1. Automatic PFAS screening of your BOMs
How the Substantio Software supports you with PFAS compliance
Substantio automatically identifies PFAS substances in your products that are listed on the REACH Candidate List as SVHCs (internal link to the REACH page, anchor “Candidate List”). You immediately see where action is needed and which components are affected.
Survey your suppliers in a structured, digital way – without email chaos. Capture PFAS-relevant information systematically across your entire supply chain.
Stay on top of current and upcoming PFAS restrictions in the EU, US, and Canada. Substantio alerts you in good time to regulatory changes.
Identify PFAS-containing materials and systematically search for alternatives. Substantio supports you in substituting and avoiding SVHC substances.
For PFAS substances that are listed as SVHCs and present at ≥ 0.1 % by weight, Substantio prepares the required data for your SCIP notification – fast and compliant.
What are PFAS?
PFAS stands for per- and polyfluoroalkyl substances – a group of more than 10,000 synthetic chemicals used in industry for their water-, oil- and stain-repellent properties.
PFAS are extremely stable. Their strong carbon-fluorine bond makes them virtually indestructible. Once released into the environment, they remain there – effectively for thousands of years – in air, water, soil and living organisms. They practically do not break down.
PFAS are found in many everyday products and industrial applications:
- Water- and stain-repellent textiles (outdoor clothing, workwear)
- Non-stick coatings (pans, baking paper)
- Food packaging (fast-food packaging, coated paper)
- Fire-fighting foams
- Electronics and semiconductors (etching processes, coatings)
- Paints, coatings, lubricants
- Coolants and seals
Why are PFAS dangerous?
PFAS accumulate in the environment and in the human body. Studies show that certain PFAS can:
- Be carcinogenic (e.g., kidney and testicular cancer)
- Weaken the immune system and reduce the effectiveness of vaccines
- Act as endocrine disruptors (hormone-active substances)
- Damage the liver
- Increase the risk of pregnancy complications
- Be detected in breast milk and blood – even in people without direct exposure
Particularly problematic: PFAS do not degrade. Even if production is stopped, they remain in the environment for generations.
Regulatory pressure: PFAS bans worldwide
EU: Far-reaching PFAS restriction in preparation
The European Chemicals Agency (ECHA) is working on a comprehensive restriction of almost all PFAS under the REACH Regulation. The restriction proposal was published in February 2023 and covers around 10,000 substances.
Current status (2025):
ECHA has evaluated more than 5,600 scientific and technical submissions and has updated the restriction proposal in Annex XVII of the REACH Regulation*. The final opinions of the committees (RAC and SEAC) are expected for 2025/2026. A ban could gradually enter into force from the late 2020s, with transition periods depending on the application.
What does this mean for companies?
- Supply shortages for PFAS-containing materials
- Need for early substitution
- Documentation and notification obligations
- Risk of product recalls and liability claims
PFAS already regulated under REACH:
Certain PFAS are already on the SVHC Candidate List and are subject to information and notification obligations (from 0.1 % by weight):
- Perfluorohexane sulfonic acid (PFHxS) and its salts
- Perfluorooctane sulfonic acid (PFOS)
- Perfluorooctanoic acid (PFOA) and its salts
- HFPO-DA (“GenX”)
Important:
The list is continuously being extended. What is allowed today may be banned tomorrow.USA: Reporting obligations and limits
The US Environmental Protection Agency (EPA) has introduced strict limits for PFAS in drinking water and requires companies to provide extensive reports on their use of PFAS. Manufacturers and importers must disclose their PFAS use – with significant penalties for non-compliance.
Canada: Extended reporting obligations
Canada is also tightening regulations: Under the Canadian Environmental Protection Act (CEPA), companies must report PFAS-containing products and perform risk assessments.
Who is affected by PFAS regulations?
These industries need to act now
PFAS are used across many industries – and the regulations affect more companies than you might think:
- Chemical industry, especially lubricants
- Textile and apparel industry – outdoor wear, personal protective equipment, impregnated textiles
- Electronics and semiconductors – etching processes, coatings, seals
- Fire protection systems – fire-fighting foams, fire extinguishers
- Metalworking and electroplating – chemicals for surface treatment
- Automotive industry – coolants, lubricants, seals
- Food packaging – fast-food packaging, coated paper, baking paper
- Paints and coatings – water- and stain-repellent finishes
If you manufacture, import or place products on the market that may contain PFAS, you should act now – before the ban comes.
Your challenges in PFAS compliance
Lack of transparency in the supply chain
Many suppliers do not know whether their materials contain PFAS – or provide incomplete information. Without systematic supplier questionnaires, risks remain hidden.
Complex substance group with thousands of chemicals
PFAS are not a single chemical, but a group of more than 10,000 substances. Identifying them is complex and requires expertise.
Regulatory uncertainty
The EU ban is in preparation, but details and deadlines are not yet final. Companies must act proactively – without knowing exactly when restrictions will come into force.
Declaration and notification obligations
Some PFAS are already subject to SCIP notification obligations today. Those who fail to report in time risk fines and sales bans.
Costs of substitution and conversion
PFAS-free alternatives are often more expensive or technically more demanding. Switching requires time, testing and investment.
Liability risks and reputational damage
Companies using PFAS may in future be held liable for environmental and health damage – with significant financial and reputational consequences.
PFAS and REACH: What you need to know
Information obligation:
SCIP notification obligation:
You must submit the article to ECHA’s SCIP database.
Documentation obligation:
All information must be documented in a traceable way.
Examples of regulated PFAS:
- PFOA (perfluorooctanoic acid) and its salts – already heavily restricted
- PFOS (perfluorooctane sulfonic acid) – banned with few exemptions
- PFHxS (perfluorohexane sulfonic acid) and its salts – on the SVHC list since 2020
- HFPO-DA (“GenX”) – developed as a replacement for PFOA but also problematic
More PFAS are added on an ongoing basis. ECHA updates the SVHC list twice a year (June and December).
From Candidate List to ban
The path from PFAS identification to full restriction typically follows this pattern:
- Identification as SVHC →information and notification obligations
- Inclusion on the Authorization List (Annex XIV) →use only with official authorization
- Restriction (Annex XVII) →use bans in specific applications
For the planned EU-wide PFAS restriction, this process may be accelerated – with virtually all PFAS affected at once.
Key links & official resources
For up-to-date information on PFAS and regulations, we recommend the following official sources:
FAQ's
What exactly are PFAS and why are they so problematic?
PFAS (per- and polyfluoroalkyl substances) are a group of more than 10,000 synthetic chemicals characterized by an extremely strong carbon-fluorine bond. This bond makes them almost indestructible – hence the term “forever chemicals”.
Why are they problematic?
- They practically do not degrade in the environment
- They accumulate in the human body and in organisms
- Certain PFAS are carcinogenic, hormone-active and damage the immune system
- They are detectable worldwide – even in remote regions such as the Arctic
- Once released, they remain for decades to centuries
When will the EU-wide PFAS restriction come?
ECHA is currently working on a comprehensive restriction proposal for almost all PFAS. The proposal was published in February 2023 and is currently being evaluated scientifically.
Current status (2025):
- ECHA has evaluated more than 5,600 submissions
- The final opinions of the committees are expected for 2025/2026
- A restriction could gradually enter into force from the late 2020s
- Transition periods will vary by application (several years for essential uses, shorter for consumer products)
Our recommendation: Act proactively now – don’t wait for the final restriction. Switching to PFAS-free alternatives takes time.
Which PFAS are already regulated today?
Some PFAS are already on the REACH Candidate List (SVHC list) and are subject to information and notification obligations:
- PFOA (perfluorooctanoic acid) and its salts – heavily restricted since 2020
- PFOS (perfluorooctane sulfonic acid) – banned with few exemptions
- PFHxS (perfluorohexane sulfonic acid) and its salts – SVHC since 2020
- HFPO-DA (“GenX”) – replacement for PFOA, also listed as SVHC
- C9–C14 PFCAs (long-chain perfluorinated carboxylic acids) – SVHC since 2019
Important: The list is updated twice a year. Further PFAS are added on an ongoing basis.
Do I have to declare PFAS in my products?
Yes, if your products contain PFAS listed on the SVHC Candidate List at concentrations ≥ 0.1 % by weight. In that case, the following obligations apply:
✅ Information obligations towards customers:
- B2B customers must be informed within 45 days of delivery
- Consumers must receive information upon request within 45 days
✅ SCIP notification obligation:
- You must submit the article to ECHA’s SCIP database
- This applies to manufacturers, importers and distributors in the EU
✅ Documentation obligation:
- All information must be documented in a verifiable way
Substantio helps you identify affected products and prepare notifications.
How do I know whether my products contain PFAS?
PFAS are often “invisible” – many suppliers do not even know whether their materials contain PFAS. Typical indicators:
- Water-, oil- or stain-repellent coatings (e.g., impregnated textiles, non-stick coatings)
- Fire-fighting foams (often contain PFAS)
- Electronics and semiconductors (etching processes, coatings)
- Paints, coatings, lubricants with special performance properties
Recommended steps:
- Ask suppliers:Request material safety data sheets and PFAS declarations
- Check BOMs:Identify critical components
- Use software:Substantio helps you systematically capture and assess PFAS substances.
What are PFAS-free alternatives?
Substituting PFAS is challenging but possible. Depending on the application, different alternatives exist:
Textiles:
- Silicone-based impregnations
- Wax finishes
- Polyurethane coatings (without fluorochemistry)
Food packaging:
- Cellulose-based coatings
- Bio-based barrier materials
- Uncoated paper with mechanical barriers
Fire-fighting foams:
- Fluorine-free foams (F3 foams)
- Protein-based extinguishing agents
Electronics:
- Alternative etching chemicals without PFAS
- Physical coating methods
Substantio supports you with alternatives screening to identify and evaluate PFAS-free materials.
What happens if I don’t declare PFAS?
Violations of declaration and notification obligations can have serious consequences:
- Fines: In Germany up to EUR 50,000 or more, depending on the severity of the violation
- Sales bans: Products may no longer be placed on the market
- Product recalls: With high costs and reputational damage
- Liability risks: Potential claims for damages in cases of environmental or health impacts
- Criminal consequences: In cases of intentional violations
Prevention is cheaper than remediation.
How does PFAS regulation differ between the EU, US, and Canada?
EU:
- Comprehensive PFAS restriction in preparation (around 10,000 substances)
- Certain PFAS already listed as SVHCs under REACH
- SCIP notification obligation for articles containing SVHC PFAS
USA:
- Strict drinking water limits for PFAS (EPA)
- Reporting obligations for manufacturers and importers
- Additional state-level regulations (e.g., California, Maine, Washington)
Canada:
- Extended reporting obligations under CEPA
- Risk assessments for PFAS-containing products
- Possible restrictions in preparation
Our recommendation: If you operate internationally, you must keep all regulations in view. Substantio helps you stay on top of them.
Do PFAS regulations also apply to small businesses?
Yes. PFAS regulations apply to all companies that manufacture, import or place products on the market – regardless of company size.
Even small businesses and start-ups must:
- Declare PFAS-containing products (if SVHC ≥ 0.1 %)
- Submit SCIP notifications
- Survey suppliers
- Fulfil documentation obligations
Good news: Digital tools like Substantio make compliance affordable and efficient even for smaller companies.
How can Substantio help me with PFAS compliance?
Substantio offers a comprehensive solution for PFAS management:
✅ Automatic PFAS identification: Detects PFAS substances on the SVHC list in your bills of materials
✅ Digital supplier questionnaires: Capture PFAS information
