January 20, 2026 Key Insights from Assent’s Top 10 PFAS Findings

Data shows that PFAS are prevalent in every industry. With new PFAS reporting requirements learn how manufacturers can meet new the rules.

By Cally Edgren, Vice President, Regulatory & Sustainability at Assent

In today’s changing regulatory environment, few issues have captured manufacturers’ attention like per- and polyfluoroalkyl substances (PFAS). These “forever chemicals” are under scrutiny worldwide for their persistence in the environment and potential negative impacts on human health.

To determine PFAS prevalence, Assent aggregated data from over 5 million supplier declarations submitted to its platform. More than 550 of Assent’s customers across various industries collected PFAS data, and over 80% of them found PFAS in their products. Among these, nearly 700 unique PFAS were identified.

This shows that while the EPA has identified over 16,000 PFAS, the actual types of PFAS being commercially produced and used are much smaller. In fact, one single substance, polytetrafluoroethylene (PTFE), known for its durability and low friction, accounted for nearly half of all reported PFAS. Other substances, such as perfluorooctanoic acid (PFOA), potassium perfluorobutanesulfonate (PFBS), and ammonium perfluorooctanoate (APFO), are also included in the top 10 findings.

The fact that nearly all Assent customers are finding PFAS in their purchased materials comes as no surprise. PFAS are known for their superior material properties and are used widely across many industries. Since most manufacturers use them, they are impacted by rapidly evolving regulatory requirements and parts obsolescence, not to mention the increasing risks of litigation. PFAS are embedded in coatings, insulators, cables and wires, surfactants, gaskets, O-rings, hoses, plastics, lubricants, and even the smallest components of electronic assemblies. Even a substance like PFOA, which hasn’t been produced in the U.S. since 2015, is found in legacy parts and imported goods, which further complicates PFAS phase-outs.

As a result, identifying and reporting PFAS cannot be simplified into one single compliance check. It’s a process of getting deeper visibility and driving accountability across your entire supply chain.

How Prepared Are Manufacturers for PFAS Reporting?

While awareness is growing, readiness to respond to customers and regulators remains inconsistent across industries. The U.S. Environmental Protection Agency (EPA)’s reporting rule under TSCA Section 8(a)(7), as mandated by U.S. Congress, requires companies to disclose detailed data on PFAS manufactured from 2011–2022. While the EPA has proposed removing “imported articles” from this requirement, numerous states like Minnesota, Connecticut, New Mexico, and Washington are also requiring reporting of products that contain PFAS and are sold in their state, while numerous additional states also have restrictions and/or labeling requirements.

The EPA’s PFAS reporting portal will open on April 13, 2026, with submissions due by October 13, 2026 (April 2027 for small businesses). The data requirements are specific and extensive, and manufacturers face a fundamental challenge: collecting and verifying information from large and varied global supplier networks.

Assent’s customers report varying levels of preparedness. Some are still in the preliminary stages, closing data gaps and educating suppliers. Others have fully mapped their PFAS usage and established centralized data exchange with suppliers’ systems using automated platforms. Those in later stages of preparedness are also able to determine which products are impacted by components containing PFAS — even just 3% of parts containing PFAS could affect over 90% of a finished portfolio, which is, in turn, subject to regulation and redesign. With market access on the line and more restrictions taking effect every year, it’s critical to understand how PFAS are used in products and processes.

The Challenges: Scope, Substitutions & Supply Chain Complexity

1. Navigating the Full Scope of PFAS Regulations

Under TSCA Section 8(a)(7), manufacturers must report on all PFAS manufactured in or imported to the U.S. from 2011–2022, including PFAS manufactured as byproducts, intermediates, and process chemicals. It applies to companies of all sizes, with no de minimis threshold. Reporting details are specific and include information such as the chemical name and concentration.

To make things even more complicated, state-level laws — like Minnesota’s Amara’s Law, which takes a phased approach to restricting PFAS-containing products as well as implementing mandatory reporting of products sold in the state that contain PFAS — are advancing much faster than federal timelines. Numerous other states have also implemented their own PFAS restrictions along with labeling and reporting requirements.

In fact, every region around the world is implementing similar regulations. Canada had a similar PFAS reporting requirement earlier this year. The EU already restricts several PFAS and is working on a “universal” PFAS ban. EU member states are implementing their own individual restrictions at a faster pace than the EU, and the Stockholm Convention includes several PFAS.

These overlapping requirements are forcing companies to navigate a maze of regulations while still responding to customer, investor, and insurance pressures to demonstrate proactive risk management. And as the regulatory restrictions grow, chemical manufacturers like 3M are getting out of the business of PFAS, making supply-chain obsolescence a real threat that impacts the ability of manufacturers to make their products.

2. Substitution & Redesign Hurdles

Replacing PFAS is often harder than identifying them. Top-performing manufacturers are mapping PFAS across product lines and operations to identify high-risk areas and begin strategic redesigns or material substitutions.

But substitution brings its own challenges. Many PFAS deliver unique performance characteristics, such as heat resistance, chemical inertness, or non-stick properties, that are difficult to replicate without compromising function or safety. Requalification testing for alternative materials, especially in sectors such as aerospace, automotive, and medical devices, can take years and cost millions of dollars.

As a result, some manufacturers are adopting a tiered approach: prioritizing high-risk materials and critical components for early substitution, while developing risk management strategies for the others. Understanding which PFAS is being used (for example, PTFE versus PFOA) helps designers determine urgency and risk of obsolescence. This balance allows for continuous improvement without disrupting production or market access.

3. Data Collection & Supplier Engagement

The scale of PFAS reporting — spanning thousands of suppliers and product categories and requiring specific information such as the CAS number and concentration — makes manual tracking impossible. That’s why automation and digital solutions are becoming essential. Leading manufacturers are leveraging platforms like Assent’s to automate supplier outreach, analyze bills of materials, and build centralized compliance databases that can generate declarations at the click of a button.

Many organizations still struggle with supplier education and engagement. They may rely on insufficient methods to identify PFAS, such as inadequate and expensive chemical testing or reviewing safety data sheets (SDS). Even when an SDS is available, PFAS aren’t usually disclosed, and proprietary formulas often hide key details. The most successful companies are those that go beyond compliance to educate their suppliers about regulatory expectations and establish long-term, transparent partnerships.

Building a PFAS-Resilient Future

The data Assent has collected through supplier declarations shows that PFAS are pervasive. But proactive manufacturers are finding pathways forward. By investing in supplier education, digital data management, and sustainable alternatives to PFAS, manufacturers can transform PFAS compliance from a reactive burden into a strategic advantage.

For global manufacturers, the time to act is now — because understanding where PFAS exist today is the first step toward building a cleaner, more resilient supply chain tomorrow.

About the Author
Cally Edgren has over 30 years of experience working at global manufacturers, including Rockwell Automation, Kohler Co., and Rayovac. She now leads a team of regulatory experts at Assent, a supply-chain sustainability software provider, as the Vice President of Regulatory & Sustainability. She’s known for her expertise in product materials regulations, market access certifications, and supply chain sustainability initiatives. She’s passionate about product compliance and helping manufacturers build strong partnerships with their suppliers to support their market requirements.

www.assent.com

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