Insight Paper June 4, 2024

PFAS Impacts on the Supply Chain

Impacts of regulations, manufacturing changes, and PFAS discontinuations on the supply chain.

INTRODUCTION

With the focus on Per- and Polyfluoroalkyl Substances (PFAS) being much higher in recent years, in addition to 34 states introducing 282 PFAS policies, there have been a plethora of new federal PFAS regulations – more in-depth information can be found here.¹ These new regulations on PFAS manufacturing have a significant impact on the supply chains. 3M, one of the largest PFAS manufacturers, has “announced it will exit Per- and Polyfluoroalkyl substance (PFAS) manufacturing [by the end of 2025] and work to discontinue the use of PFAS across its product portfolio.”² In this Trexin Insight Paper (TIP), we will examine the impact of these PFAS manufacturing changes on companies; including how companies can locate PFAS in their supply chain and next steps companies can take for products that contain PFAS.

AFFECTED COMPANIES

According to a nationwide survey taken in November 2023, roughly 76% of Americans said they have either never heard of PFAS or think the impact of PFAS is relatively small.³ However, PFAS is used extensively in a wide range of industries including automobiles, consumer goods, electronics, and medical technology.⁴ For example, 79% of nonstick pans were coated in PTFE (a type of PFAS) and “nearly 40 percent of 138 [fast-food] wrappers tested contained PFAS.”⁵⁶ This ultimately means companies in these supply chain, spanning from a manufacturer of PFAS to those producing the final product, will be impacted by changes in PFAS manufacturing. To avoid fees and penalties due to non-compliance, companies will be required to strategize the next steps for their products impacted by new and future PFAS regulations.

For instance, companies that sell products in Minnesota will have to ensure their products do not contain intentionally added PFAS to comply with Minnesota laws that PFAS is only allowed if it is unavoidable.⁷ These laws require all companies that manufacture, sell, or distribute products with intentionally added PFAS to submit required information to the Minnesota Pollution Control Agency (MPCA).⁸ Based on this information, companies will be fined for products that are manufactured, sold, or distributed with intentionally added PFAS.⁹

LOCATING PFAS IN THE SUPPLY CHAIN

Since PFAS regulations have been less strict in the past, companies lack a complete database that allows them to easily identify the presence of PFAS in their products. To fix this, companies will need to learn what products are affected by PFAS and locate where PFAS is present in the supply chain. The two main ways for companies to solve this include testing parts manufactured by their company that could potentially be impacted by PFAS, and outreach to their suppliers to investigate their products and understand if their supply chain is impacted.

Outreach can be a huge undertaking since it requires understanding regulations to know what information needs to be collected, especially since new regulations and changes are still happening. It also is an extensive workload to survey all suppliers and gather information on all parts and products. There is a lot that goes into making outreach programs more efficient, including creating workflows, using effective communication, prioritizing suppliers, and more.¹⁰

NEXT STEP FOR COMPANIES

Once companies know what products in their supply chain are affected by PFAS, they must decide their next steps. These next steps are affected by a variety of factors, including how the product is affected by PFAS, how much PFAS is in the product, and more. The main goal of the next steps is to ensure that all PFAS manufacturing and products align with current and future regulations. Some main ways companies can handle the next steps are by decreasing the amount of PFAS in a product, completely removing PFAS from a product, or finding an alternative to PFAS.

A prime example of this is in the fast-food industry with removing PFAS from packaging. Part of these decisions are due to strict regulations, including the U.S. Food and Drug Administration (FDA) announcing in February that materials containing PFAS can no longer be sold for use in fast food packaging.¹¹ Regulations and an easy alternative to remove PFAS from packaging has led to major retailers and fast-food companies to announce that they are phasing out PFAS from their packaging.¹²

CONCLUSION

With new regulations and major manufacturers halting PFAS manufacturing, it is important that companies act and create next steps to ensure their products’ availability. Trexin has the experience and expertise to tackle many PFAS-related concerns your organization might have while working quickly and efficiently within the bounds of new regulations. For guidance on evaluating the presence of PFAS in your supply line and remediation on products with PFAS risks, please contact one of our PFAS Advisors listed below. Click here to learn more about how we are helping a large MedTech leader survey its suppliers to fully inventory the presence of PFAS in their products.

Want to learn more? Connect with one of Trexin’s PFAS Advisors: