should:
- Assess Exposure: Identify PFAS in materials, map out risks, and create a clear compliance roadmap.
- Collaborate with Suppliers: Build transparent partnerships to gather accurate data and quickly find alternatives.
- Design for Compliance: Factor PFAS rules into product design, choosing safer materials early to prevent costly setbacks.
- Stay Informed: Regulations vary worldwide and evolve rapidly; monitor changes in all relevant markets.
- Centralize Documentation: Maintain updated supplier declarations and material data to streamline reporting.
Proactive collaboration among suppliers, engineers, and compliance teams helps businesses navigate PFAS restrictions while fostering a stronger, more sustainable supply chain.
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