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Regulations around per- and polyfluoroalkyl substances (PFAS) currently resemble “a patchwork quilt,” says Daniella Landers, an attorney experienced in environmental regulation. Maine will ban these “forever chemicals” in all textile products beginning Jan. 1, 2026. Other states have varying laws. Canada and the European Union (EU) are in the process of developing rules related to PFAS use or reporting.
In the U.S., a portal for reporting the presence of PFAS in manufactured or imported items to the Environmental Protection Agency (EPA) is scheduled to open April 13, 2026, with a data submission deadline of Oct. 13, 2026 (April 13, 2027, for small manufacturers that are importers). Required under the Toxic Substances Control Act (TSCA), the reporting was originally scheduled for November 2024 then July 2025. It was delayed first due to budgetary concerns and then for testing of the reporting software.
The EPA needs infrastructure and personnel to digest this information, says Michael Sullivan, an attorney specializing in corporate defense at Womble Bond Dickinson law firm. Even though this month’s federal deadline has shifted, Landers and Sullivan say company leaders should remember that states may have reporting requirements too.
“You can’t just push a button to generate this information. You have to chase it down through your supply chain. That effort takes time,” Sullivan says.
PFAS in products, supply chain
The TSCA rule requires companies that have manufactured PFAS or imported products containing these chemical compounds to report this information to the EPA, dating back to 2011. The “importer of record” for this purpose is the person or entity responsible for paying duties on the imported goods.
As an example, Sullivan says, “If an upholstery manufacturer imports the upholstered product [containing PFAS] and sells it to a furniture manufacturer in the United States, which then puts it on a piece of wooden furniture, the upholstery manufacturer is the entity that has to do the reporting for the purpose of TSCA.” Considering the hodgepodge of state regulations, though, it’s still a good idea for product retailers like the furniture manufacturer in this example to document the history of PFAS use in their products, the lawyers say.
Companies also may need to refer to another entity’s information. A procedural rule finalized by the EPA in June 2023 allows companies to claim portions of their filings as confidential business information. “If you’ve got a special sauce, you can protect some aspects of your special sauce,” Landers says.
That’s one reason to make sure your supply chain is well-documented, says Sullivan, including using best efforts to find former suppliers. This could include maintaining written records of outreach to suppliers; tracking the response, or lack thereof, as well as follow-up efforts; or reports of internal supply chain investigations. Reasonable effort, Sullivan says, “typically is something more than a quick phone call.”
Companies might not be incorporating PFAS into their own products and processes, says Ross Ward, Ph.D., former chief commercial officer at NIRI in Leeds, England, “but one thing they are finding is that a lot of materials they’re buying from upstream areas of the supply chain actually contain PFAS.”
Among the services NIRI provides is supply chain monitoring as well as testing that can identify the presence of PFAS in products. “We could take material, and through a series of different analytical techniques, really start to understand the material composition and molecular composition and then actually understand how much [PFAS] is in there,” Ward says, as well as its intended use.
Without documented information, Landers says, testing generally is required to confirm whether a product contains PFAS. Making this a challenge is that sampling protocols for commercial labs do not cover all PFAS products. It’s estimated that more than 50%–70% of PFAS chemicals aren’t able to be tested, Landers says.
Conversations with customers
With laws in some U.S. states banning the sale of PFAS-containing products, the possibility of the EU implementing a universal PFAS ban, which could come in 2025 or 2026, and other regulations, people are feeling ambiguity and frustration, Ward says. “In terms of the regulation deadlines, there seems to be a bit of a mismatch in terms of what can be achieved.”
That shows up in customer conversations, says Steve Bassetti, director of global marketing for fibers and composites at Michelman, a 75-year-old family-owned company with corporate headquarters in Cincinnati, Ohio. He gave an example to make the point, particularly about the disconnect between customer expectations of a product and the current lack of a direct replacement for PFAS for oil repellency.
“If you’re supplying a uniform to the Department of Defense, the DOD doesn’t want to sacrifice performance with respect to water repellency, fuel repellency, etc. They want that soldier protected. The EPA or governing bodies down the hall are saying, ‘Nope, we don’t want these forever chemicals,’” Bassetti says. “And you’ve got the supply chain sitting there in the middle saying, ‘I don’t want to use PFAS anymore because I’m facing a potential litigious environment, and yet my customer, DOD, is not yet ready to acquiesce on the performance.’ These tug-of-wars are going on across many, many different industries.
“There’s this whole trade-off conversation,” he adds. “If you’ve got a ski jacket or a rain jacket and it’s been using PFAS, it might have a certain performance level associated with it. And going forward … it may not last 10 years. It might only last five years. Is the consumer willing to accept that?”
Joseph Davis, president of the material solutions group for Glen Raven Inc., based in Burlington, N.C., says his company has placed a greater emphasis on education and transparency regarding fabric performance and care when communicating with customers about its Sunbrella® outdoor fabrics. Glen Raven started offering non-PFAS solutions for its Sunbrella Contract fabrics beginning in 2019, followed by a rolling transition to non-PFAS across the entire Sunbrella fabric portfolio beginning in 2023. “Our goal is to provide clear guidance on maintenance and stain removal to help people adjust to the new formulations,” Davis says.
Oil-repellency issue
Although PFAS have been overused, Ward says, there are alternative options that can fulfill some of their functions, such as water or soil repellency. However, he adds, “If you’re looking within the oil-repellency area, you are not going to find a direct replacement for PFAS.”
That means, he says, that it’s necessary to think not just about a one-to-one replacement for a PFAS chemical compound but also to consider an entire product’s structure. This might mean changing the geometry or configuration of fibers to impact the flow of liquid distribution. “It’s about moving some of those liquids around more rapidly or spreading them out further so that they are then more effectively exposed to these PFAS alternatives,” Ward says.
Additionally, Ward says, “We can look at what other levers we can pull,” such as changing materials’ structural properties or strategically positioning them. NIRI has created a composite of woven fabric and nonwoven laminate that has oil-repellent properties comparable to a PFAS-coated fabric. The approach can be applied to nonwoven, woven or knitted textiles, Ward says. NIRI works in a broad range of textiles, including developing polymers, fibers and filaments that go into conventional textiles. Its product development arm is working to consider not only oil-repellency needs but comparable attributes to existing products in areas such as moisture management or air permeability.
Michelman is in the supply chain for retail food and food service packaging, which also faces PFAS regulations. The company has developed water-based coatings for that market that provide oil and grease resistance. Expertise from developing such solutions can serve as a springboard into the textiles market, Bassetti says.
Opportunity for innovation and new markets
In response to the changes in oil repellency with non-PFAS products, Glen Raven developed a new product, Sunbrella Extract™ Oil-Based Stain Remover.
“We are shifting towards a more tailored approach, where different applications require different solutions,” Davis says. “This could mean more specialized coatings for specific use cases or the development of alternative solutions that better address emerging performance needs.”
The change in approach to PFAS, Ward says, is not only a challenge but also an opportunity for companies to innovate and diversify into new markets.
Michelman makes water-based, PFAS- and solvent-free polymer dispersions and emulsions used to modify surfaces and substrates. It’s focusing its textile efforts on medical textiles and protective apparel. “I think what you’re going to see is a lot more individual solutions, a lot more market-specific solutions,” Bassetti says.
He notes that manufacturing processes that worked in a world of PFAS may need to change drying conditions, line speeds or more to accommodate non-PFAS alternatives. Such considerations could lead to varying solutions for PFAS replacement even within a category like medical textiles, with one solution identified for surgical masks and another for disposable gowns, Bassetti says.
By picking and choosing certain areas of focus, “Michelman can be a little bit more nimble, a little bit more intimate with our customers in these markets to create customized solutions,” he says.
Larger companies may find advantage in their size. Glen Raven notes that it made a significant investment in its global research and development team to work with accredited research laboratories and universities to evaluate and develop its non-PFAS solutions. This included extensive testing over nearly a decade to ensure solutions maintained products’ expected performance.
“One of the biggest takeaways from this transition is the importance of ongoing investment in R&D and working with top-tier partners,” Davis says. “Frequent and transparent communication with our partners has been key as we have worked together to navigate these changes.”
Overall, Bassetti says, there is an openness to cooperation or collaboration within the industry, as companies along the supply chain are eliminating PFAS from their products. Whereas in years past, it may have been more difficult to break into an established market, today, “Everybody’s willing to have the conversation,” he says.
When companies develop products in isolation, Ward says, they can often miss the bigger picture. NIRI, he says, can prototype materials, components and end products and look collectively at the system. “What you can then do is work back to the supply chain and advise them on how they can produce an end product that’s commercially, technically viable.”
“The nice thing is you’ve got a willingness, more than ever, for people to sit at the table and figure it out,” Bassetti says. “We’re just one of many companies who want a seat at that table. There’s selfish reasons—we obviously want to grow our business—but there’s societal reasons. We believe replacing forever chemicals is the right thing to do, and eliminating PFAS from our products is another way we execute our purpose of innovating a sustainable future.”
Joanna Werch Takes is a writer and editor based in Minnesota.
SIDEBAR: What to do with old stock?
One question facing the industry is what to do with existing stock that contains PFAS. States that ban the sale of PFAS, says attorney Daniella Landers, generally set an effective date that may give companies time to rid themselves of inventory. Once a ban date goes into effect, however, there is no sell-through provision.
Glen Raven says it’s working closely with its customers to facilitate a smooth transition to non-PFAS solutions through the supply chain. This involves proactive inventory management, ongoing communication and education.
Ross Ward, formerly of UK-based NIRI, says the European Union’s focus on closed-loop recyclability means that there is some early thought on whether PFAS could be extracted from a returned item. The focus, he says, would be on preventing PFAS leakage into the environment.
That leakage, says Landers, is the reason companies shouldn’t put products containing PFAS into landfills. In addition to health and environmental concerns, she says, in April 2024, the EPA designated perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, also known as Superfund). Landers says that classification makes it easier to hold parties liable for cleaning up PFAS contamination.
One potential method that has been discussed, Landers says, is disposal through high-temperature chemical breakdown or incineration. The EPA has an Interim Guidance on the Destruction and Disposal of PFAS Materials document that was published for public comment in April 2024, listing pros and cons of various options, including storage, to keep the substances out of the environment. Find a link to that guidance and more in Advanced Textiles Association’s online PFAS Resource Center at textiles.org/pfas-resource-center.