PFAS Disclosure Programs

What it is: Per- and polyfluoroalkyl substances (PFAS), often called "forever chemicals" due to their environmental persistence, are a family of thousands of synthetic chemicals now subject to an expanding web of disclosure and reporting obligations at both the international, federal, and state level. PFAS are regulated in the U.S. primarily through TSCA, though requests increasingly arrive as standalone supply chain inquiries separate from any specific regulation.

Why you're receiving this request: The most common thing landing in supplier portals right now is a straightforward product-level question: does this product contain PFAS, and if so, which ones? Customers are building PFAS inventories across their supplier base, often well ahead of any specific regulatory deadline, and they need a yes or no answer against a defined substance list. PFAS appear in many places manufacturers don't expect: industrial coatings, lubricants, hydraulic fluids, gaskets, seals, and non-stick surfaces are common sources and equipment or machinery may require PFAS-treated components. Even if you're not adding PFAS yourself, your suppliers may be.

On the regulatory side, EPA's TSCA rule requires any company that manufactured or imported PFAS, or imported articles containing PFAS, in any year between 2011 and 2022 to submit a one-time report to EPA. Submissions are currently due by October 13, 2026 for most manufacturers. State-level obligations are layering on top: Minnesota's PFAS reporting requirement took effect in 2026 with more states following. If you haven't audited your products and processes for PFAS presence, requests will only increase.

Official resource: EPA TSCA PFAS Reporting and General Info