# PFAS Materials & Environmental ###### Per- and Polyfluoroalkyl Substances (PFAS) Restrictions & Reporting ## 10,000+ PFAS Compounds. Your Suppliers Don't Know They Have Them. The Bans Are Already Here. PFAS are hidden in coatings, treatments, and formulations across your supply chain—often without your suppliers' knowledge. No master list exists. State bans are live. Federal reporting is mandatory. Certivo automates PFAS substance identification, multi-jurisdiction tracking, and audit-ready proof. 10,000+ Known PFAS compounds globally July 31, 2027 EPA TSCA PFAS reporting deadline (most manufacturers) 99.2% Certivo AI extraction accuracy ## Regulation Overview **Jurisdiction** Global: US Federal, EU, 20+ US States **Regulatory Body** EPA (US), ECHA (EU), State Agencies (CA, MN, ME, WA, CO, NY) **Regulation Number** TSCA Section 8(a)(7); EU REACH Universal Restriction (proposed); State laws vary **Effective Date** EPA TSCA reporting: Jul 31, 2027 (most manufacturers) · Jan 31, 2028 (small manufacturers) · EU restriction opinions: 2026 · State bans: 2025–2032 **Official Source** [EPA TSCA PFAS](https://www.epa.gov/pfas) · [ECHA PFAS](https://www.echa.europa.eu/pfas) **Key Threshold** Intentional addition (most states); presence above thresholds (e.g., 100 ppm TOF); manufacturing/import since 2011 # What is PFAS? PFAS (per- and polyfluoroalkyl substances) are synthetic chemicals used for water, grease, and heat resistance. They are found in coatings, treatments, packaging, electronics, textiles, and thousands of industrial applications. There is no single master list. EPA has identified 1,462+ PFAS under TSCA. OECD uses a different definition. State laws vary. Suppliers often don't know PFAS are present in their materials or formulations. ## Key Components / Sub-Frameworks **Obligation** Report chemical identity, uses, volumes, disposal, exposures by Jul 31, 2027 (most manufacturers) · Jan 31, 2028 (small manufacturers) **TSCA Section 8(a)(7)** US Federal one-time reporting for PFAS manufactured/imported 2011–2022 **Obligation** Prepare for broad PFAS ban with limited derogations (effective 2027+) **EU REACH Universal Restriction** Proposed ban on manufacture, use, and sale of nearly all PFAS in EU/EEA **Obligation** Remove intentionally added PFAS from regulated products by state deadline **State Product Bans** US state-level bans on PFAS in specific product categories (20+ states) **Obligation** Compliance required by December 2026 **EU POPs Regulation** Global ban on long-chain PFCAs (C9-21) under EU law **Obligation** Notify state agencies per jurisdiction requirements **State Notification Requirements** State agency reporting of PFAS-containing products sold **Obligation** Compliance required by October 2026 **PFAS in Firefighting Foam** EU restriction on PFAS in firefighting foam under REACH ## PFAS Bans Are Live. Federal TSCA Reporting Window Opens April 2026. 20+ US states have enacted PFAS product bans—many effective now. EPA TSCA reporting requires historical data back to 2011, with submissions due by July 31, 2027 for most manufacturers and January 31, 2028 for small manufacturers. Companies without substance-level supply chain data face enforcement risk, market exclusion, and product recalls. ## Key Compliance Requirements # Who Must Comply - Manufacturers of PFAS or PFAS-containing products (US and EU) - Importers of articles containing PFAS (even trace amounts under TSCA) - Brand owners selling into states with PFAS bans - Companies placing PFAS-containing products on EU market - Distributors and retailers selling PFAS-containing products in regulated states - Contract manufacturers producing PFAS-containing articles for brand owners # Key Thresholds #### Intentional addition Any amount of PFAS intentionally added (most state laws) #### 100 ppm TOF Total organic fluorine threshold in some state regulations #### No de minimis TSCA reporting applies to any presence in imported articles #### January 1, 2011 TSCA lookback start date for historical manufacturing/import ## Core Obligations 1. `TSCA Section 8(a)(7) Reporting` `Report all PFAS manufactured/imported 2011–2022: chemical identity, uses, volumes, disposal, exposures` `DEADLINE` `Jul 31, 2027 (most manufacturers) · Jan 31, 2028 (small manufacturers)` 2. `State Product Bans` `Remove intentionally added PFAS from regulated product categories` `DEADLINE` `Varies: 2025–2032 by state and product` 3. `State Notification/Reporting` `Notify state agencies of PFAS-containing products sold` `DEADLINE` `Varies (e.g., Maine: Jan 2026 for CUU requests)` 4. `EU Universal Restriction` `Prepare for broad PFAS ban with limited derogations` `DEADLINE` `Opinions 2026 · Effective date TBD (likely 2027+)` 5. `Supply Chain Documentation` `Maintain traceable PFAS substance evidence across all tiers` `DEADLINE` `Ongoing` ## PFAS-Specific Pain Points ###### Suppliers Don't Know PFAS Are Present Your Tier 1 supplier says "no PFAS." But their coating vendor uses fluoropolymers. Their packaging supplier uses grease-proofing treatments. Without CAS-level substance data from every tier, you can't prove compliance—and neither can they. ###### No Single Source of Truth EPA lists 1,462 PFAS. OECD defines PFAS differently. State laws use varying definitions. There is no master list to check against. Your compliance team is left cross-referencing regulatory databases manually while definitions continue to shift. ###### State-by-State Chaos Maine bans PFAS in packaging by May 2026. Minnesota restricts 11 product categories now. California targets cosmetics and apparel. Colorado, Washington, New York, Illinois—each has different scopes, thresholds, and timelines. A single product may require 15+ compliance checks. ###### 12-Year TSCA Lookback EPA requires reporting on PFAS manufactured or imported since 2011. Most companies don't have structured records from 2011. Supplier contacts have changed. Product lines have evolved. The data collection burden is enormous—and the deadline is fixed: July 31, 2027 for most manufacturers, and January 31, 2028 for small manufacturers. ## Certivo In Action ## PFAS Workflow **GET EVIDENCE IN** Collect PFAS Declarations from Every Supplier—Without the Chasing CORA launches targeted campaigns to collect PFAS substance data—including from suppliers who don't know what PFAS they have. - Launch PFAS-specific campaigns to thousands of suppliers in one click - Collect material declarations, SDSs, and formulation data in any format - Auto-crawl supplier websites for existing PFAS declarations - Free supplier portal accepts PDFs, Excel, XML, even scanned documents **MAKE SENSE OF IT** Know Instantly Which Products Contain PFAS Substances CORA-driven compliance intelligence reads supplier documents—even complex formulations—and extracts PFAS data at substance level for validation. - 99.2% extraction accuracy on CAS numbers, concentrations, and uses - Automatic validation against TSCA, REACH, and state-specific PFAS lists - Flags intentional vs. non-intentional PFAS presence - Continuous monitoring: re-validates your portfolio as regulations change ⚠️ **PROVE COMPLIANCE OUT** Respond to Customer Requests in Hours, Not Weeks Generate audit-ready PFAS documentation instantly from validated supplier data. - One-click PFAS audit packs with full substance traceability - Customer-specific response formats for OEM and retailer requirements - TSCA Section 8(a)(7) reporting data package generation - Defensible records with complete audit trail ## One Platform for 10,000+ PFAS Compounds, 20+ State Laws, and Global Bans. Certivo doesn't just track PFAS lists—it identifies PFAS in supplier documents, validates against every applicable regulation simultaneously, and generates the proof you need. As new state bans take effect and EU restrictions advance, your compliance status updates automatically. - CAS-Level Extraction - Multi-Jurisdiction Validation - State Ban Tracking - TSCA Reporting Support - Continuous Monitoring ## Features Tabs **Declaration Collection** Certivo's automated campaigns achieve 95% response rates vs. 20-30% with manual outreach. - CORA-powered multilingual outreach campaigns - Free supplier portal (no supplier login barriers) - Accepts any document format: SDS, declarations, formulation sheets - Intelligent follow-up sequences until suppliers respond 95% Supplier Response Rate **Substance Extraction** Every declaration parsed to CAS number level automatically—no manual data entry. - CORA-enabled analysis reads PDFs, Excel, XML, images, even handwritten scans - Extracts CAS numbers, concentrations, and use categories - Maps substances to EPA structural definition and state-specific lists - Flags discrepancies and missing data for human review 99.2% Extraction Accuracy **PFAS Monitoring** Always validated against current PFAS definitions and state requirements—not your last audit. - Built-in rule engine for TSCA, REACH, POPs, and 20+ state PFAS laws - Automatic threshold checking (ppm, %, intentional addition) - Real-time re-validation as regulations update - Jurisdiction-specific compliance status per product **Regulatory Intelligence** Know when new PFAS bans pass before they affect your products. - Tracks EU restriction progress, state legislation, and enforcement actions - Alerts when new regulations affect your product portfolio - Pre-publication signals for upcoming PFAS requirements - Regulatory calendar with deadline tracking **Customer Response** Generate PFAS evidence packages in hours instead of 4-6 weeks. - One-click generation of customer-specific PFAS response packages - TSCA 8(a)(7) data compilation support - Full audit trail for every validation decision - Export in any format: PDF, Excel, XML, customer templates ## Related Regulations **REACH (SVHC)** Several PFAS are on the SVHC Candidate List; EU PFAS restriction builds on REACH **Combined Value** Single supplier declaration validates PFAS + SVHC status simultaneously **TSCA** PFAS reporting is TSCA Section 8(a)(7); broader TSCA compliance overlaps **Combined Value** Unified TSCA data collection across PFAS and other chemical requirements **California Prop 65** PFOA, PFOS, and PFHxS are listed under Prop 65 **Combined Value** One submission checks PFAS bans + Prop 65 warning requirements **SCIP Database** PFAS that are SVHCs require SCIP notification for articles in EU **Combined Value** Certivo generates SCIP-ready data from the same supplier evidence **EU RoHS** Some fluorinated flame retardants overlap with RoHS scope **Combined Value** Materials compliance workflows consolidated across RoHS and PFAS **EU Battery Regulation** PFAS in battery components may face restrictions **Combined Value** Future-proofed compliance as battery-specific PFAS rules emerge ## Managing PFAS alongside related materials regulations eliminates duplicate supplier requests. Certivo validates one submission against multiple frameworks automatically. ## Industries Most Impacted **Consumer Goods** Your Pain Point Cookware, textiles, cosmetics, packaging face live state bans **Automotive Manufacturing** Your Pain Point PFAS in coatings, seals, and lubricants; long product lifecycles **Electronics Manufacturing** Your Pain Point PFAS in solder masks, conformal coatings, and etching chemicals **Industrial & Heavy Equipment** Your Pain Point PFAS in seals, gaskets, and high-performance coatings **Medical Devices & Equipment** Your Pain Point PFAS in tubing, coatings, and sterile packaging **Aerospace & Defense** Your Pain Point PFAS in lubricants, coatings, and firefighting foam **Packaging** Your Pain Point PFAS in grease-proof treatments; 20+ state food packaging bans **Textiles & Apparel** Your Pain Point PFAS in water-resistant treatments; NY, CA, MN bans in effect ## Return on Investment ##### 80% ###### Reduction in Compliance Labor CORA-powered regulatory intelligence reads supplier documents and extracts PFAS substances to CAS number level—eliminating manual data entry and reducing errors. ##### 4 hours ###### To Customer Response Generate complete PFAS compliance documentation for customers or regulators in hours, not the weeks required for manual compilation. ##### Real-Time ###### Regulatory Sync Identify PFAS in products before bans take effect—avoiding market exclusion, recalls, and enforcement penalties. ## Key Statistics 10,000+ PFAS compounds tracked 95% Supplier response rate 20+ US state PFAS laws monitored ## Frequently Asked Questions **How does Certivo identify PFAS in supplier documents when suppliers don't know they have them?** CORA-driven compliance intelligence parses material declarations down to individual substance level, extracting CAS numbers, chemical names, and trade names. CORA then cross-references against comprehensive PFAS databases including the EPA structural definition, OECD definition, and state-specific lists. When a supplier declaration lists "PTFE," "fluoropolymer," or a specific CAS number that matches PFAS criteria, the system flags it automatically—even if the supplier didn't recognize it as PFAS. **What's the difference between EPA TSCA reporting and state PFAS bans?** EPA TSCA Section 8(a)(7) is a one-time reporting requirement for anyone who manufactured or imported PFAS (or PFAS-containing articles) between 2011-2022. Most manufacturers must submit reports by July 31, 2027, and small manufacturers reporting exclusively as article importers have until January 31, 2028. State bans are ongoing sales prohibitions—Minnesota, Maine, California, and others ban specific PFAS-containing products from being sold in their states, with different product categories and effective dates. You need to comply with both: report your historical PFAS activity to EPA and ensure your current products meet state requirements. **Does Certivo cover the EU PFAS restriction that's being proposed?** Yes. ECHA's proposed universal PFAS restriction under REACH is tracked in Certivo's framework library. When the restriction is finalized (expected 2027+), Certivo will validate supplier declarations against the specific requirements, derogations, and phase-in timelines. In the meantime, Certivo tracks existing EU PFAS restrictions (PFOA, PFOS, PFHxS under REACH and POPs) and helps you prepare for the broader restriction by identifying PFAS across your supply chain now. **How do I prove to customers that my products are "PFAS-free"?** Certivo generates certificates of conformance at product, part, or lot level based on validated supplier evidence. Each certificate includes traceability to source declarations, showing which suppliers provided data, what testing or statements support the PFAS-free claim, and how the data was validated. For customers requiring specific formats (like Minnesota's certification requirements), Certivo produces packages that meet their exact specifications. **What if my supplier says they don't have PFAS but I'm not sure?** This is extremely common—most suppliers haven't investigated PFAS specifically. Certivo's approach: (1) CORA sends targeted questionnaires that explain exactly what PFAS means and why you need to know, (2) CORA-enabled analysis parses any existing material declarations the supplier has to identify potential PFAS substances, (3) the system flags discrepancies when a supplier claims "no PFAS" but their documentation lists fluorinated compounds. You can then follow up with specific questions rather than accepting blanket denials. ## Ready to Automate PFAS Compliance? See how Certivo's PFAS compliance software transforms substance tracking from reactive firefighting to proactive confidence. Book a Demo Talk to an Expert ##### Every account includes a dedicated compliance expert alongside CORA.