PFAS - A Regulatory Review and Proposed Management Framework
TWI Industrial Member Report 1223-2026
By Alan Taylor, FRSC, FIMM
Industrial Need
Perfluoroalkyl and polyfluoroalkyl substance (PFAS) is the generic term widely used to describe fluorinated chemicals and polymers. PFASs may be polymeric or non-polymeric in nature and find utility as coatings, bearing materials, seals, surface treatments, liners, surfactants and processing aids. They are widely used in every industrial sector and whilst the value of the global PFAS market is subject to considerable uncertainty; it is frequently estimated to be approximately £20bn/year. Fluoropolymers are generally regarding as contributing a substantial proportion of this value.
Concerns about the hazards of some PFAS have been growing with key substances being listed under the Stockholm Convention for Persistent Organic Pollutants. There is also increased regulatory scrutiny in many jurisdictions with the EU currently evaluating a broad PFAS class restriction, it is probable that the European Commission will make a decision on this proposal in 2027, in which case a restriction timeline may be set. Another example is the U.S., in 2024, PFAS reporting and record-keeping requirements under the Toxic Substances Control Act were finalised. This rule requires that those who have manufactured and/or imported during the relevant period to report on PFAS uses, production and/or importation volumes, disposal, exposures and hazards. This obligation is particularly significant because it is retrospective to 1 January 2011.
The changing landscape of PFAS is multi-faceted and complex and has evolved from a relatively specialised chemicals management issue into a broader strategic challenge affecting industry, regulators, investors, customers and society. While the scientific, regulatory and commercial landscape continues to develop the direction of regulatory travel is increasingly towards broader control of PFAS, with greater emphasis on persistence, environmental release and life-cycle impacts rather than solely on the hazards of individual substances.
Whilst there is broad industry awareness that the PFAS landscape is changing, there is a lack of clear guidance to this complex issue. TWI has kept a watching brief on this topic since 2014, a Joint Industry Project (JIP) was started in April 2026. This Member Report is the formal output of the first deliverable under this JIP which is also supported under TWI’s Core Research Programme.
Key Findings
- The direction of regulatory travel is increasingly towards broader control of PFAS, with greater emphasis on persistence, environmental release and life-cycle impacts rather than solely on the hazards of individual substances.
- Information and transparency are becoming increasingly important.
- PFAS is becoming an issue that extends being environment compliant. The emergence of multi-billion-dollar legal settlements, growing investor interest and expanding disclosure requirements demonstrate that PFAS can influence corporate reputation, financial performance and long-term business strategy, as well as product stewardship and environmental management.
- Significant uncertainties remain. Regulatory frameworks continue to evolve, and the technical feasibility of substitution varies considerably between applications. Not all PFAS present the same level of risk, and not all applications are currently replaceable. Consequently, simplistic assumptions regarding universal prohibition or universal substitution are unlikely to reflect industrial reality.
- Adoption of a balanced approach that combines scientific understanding, regulatory awareness, supply chain awareness and transparency and practical innovation are likely to lead to greater success in navigating the evolving PFAS landscape.
- The most effective response may not be immediate elimination of all PFAS, but a structured transition programme focussed on reducing unnecessary use, improving stewardship and identifying technically viable alternatives where they exist.
Impact
The report presents an overview of the key topics relating to PFAS, specifically:
- PFAS: Definitions and classifications
- Uses of PFAS
- Hazards associated with PFAS
- The regulatory landscape from a global perspective and in more detail in significant jurisdictions
- Restrictions versus substance-specific controls including implications for manufacturers, importers and downstream users
- Emerging disclosure and reporting requirements and substance and product reporting
- Environmentally directed finance and sustainability
- Public perception, stakeholder attitudes and reputational risk
- Litigation and liability landscape
- Product stewardship and life-cycle management
- PFAS alternatives
We propose a PFAS Transition Framework that provides a defensible, evidence-based methodology that balances technical performance, regulatory compliance, commercial requirements and environmental responsibility.