Oct 12, 2026Testing Standards
PFAS Testing: Regulations, Product Scope and What Manufacturers Should Prepare
PFAS rules differ by market and keep changing. What manufacturers should know about EU and US restrictions, product scope, testing and preparation.
PFAS rules differ by market and keep changing. Some controls are substance-specific limits that already apply; some are reporting duties with deadlines that have shifted more than once; and the broadest European measure is still under scientific evaluation. This guide sets out the current position and what to prepare.
What PFAS Are and Where They Are Used
PFAS are a large family of man-made fluorinated chemicals — EPA describes them as thousands of substances — defined by regulators as organic chemicals containing at least one fully fluorinated carbon atom, the definition used in US state laws and the EU packaging regulation. The carbon-fluorine bond is one of the strongest in organic chemistry, which is why PFAS resist degradation and persist. That stability, along with water, oil and stain resistance, explains their use in textiles and apparel, food-contact packaging, non-stick cookware, cosmetics and electronics. In practice PFAS usually sit in a coating, finish, grease-proofing agent or specialty component rather than appearing as a listed ingredient.
Where PFAS Are Restricted: European Union
Three tracks matter in the EU.
POPs Regulation. Under Regulation (EU) 2019/1021, several PFAS groups are controlled as persistent organic pollutants. PFOA, its salts and related compounds carry unintentional trace contaminant limits of 0.025 mg/kg for PFOA and its salts and 1 mg/kg for related compounds in substances, mixtures and articles (Delegated Regulation (EU) 2020/784). PFOS is limited to 10 mg/kg in substances or mixtures and 0.1% by weight in articles, or 1 µg/m² for textiles and other coated materials. PFHxS was added in 2023 with the same 0.025 mg/kg and 1 mg/kg limits (Delegated Regulation (EU) 2023/1608).
REACH. C9–C14 perfluorocarboxylic acids, their salts and related substances — the group that includes PFNA — are restricted under Annex XVII, with limits of 25 ppb for the sum of C9–C14 PFCAs and their salts and 260 ppb for related substances, restricted since 25 February 2023, with 4 July 2023 applying only to specified uses (Commission Regulation (EU) 2021/1297). Separately, a proposal to restrict PFAS as a broad class remains under scientific evaluation: the European Commission stated in June 2026 that a restriction proposal will follow the European Chemicals Agency's final scientific assessment, expected by the end of 2026, and that it will consider a ban on PFAS in consumer goods, with possible continued industrial use only for critical uses under strict conditions. No class-wide restriction has been adopted yet.
Packaging. Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, restricts PFAS in food-contact packaging from 12 August 2026: 25 ppb for any individual PFAS measured by targeted analysis (polymeric PFAS excluded), 250 ppb for the sum, and 50 ppm including polymeric PFAS. A total fluorine result above 50 mg/kg triggers a duty to document the fluorine content.
Where PFAS Are Restricted: United States
TSCA Section 8(a)(7). EPA's reporting rule, finalised in October 2023, requires manufacturers and importers that manufactured or imported PFAS in any year from 2011 to 2022 to report use, production and exposure information. The submission period has moved twice; under an April 2026 final rule it begins on 31 January 2027, or 60 days after the effective date of a forthcoming final rule on the rule's substantive requirements, whichever is earlier. EPA proposed in November 2025 to narrow the scope with exemptions, including concentrations at or below 0.1%, imported articles, byproducts, impurities, R&D chemicals and non-isolated intermediates; the proposal is not final.
State laws. Several states have moved ahead. Maine bars, from 1 January 2026, the sale of products in nine categories containing intentionally added PFAS — cleaning products, cookware, cosmetics, dental floss, juvenile products, menstruation products, textile articles, ski wax and upholstered furniture — with carpets and rugs and fabric treatments banned since 2023, artificial turf and severe-wet outdoor apparel from 2029, and a general prohibition from 2032 unless a use is currently unavoidable. California prohibits new textile articles containing regulated PFAS from 1 January 2025, with total organic fluorine thresholds of 100 ppm from 2025 and 50 ppm from 2027, and a "Made with PFAS chemicals" disclosure for severe-wet outdoor apparel until its 2028 deadline. Minnesota requires reporting by 1 January 2026 and bans eleven product categories from 1 January 2025, with a general prohibition in 2032 unless a use is currently unavoidable. Dates and scope have been amended before; re-check per project.
Which Products Are Most Often Affected
The recurring categories are textiles and apparel, food-contact materials and packaging, cookware, cosmetics, juvenile products and toys, upholstered furniture and cleaning products. Electronics appear mainly through exemptions and narrow allowances — Maine exempts semiconductors and non-consumer electronics — but fluorinated substances have historically been used in electronics manufacturing, so electronic components can still raise questions. Most state laws trigger on intentionally added PFAS or a total organic fluorine threshold, so the material list determines exposure.
How PFAS Testing Works
PFAS testing generally follows two complementary approaches. Screening methods measure total or organic fluorine and answer whether fluorine is present above a detection level, without identifying individual substances. Targeted analysis measures specific PFAS compounds, typically by liquid chromatography with tandem mass spectrometry (LC-MS/MS). For textiles, the European EN 17681 series provides relevant methods: EN 17681-1:2025 covers analysis of an alkaline extract by liquid chromatography and tandem mass spectrometry, and EN 17681-2:2022 covers volatile compounds by extraction and gas chromatography. Standard editions are updated periodically, and rules pair screening and targeted results differently — the EU packaging limits, for example, are written around targeted analysis with a total fluorine trigger — so the applicable method, edition and reporting basis should be confirmed with the laboratory before sampling.
What to Prepare Before Requesting Testing
Assemble a component-level material list that flags coatings, finishes, stain-repellent treatments, inks, adhesives and sealing materials. Collect supplier declarations on intentionally added PFAS, and map each product to its destination market and relevance dates. Previous test reports or material declarations support a risk-based approach and reduce repeat testing for unchanged materials. Where screening or supplier information suggests a possible presence, targeted analysis and supplier follow-up determine the next step. Sample quantities vary by product and method; the laboratory confirms what it needs for each project.
How LCS Supports Chemical Testing
LCS is an independent third-party testing laboratory. Its chemical testing laboratory performs restricted-substances and PFAS testing in its own laboratory - PFAS projects are not subcontracted. Specific test scope, methods and reportable standards for a given product are confirmed with the laboratory when the project is planned, since PFAS requirements differ by material, market and limit value. Testing produces a test report; certificates are issued by the relevant certification body, or by the manufacturer or importer based on testing. The Chemical Testing service page describes the laboratory's chemical scope.
FAQs
Does an EU PFAS class restriction already apply?
No class-wide restriction has been adopted. Current EU controls are substance-specific entries under the POPs Regulation and REACH; the Commission has indicated a broad restriction proposal will follow once ECHA's final scientific assessment is delivered, expected by the end of 2026.
Is a total fluorine result enough for compliance?
Screening indicates whether fluorine is present; targeted analysis identifies which substances. Some rules act on total fluorine values, while others set limits on specific compounds.
Do supplier "PFAS-free" declarations remove the need for testing?
Not automatically. Declarations are useful evidence, but several regimes place duties on the manufacturer and set thresholds measured by analysis. Risk-based verification, with testing where warranted, is the more robust route.