Learn What PFAS Are, The Components That Use Them & The Regulations Around Them
PFAS stands for per- and polyfluorinated alkyl substances. They're a large chemical family, encompassing over 10,000 highly fluorinated substances. The common feature that connects all these chemicals is that they have carbon atoms linked to fluorine atoms. While there are thousands of PFAS currently in existence, historically the most widely used of these compounds are perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). This carbon-fluorine bond makes PFAS extremely stable both thermally and chemically — meaning they're resistant to high temperatures and take a long time to degrade. They're also highly effective at repelling water, grease, and stains.
The first PFAS compound was introduced to the world by DuPont in the form of the highly durable, nonstick, heat-resistant resin known as Teflon, or Polytetrafluoroethylene (PTFE). In the three decades following its introduction to the public, companies began to incorporate PFAS into an array of popular commodities, including shoes, apparel, outdoor equipment, food packaging, cosmetics, and more. Today, this collection of unique and highly advantageous properties lends itself to even more products and applications, including waterproof jackets, nonstick pans, sunscreen, and coatings for various electronics.
PFAS chemicals, notably perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), polytetrafluoroethylene (PTFE), and perfluorobutane sulfonic acid (PFBS), show up in electronics manufacturing in a variety of products:
A survey of Z2's component database identified over 40,000 parts that have PFAS in them. Grouping these parts by product type showed that 281 electronic commodities are impacted by PFAS. Of these commodities, over 14,000 capacitors contained PFAS (about 36% of the total parts). Connectors and cables followed, with thousands of parts each. Oscillators and RF products also had 1,000+ parts with PFAS in them. While these are only the top 5 categories, over 270 other categories are also impacted.
Top Electronic Component Categories Containing PFAS
While their properties make them ideal for manufacturers, those same qualities also make them a growing threat to the environment and human health at large. Any exploration into the negative human health effects of PFAS exposure must start with the C8 Health Project. The C8 Project was a yearlong epidemiological study of nearly 70,000 people that lived near the DuPont Washington Works chemical plant in West Virginia, conducted in the wake of a class action settlement against the company for its contamination of nearby water supplies. The results were nothing short of alarming. First, the study found that the participants had PFAS levels in their blood that were five times higher than those of any other previously observed population. Second, it identified probable links between PFAS exposure and six different diseases, including thyroid disease, testicular and kidney cancer, and pregnancy-induced hypertension.
Research into forever chemicals' effects on wildlife has been less comprehensive or conclusive. Nevertheless, studies have shown that the chemicals are present in over 330 species worldwide, including large and small mammals, birds, fish, and reptiles. More specifically, there's evidence that PFAS exposure affects the immune systems of bottlenose dolphins and sea otters, as well as the brains, reproductive systems, and hormones of polar bears. Although the highest concentrations of PFAS are found in waterways near chemical plants and wastewater treatment facilities, their extraordinary persistence and mobility has allowed them to spread to some of the farthest reaches of the planet.
Current PFAS regulations on an international level can be found in the Stockholm Convention — an international treaty developed in 2001 to regulate persistent organic pollutants (POPs) with detrimental human health effects. Initially focusing on 12 POPs, the list now contains more than 30 substances, including perfluorooctanoic acid (PFOA) and perfluorohexane sulfonic acid (PFHxS). In 2023, Germany, Denmark, the Netherlands, Sweden, and Norway submitted a proposal to the European Chemicals Agency (ECHA) requesting PFAS be added to REACH. If adopted, this proposal would be one of the most comprehensive changes to REACH since it was entered into force in June 2007, potentially banning all PFAS usage — in other words, over 10,000 different substances.
In October 2021, the EPA announced a PFAS Strategic Roadmap, a multifaceted, whole-of-agency approach to the chemicals that includes directives to research exposures and toxicities, restrict further PFAS from entering the environment, and clean up existing contamination. On October 11, 2023, the EPA published a final rule under the Toxic Substances Control Act Section 8(a)(7), titled Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances. The new rule requires all businesses — including manufacturers and importers of one of around 1,400 PFAS compounds — to submit a report to the EPA detailing their use of PFAS.
Potentially Banned PFAS Compounds in Electronics
| Compound | Full Name | Applications in Electronics |
|---|---|---|
| PFOA | Perfluorooctanoic acid | Cables and computer parts |
| PFOS | Perfluorooctane sulfonate | Cables and computer parts |
| PTFE | Polytetrafluoroethylene | Electrical insulation, medical devices, aerospace, seals and gaskets, textile coatings |
| PFBS | Perfluorobutane sulfonic acid | Surfactant, emulsifier, aerospace |
The EPA is requiring companies to retroactively report on their PFAS usage from January 1, 2011 to December 31, 2022. In enforcing the new TSCA regulations, the agency is using a structural definition of PFAS covering three molecular structures. Any business that has imported or manufactured PFAS or PFAS-containing articles between January 2011 and December 2022 must report it.
PFAS regulations by state are in constant flux. Many state-level regulatory efforts are even stricter than those proposed by the federal government. In all, twenty-five states have adopted laws restricting PFAS usage, with nine additional states proposing new legislation.
| State | Law / Bill | Key Requirements |
|---|---|---|
| Maine | LD 1503 | Effective Jan 1, 2023 for rugs/carpets/fabric; Jan 1, 2025 CAS reporting; full ban Jan 1, 2030 |
| Minnesota | Amara's Law | 11 product categories banned Jan 1, 2025; complete ban on intentionally-added PFAS Jan 1, 2032 |
| Illinois | Senate Bill 2705 | Full ban by 2032 |
| Kentucky | HB 116 | Notification requirements |
| California | Proposition 65 | Label requirements |
| Tennessee | Pending | Reviewing a bill for total ban as early as 2025 |
Given the amount of evidence pointing to the serious dangers associated with PFAS, many companies are moving to a stricter, more responsible stance on forever chemicals. Beginning in 2020, ChemSec, a nonprofit that advocates for the transition from toxic chemicals to safer alternatives, initiated a corporate PFAS movement. To date, well over 50 companies — including H&M, Lacoste, New Balance, and Ralph Lauren — have joined the initiative. Perhaps even more notably, 3M announced that it would be phasing out its production of PFAS, declaring it would work to discontinue the use of PFAS across its product portfolio by the end of 2025.
PFAS are currently difficult to track in the supply chain for two primary reasons: (1) None of the PFAS regulations define PFAS the same way, meaning the scope of what's being regulated by each governing body isn't entirely clear yet; and (2) Because the regulations are still being finalized, many manufacturers don't yet have the required Certificates of Compliance (CoCs) to share with customers. Z2's software solution empowers companies to effectively manage the design, supply chain, and sustainability of their products. Built upon the most comprehensive component database in the industry, Z2's solution gives teams the critical data they need to stay compliant with existing regulations like REACH and RoHS as well as new regulations related to PFAS. Z2 possesses the full material disclosures for approximately 70% of the components within its database.
Companies can utilize Z2 to not only procure Certificates of Compliance (CoCs) for parts but also determine compliance by leveraging Full Material Disclosures (FMDs) for these components. Z2 gives teams instant visibility into their BOM's compliance, all of which is backed by billions of data points and source documentation. With Z2, teams can easily see which parts are compliant, which aren't, and which ones need attention first, saving teams time and effort in their compliance processes.
Users directly upload their BOM(s) to the Z2 platform
Parts in the BOM are matched with compliance documentation in Z2
Instantly see which parts are compliant, non-compliant, or need attention
Upload your own documents or coordinate with Z2 to contact suppliers
Track PFAS alongside RoHS, REACH, and every other regulation across your entire BOM, backed by full material disclosures for the parts in your products.
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