Navigating PFAS Compliance in Plastics

Per- and polyfluoroalkyl substances (PFAS) are nearly indestructible manmade chemicals, also known as “forever chemicals,” because they degrade very slowly. PFAS’ slow degradation increases product durability, but can also cause the chemicals to accumulate in harmful places like the environment and even the human body. While PFAS as a category are not dangerous by default, some chemicals that fall under the PFAS category pose a risk. Legislators around the world are responding to that risk through regulation. Manufacturers of plastic products must be aware of any PFAS used in their products and stay informed on regional regulatory efforts to ensure compliance.

A Complex Chemical Family

The name PFAS encompasses a vast group of manmade chemicals known for their durability and resistance to heat, water and oil. These characteristics make PFAS invaluable in many plastics applications, but their persistence in the environment raises health and ecological concerns.

Christopher Thelen, Regulatory Supervisor at M. Holland, discusses the nuance necessary when communicating about PFAS: “There’s no such thing as a blanket statement related to PFAS chemicals. Conservatively, the number of chemicals falling under this classification is around 15,000, but some organizations’ definitions increase that number closer to seven million.”
It’s important to recognize that not every PFAS chemical is dangerous. Fluoropolymers, for example, are a type of PFAS that have been widely used for decades in aerospace applications, electronics and medical devices and are generally regarded as safe and stable. Two PFAS chemicals, perfluorooctane sulfonic acid (PFOS) and perfluorooctanoic acid (PFOA), however, have been linked to adverse effects in humans, including higher cancer rates.

“The industry has known the dangers of chemicals like PFOS and PFOA for years and they have been removed from the products we sell,” Christopher continued. “One has to be careful not to paint every substance with the same broad brush. If all PFAS chemicals are banned, the impact on industries would be severe. There are limited alternatives that offer comparable performance, and where substitutes do exist, trade-offs in weight, durability and cost may be unavoidable”

Putting Together the PFAS Regulatory Puzzle

With growing public concern and increased research on the environmental and health risks of PFAS, governments around the world are pursuing regulatory action. The PFAS regulatory landscape is evolving rapidly and inconsistently.

The U.S. passed a rule in April 2024 designating PFOS and PFOA as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), commonly referred to as the Superfund law.

Several U.S. states have enacted varying bans on PFAS use in products and packaging. These bans are not limited to the U.S. Across the pond, the European Chemicals Agency (ECHA) has proposed a broad ban on all PFAS, including those like fluropolymers that are not associated with the same level of risk as PFOA and PFOS.

The varying rules make the regulatory landscape incredibly complex, resulting in a regulatory environment that leaves many manufacturers uncertain about what is required to remain compliant and what changes may be on the horizon. According to Christopher, “PFAS legislation is more fragmented than a jigsaw puzzle. Customers are confused with so many varying regulations at the local, state, federal and international levels, it can be difficult for companies to confidently ensure they are in compliance.”

Preparing for the Compliance with PFAS Regulation

As PFAS oversight expands, plastics manufacturers must be proactive in how they manage and monitor their use of these substances. For manufacturers, this signals an urgent need to assess long-term strategies for material selection and regulatory compliance. The following best practices can prepare you for more stringent regulations, should they arise:

• Maintain close communication with regulatory experts. Stay connected with your internal compliance teams and external partners who can help interpret the evolving landscape and provide guidance specific to your materials and markets.
• Request PFAS declarations for all resins. Understanding exactly which substances are present in your materials is critical. Work with your suppliers to establish transparency about any PFAS used and stay informed of formulation changes. “At M. Holland, we maintain a library of regulatory documents for our branded prime resins, which address topics such as the presence or absence of PFAS,” Christopher noted. “Never hesitate to reach out. We’re all working to keep up with the changes in legislation. Staying engaged is key.”
• Explore PFAS alternatives: Investing in research and development now will put you in a better position in the case of a blanket PFAS ban. PFAS-free alternatives are already in use in food packaging among other applications, with many more are emerging.

For plastics manufacturers, the best path forward is one of vigilance, transparency and partnership. With the right information and resources, it is possible to remain compliant, protect your business, and continue to deliver high-performance materials that meet the needs of modern applications.

M. Holland offers regulatory expertise and ongoing support to customers. Contact your account manager with questions for our regulatory team or visit the Sustainability market page for more information on how M. Holland can help progress your sustainable manufacturing initiatives.