How can we replace PFAS?
PFAS = Pretty Fricking Annoying to Substitute
As I’ve said before, there’s no real way to avoid discussion of the perils of PFAS—even hiding under a rock won’t protect you, as they’ve been shown to be pretty much everywhere. PFAS (per- and polyfluoroalkyl substances, for long) refers to a whole group of chemicals that are very resistant to oil, water, and heat, making them extremely useful for a wide range of coating and barrier products. Unfortunately, PFAS are also extremely resistant to breaking down in the environment, granting them the nickname “forever chemicals”, and are also pretty bad for human and environmental health.
As consumer awareness of PFAS grows, manufacturers, brands, and retailers are finding themselves in a tough place. Consumers want PFAS-free products, especially when it comes to items that contact food or skin. But PFAS are proving to be so ubiquitous that even products that shouldn’t have PFAS, like paper straws, are turning up contaminated when tested. There’s a real reputational risk for companies that label items as “PFAS-free,” when all they can really guarantee is that they haven’t intentionally added PFAS to the product.
PFAS legislation is on the rise
Now, the US state of Minnesota has passed Amara’s Law, named in honor of Amara Strande, a 20-year-old who lobbied her state to enact tougher chemical legislation even as she was dying of a rare form of liver cancer. Despite intense opposition from over 50 chemical companies and trade associations, the law will be coming into effect in 2025, with the goal of protecting future generations from being exposed to these chemicals.
The law aims to prohibit unavoidable uses of PFAS by 2032, exempting uses defined as “essential for health, safety, or the functioning of society and for which alternatives are not reasonably available” (nice breakdown of that concept here). From next year, PFAS will be banned in new products sold in Minnesota in the categories of carpets or rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children’s products, menstruation products, textile furnishings, ski wax and upholstered furniture.
This has caught the industry a bit flat-footed, as many companies expected cookware to be exempted as a use where no good alternatives are available. However, legislators have ruled that society can function even if food sticks to pans a bit.
What does this mean for the rest of the US?
Now, Minnesota is only one state—the US has 49 others. What does this legislation mean for the rest of the country? Well, some other states are moving on PFAS, too. Safer States has put together a very neat database here showing what’s going on. Some states are banning use of PFAS in specific product categories, while others are restricting its presence in drinking water or encouraging development of alternatives.
It’s always interesting to watch how industry reacts to state legislation in the US. Some companies maintain only one supply chain for the entirety of the country, so a ban on PFAS in one state will require them to stop selling those products in every state and seek alternatives. Other companies do adjust their product portfolio for each state, so for now, consumers can just cross the border and buy their PFAS products in Wisconsin. However, PFAS restriction does appear to be on the rise, so R&D spending on PFAS alternatives is likely to rise across the country.
What about PFAS in the EU and UK?
The EU is moving a bit slower on PFAS, though legislation is on the horizon. In the 2020 Chemicals Strategy, the EU committed itself to “phasing out the use of per- and polyfluoroalkyl substances (PFAS) in the EU, unless their use is essential.”
Any ban on PFAS will be carried out under the umbrella of REACh, the main European chemical safety legislation. This creates an interesting issue, as there’s no functionality for banning groups of chemicals—it’s on a chemical-by-chemical basis. The European Chemicals Agency (ECHA) has therefore issued a dossier covering about 10,000 PFAS substances. The dossier is currently under committee review, and could result in a few different legislative approaches. The earliest restrictions are expected to come into force in 2026 or 2027. There’s also a related proposal banning PFAS in firefighting foams, on which a decision is expected in 2025.
In the UK, the picture is less clear. The government published an analysis of options in 2023 that suggests prioritising firefighting foams as the first use to substitute, and recommends considering further restrictions on the use of PFAS in textiles, furniture, and cleaning products. The UK REACH work programme for 2024 includes development of PFAS restriction proposals. The timeline for any restrictions is not yet clear.
In any case, the gears are moving, and this is a clear signal to industry that if you don’t already have good alternatives to PFAS, you should be hunting for them. Manufacturers, retailers, and brands who can offer high-functioning textiles, cookware, packaging, coating, or cosmetics without PFAS added are already at a competitive advantage, and this will only grow in future.
Approaches for replacing PFAS
Given the regulatory incentive and consumer demand, market leaders should be scrambling for ways to offer high-performing products that have no PFAS added. It’s not an easy task—chemical supply chains are pretty opaque, and it can be hard to monitor where PFAS is added. Furthermore, good alternatives are not readily available in many PFAS applications. What can a forward-thinking company do to get ahead of competitors and future-proof its products against inbound PFAS regulation?
Communicate
Communication is key. Make sure that all your internal teams are aligned on acceptability of PFAS within your products, as well as what an acceptable alternatives looks like. If the regulatory team says one thing, but the product designers say another, progress will be slow.
Clear communication with your supply chain is also vital. If you have a restricted substance list (RSL), add PFAS to it, and include a clear definition, as it is a whole group of chemicals. Make sure your teams are trained on how to ask vendors about alternatives. Don’t stop at basic questions (“Does it have PFAS?”); follow up for more details (“Do you have a test report? What are you using instead?”).
If you’re developing PFAS alternatives, talk to your customers! Make sure you understand what ideal vs. acceptable performance looks like, and be clear with them about what the technical challenges are and how you’re addressing them.
Finally, consumer education will be an important piece of the puzzle. It will be a challenge to explain why “no PFAS added” is a desirable label, what progress you’re making towards it, and any performance differences in updated products and how they can be overcome. In the green chemical industry, transparency is critical to gain and maintain consumer trust, so don’t be afraid to say “we know it’s a problem, we’re working on it, and here’s how.”
Collaborate
In some applications, such as cookware and electronics, there will be a lot of R&D needed to find suitable replacements for PFAS. No one company will be able to solve the problem alone. Collaboration up and down the value chain will accelerate the effort for everybody.
If you’re a manufacturer or brand, talk to retailers about what their PFAS policy is, and how your products can fit in. If you’re a retailer, talk to brands and vendors about what they’re doing to find alternatives, and how you can help. If you’re a start-up or manufacturer creating new solutions, look for partners who are excited about your efforts and willing to chip in on development. Talk to your competitors, too, and see if you can find common ground and work towards replacements that will be beneficial for everyone.
Other important partners in the R&D effort will include:
universities and research institutes
funding agencies
trade associations
pressure groups
regulators
Innovate
While you’re communicating and collaborating, make sure you’re not stuck in the trap of looking for exactly the same thing, minus the hazard. Ask yourself:
Why is PFAS in this product in the first place? What function is it serving?
Look for proof that the fluorinated substance is actually serving the function, rather than assuming.How necessary is that function? Do consumers actually care about it?
Can that same function be met without chemical treatment? For example, can a fabric or yarn be constructed in a way that’s inherently water repellent?
This sort of alternatives assessment approach can help remove the "drop-in replacement” blinders and open up new avenues for innovation.
What do we need to get PFAS out and alternatives in?
It’s not an easy job to replace such a unique and ubiquitous group of chemicals. If we want to be sure that PFAS replacement is not just a passing fad, there are a few key things we’ll need.
Regulations
The wider the ban on PFAS spreads, the greater the demand (and funding) for alternatives will grow. We need regulations that are well-enforced, so consumers and industry can believe in them.Transparency
Transparency within supply chains is crucial to enable elimination of PFAS, and to engender consumer trust.Concerted demand
Value chains need to come together and speak with one voice, reflecting growing consumer and regulatory pressure. Voluntary phase-out initiatives can be a powerful force for driving chemical substitution.Useful resources
Guides and trainings in replacing PFAS will be critical in bringing the whole industry along for the ride. Not every company has the resources to create an in-house PFAS replacement team, or even have chemists on staff, so clear, useful assistance will be important.
Did I miss anything? Happy to learn if there’s something else we need, or if you’ve got favourite resources for PFAS substitution, please share them!