PFAS (Per- and Polyfluoroalkyl Substances) are fluorinated organic chemicals containing at least one fully fluorinated carbon atom (i.e. at least one aliphatic -CF2- or -CF3 element). PFAS includes PFOA (Perfluorooctanoic Acid), PFOS (Perfluorooctane Sulfonate) and many other chemicals.
PFAS has been found used in consumer products including juvenile product, due to their grease, water and stain-resistant properties. However, Certain PFAS, e.g. PFOA and PFOS have been found very persistent in the human body, and can lead to adverse health outcomes. Animal studies indicate PFOA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects. Both chemicals have caused tumours.
EU and more U.S. States have already imposed restrictions on PFAS in juvenile product. Following is the summary of the earlies effective date for the juvenile product related requirement:
|
Earliest
Effective |
Region |
|
Restriction Rules |
|
|
2019 |
EU POPs |
|
2020 |
EU POPs |
|
2023 |
EU REACH Annex XVII, California |
|
2024 |
Colorado |
|
2030 |
Maine |
|
Reporting Rules |
|
|
2011 |
Washington (Chemicals of High Concern to Children) |
|
2014 |
Vermont (Chemicals of High Concern to Children) |
|
2018 |
Oregon (High Priority Chemicals of Concern for Children's Health) |
|
2020 |
Maine (Priority Chemicals) |
|
2023 |
Maine |
In EU and UK-NI, REACH Annex XVII Entry 68 will come into force in 2023, it is restricting the use of C9-C14 PFCAs and related substances.
The most concerned U.S. California AB 652 which restricts PFAS in juvenile products will become effective on July 1, 2023. Per AB 652, less than 100 ppm of total organic fluorine is allowed.
U.S. Colorado HB 22-1345, which also restricts PFAS in juvenile products, will become effective on January 1, 2024.
In 2023, reporting of intentionally added PFAS to Maine authority is requested.
More and more regions are imposing the PFAS restriction, with expertise from PTS Testing Service, manufacturer can cope with the PFAS challenge effectively.
PFAS have been restricted in many major countries and regions, for example:
|
Country /Region |
Regulation |
Products Scope |
Restricted PFAS and Limits |
Applicable Date |
|
China |
Ministry of Ecology and Environment Notice No. 10 of 2019 |
Substances, products |
(1) PFOS and its salts: shall not be used;(2) PFOSF: shall not be used. |
26 March 2019 |
|
EU |
POPs Regulation (Regulation (EU) 2019/1021) |
Substances, mixtures, articles |
(1) PFOA and
its salts ≤ 0.025 mg/kg (25 ppb); |
4 July 2020 |
|
EU |
REACH SVHC |
Substances, mixtures, articles |
(1)
Pentacosafluorotridecanoic acid: ≤ 0.1%; |
Various, have applied |
|
Denmark |
Executive Order No. 681 of 2020 |
Food contact materials made of paper and board |
PFAS: shall not be used. |
1 July 2020 |
|
Canada |
SOR/2012-285 and Amendment SOR/2016-252 |
Substances, products |
(1) PFOS and
its salts, its related substances: shall not be contained; |
1 January 2017 |
|
US Maine |
06-096 C.M.R. ch. 890 |
Certain children’s products |
PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. |
28 July 2020 |
|
US Washington |
HB2658 |
Food packaging |
PFAS: not intentionally added. |
1 January 2022 |
|
Washington CHCC (173-334 WAC) |
Certain children products |
(1) PFOA and
related substances: < PQL for intentionally added; or < 100 mg/kg (100
ppm) for contaminant; |
21 August 2011 |
|
|
US Vermont |
Vermont CHCC (18 V.S.A. chapter 38A) |
Certain children products |
(1) PFOA: <
PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; |
10 June 2014 |
|
US Oregon |
Oregon HPCCCH(OAR-333-016) |
Certain children products |
PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. |
1 January 2016 |
|
US New York |
New York Environmental Conservation Law, Section 37 Title IX |
Certain children products |
(1) PFOA and
related substances: < PQL for intentionally added; or < 100 mg/kg (100
ppm) for contaminant; |
1 March 2020 |
|
S.8817 and A.4739-C |
Food packaging comprised of paper, paperboard, or other materials originally derived from plant fibers. |
PFAS: not intentionally added. |
31 December 2022 |
|
|
US Rhode |
S.218 |
Food packaging |
PFAS: not intentionally added |
1 January 2020 |
|
US Massachusetts |
S.1315 (SD 678) |
Food packaging |
PFAS: not intentionally added |
1 January 2020 |
|
US California |
Proposition 65 |
All products |
(1) PFOA: not
pose a significant risk; |
10 November 2017 |
|
US California, San Francisco |
San Francisco Ordinance No. 201-18 |
Food service ware |
PFAS: not intentionally added |
1 January 2020 |
Following restrictions on PFAS have been also proposed in major countries and regions, for example:
|
Country /Region |
Regulation |
Products |
Proposed Restricted PFAS and Limits |
|
EU |
REACH Annex XVII |
Substances, mixtures, articles |
(1) C9-C14 PFCAs and their salts: < 0.025 mg/kg (25 ppb);(2) C9-C14 PFCA-related substances: ≤ 0.026 mg/kg (260 ppb) (sum) |
|
US |
Toxic in Packaging Model Legislation |
Package or packaging components |
PFSA not detachable. |
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