Analytical Approaches

Driven by divergent PFAS regulations across international markets and the need for brands to comply with RSL, numerous testing approaches are available in the market. These include total fluorine analysis, total organic fluorine analysis, targeted PFAS determination and an emerging non-targeted PFAS screening using sophisticated analysis technique (such as qTOF).

Table 1. Summary of common analytical approaches for PFAS

Among all analytical approaches, total fluorine (TF) and targeted PFAS analyses are the most widely available at international commercial testing laboratories.

TF ≠ PFAS

Total Fluorine (TF) refers to the total amount of fluorine from all sources, including organic fluorine and inorganic fluorine. PFAS only represent a specific category of organic fluorine that poses actual or potential hazards to the environment and human health. As the core regulatory target of global fluorine elimination initiatives and fluorinated compounds supervision, PFAS also constitute one component of Total Fluorine. Compared with PFAS, Total Fluorine (TF) covers a far broader scope.

In any case where the total fluorine result exceeds the specific regulatory limit, it is recommended to perform a supply chain investigation to obtain further information regarding the potential sources of fluorine. This includes requesting details on fluorine sources, enhancing supply chain transparency and reviewing crucial documentation. If reliable information is not available (or if it does not conclusively demonstrate that the exceedance is due to non-PFAS sources), it is prudent to perform follow-up targeted PFAS testing to confirm whether the exceedance is due to PFAS.

This tiered approach helps distinguish intentional PFAS use from incidental inorganic fluorine or non-regulated fluorinated compounds, while minimizing unnecessary full testing costs.

Regulatory Landscape

(1) EU (targeted PFAS focusing)

# It is noteworthy that many chemicals, by definition and based on their molecular structures, fall under the group of “related substances“. Analysing all such “related substances” is generally impractical and, in most cases, technically infeasible.
* Includes restrictions based on total fluorine analysis.
^ Covers cosmetic products, wax products and textile clothing products, footwear, and waterproofing agents for textiles, clothing and footwear

(2) US (total organic fluorine focusing)

Many US states regulate PFAS in consumer products, such as food packaging, apparel, textiles, and other goods, by prohibiting their intentional addition or use for any functional purpose. However, states vary significantly in how they define, prove and enforce the concept of "intentional" presence.

Some states, including California and Vermont, incorporate total organic fluorine (TOF) as a measurable proxy in multiple laws. This quantifiable fluorine-based threshold serves to indicate presumed intentional addition of PFAS. Exceeding the threshold will shift the burden of proof to manufacturers or importers, as in Washington, to rebut the presumption typically by providing credible evidence that the detected fluorine originates from non- PFAS sources (e.g. inorganic fluorides or non-PFAS organic compounds).

Other states, such as Maine and Minnesota, include total organic fluorine (TOF) content as information in their PFAS reporting rules if the exact quantity of each individual PFAS compound added is not known.

Many other states regulate PFAS without establishing any specific numerical fluorine threshold (i.e. no predefined "execution level" or de minimis limit). Instead, they impose a straightforward ban on "no intentionally added PFAS", relying on manufacturer declarations, supply chain attestations or targeted enforcement to ensure compliance. As more states enact or refine laws, the use of fluorine-based thresholds is likely to expand as a practical and standardized method for regulating PFAS.