The Global Shift Away from PFAS: What It Means for Your Supply Chain

As one of the world's largest manufacturers, 3M’s recent decision to cease the production of per- and polyfluoroalkyl substances (PFAS) by the end of 2025 has grabbed headlines. However, 3M is not alone in this move. Other major chemical manufacturers are also beginning to phase out PFAS production in response to growing environmental, health, and regulatory pressures. This collective shift marks a significant turning point for industries worldwide, necessitating a proactive response from businesses to mitigate risks and ensure continuity.

The Broad Impact of PFAS on Industries

The decision by multiple chemical giants to stop manufacturing PFAS will have profound implications across numerous sectors. Industries such as automotive, construction, manufacturing, and transportation are heavily reliant on the unique properties of PFAS. These chemicals are valued for their resistance to heat, water, and oil, making them indispensable in various applications, from non-stick cookware and water-resistant fabrics to firefighting foams and advanced chemical processes.

Yet, the impact goes beyond just the products themselves. Many companies depend on PFAS for critical processes and equipment that safeguard their operations and ensure employee safety. This includes personal protective equipment (PPE) and engineering controls that mitigate workplace hazards. The discontinuation of PFAS production by leading chemical manufacturers is likely to disrupt these processes, compelling companies to seek alternative solutions.

A Broader Industry Shift Finding Alternative to PFAS

3M’s decision is part of a larger trend, with other chemical manufacturers also stepping away from PFAS production. The escalating litigation and liability risks associated with PFAS are further motivating manufacturers to eliminate these chemicals from their product lines.

This industry-wide movement is driving businesses across all sectors to reassess their reliance on PFAS. The pressure from investors, customers, and competitors is growing, making it clear that companies can no longer afford to adopt a reactive stance. A proactive strategy is essential to ensure business continuity and maintain a competitive edge in an increasingly regulated market.

Understanding the Scope of PFAS Use

The challenge of eliminating PFAS from supply chains is formidable due to the extensive use of these substances across multiple industries. According to the European Chemical Agency (ECHA), more than 10,000 PFAS chemicals are currently on the market, and their applications are vast. PFAS can be found in a wide array of products, including fast food packaging, pesticides, dental floss, cosmetics, water-resistant clothing, furniture, and non-stick cookware.

However, these examples only scratch the surface. Recent lawsuits have revealed that PFAS can also be found in unexpected places, such as fruit juice and underwear. Furthermore, their use is not confined to consumer products; PFAS are integral to many industrial processes, medical technologies, machinery, and health and safety applications. Given their widespread use, it is likely that most companies have PFAS embedded somewhere within their supply chains, operational processes, or maintenance activities. The potential unavailability of these substances could lead to significant operational disruptions.

The Risks of a Reactive Approach for PFAS

While the deadlines for phasing out PFAS may seem distant, companies must begin identifying these chemicals in their supply chains now to mitigate potential risks and penalties. Both the United States and the European Union are actively working to hold manufacturers accountable, with regulations that either restrict PFAS use or enforce stringent reporting requirements. Non-compliance could result in severe consequences, ranging from hefty fines to criminal investigations. Additionally, the reputational damage from being involved in PFAS-related lawsuits could harm a company’s standing with consumers and investors alike.

The legal landscape is already shifting. For instance, California Attorney General Rob Bonta has filed a lawsuit against 3M, DuPont, and other entities for environmental damage and endangering public health due to PFAS. The lawsuit doesn’t just target chemical manufacturers; it also implicates distributors and users of PFAS. Furthermore, 3M has faced significant financial settlements in the past, including an $850 million settlement in 2018 for groundwater contamination in Minnesota and a €571 million agreement with Belgium in 2022.

The insurance industry is also reacting to these developments. Insurers are increasingly wary of the financial risks associated with PFAS-related lawsuits and cleanup costs. As a result, companies may face stricter insurance requirements or, in some cases, could even lose liability coverage altogether. This adds another layer of complexity for businesses relying on PFAS.

Steps for Proactive PFAS Preparation

Given the risks associated with PFAS, it is crucial for companies to adopt a proactive strategy. Here are the steps businesses should take to prepare:

1. Assess Current Risks:
   Start by identifying where PFAS are used in your supply chain, products, and processes. Understanding the current extent of your reliance on PFAS will allow you to evaluate the risks associated with parts obsolescence and regulatory non-compliance.

2. Identify Blind Spots:
   It’s not just about what you know; it’s also about what you might be missing. Many companies focus on product design risks but overlook how PFAS are used in processes, maintenance, and employee health and safety. A thorough assessment of all operations is necessary to uncover these blind spots.

3. Stay Ahead of Reporting Requirements and Restrictions:
   PFAS regulations are evolving, with specific substances already subject to laws such as California's Proposition 65, EU REACH, and the Stockholm Convention on Persistent Organic Pollutants (POPs). While it’s important to monitor forthcoming regulations, companies must also ensure they are compliant with current requirements in all markets where they operate.

4. Redesign Products and Processes Early:
   The need for redesigns will become inevitable as PFAS products are phased out and companies scramble for alternatives. Starting the redesign process early will help avoid rushed efforts, reduce competition for scarce resources, and minimize costs.

5. Plan for All PFAS:
   Historically, regulations have focused on specific PFAS, like PFOA or PFOS. However, new laws, such as the one recently enacted in Maine, are beginning to target all PFAS chemicals. Companies should prepare for a future where all PFAS are regulated, rather than waiting for each individual substance to be restricted.

6. Anticipate Parts Obsolescence:
   The timing of parts obsolescence due to PFAS restrictions is uncertain, but the collective decisions by major manufacturers to cease production of these chemicals are clear signals that it’s coming sooner rather than later. Companies that take the initiative now to understand and mitigate these risks will gain a competitive advantage and position themselves for long-term success.

Conclusion

The global movement to phase out PFAS, led by industry giants like 3M, marks a defining moment for businesses worldwide. This shift not only demands compliance with evolving regulations but also presents an opportunity to innovate and lead in sustainability. Companies that act now to eliminate PFAS from their operations will not only mitigate legal, financial, and reputational risks but also position themselves as forward-thinking leaders in an increasingly eco-conscious market. The choice is clear: adapt proactively or risk falling behind in a rapidly changing regulatory landscape.

Now is the time to future-proof your business against the challenges posed by PFAS restrictions. Start by assessing your supply chain, identifying PFAS dependencies, and exploring sustainable alternatives. Don’t wait for regulatory deadlines or supply disruptions to take action. Partner with Acquis to navigate this complex transition seamlessly.

Book a consultation today to uncover how your business can proactively eliminate PFAS and strengthen your supply chain. Let’s build a safer, greener future—together.