How to Answer a Customer PFAS Questionnaire Without Overstating

Who reads a customer PFAS questionnaire answer, and what do they decide?

A customer PFAS questionnaire answer is read by the customer's product compliance or regulatory team, who use it to decide whether they have a reporting duty, a sales restriction or a substitution project. In the United States, any person that manufactured (including imported) PFAS or PFAS-containing articles for commercial purposes at any time from 1 January 2011 through 31 December 2022 falls under the TSCA section 8(a)(7) reporting rule (40 CFR 705.10, 2026). In Minnesota, the manufacturer of a product sold in the state must report intentionally added PFAS in that product, except products manufactured before 1 July 2023 (MPCA, 2026). Neither duty can be met without supplier information, so your answer becomes part of the customer's own compliance record.

The reviewer on the customer side usually decides three things from your PFAS answer. First, whether the product contains PFAS under the definition their rule uses. Second, whether the answer is complete enough to rely on, or whether they must ask again. Third, when they need to ask again. A reviewer who receives a yes or no without a definition, an evidence basis or a date cannot make any of these decisions, and the questionnaire comes back. Writing for that reviewer means stating limits plainly. An answer that says what is unknown is more useful to them than one that claims more than its evidence supports.

How should each section of a PFAS questionnaire answer be structured?

A PFAS questionnaire answer should have five sections in a fixed order, each stating one thing and naming the evidence held for it. The table below checks a PFAS answer before it goes to the customer.

The section most often missing from a PFAS answer is the fourth, evidence basis and limits. A statement that no PFAS is intentionally added, with nothing about limits, reads as a claim that every raw material has been checked. If one supplier has not replied, the limits section is where that gap belongs, in one sentence, with the share of the formulation it affects. Keep sections 2 and 3 separate: the definition decides what counts as PFAS, and the statement applies it to the product. When a customer form has no field for the definition or the limits, add them as a note on the form or in a cover letter rather than leaving them out.

Which PFAS definition should the answer state?

The answer should state the PFAS definition that the customer's rule uses, by name and source, because the main definitions cover different sets of substances. Three definitions matter most for chemical products sold into the US and Europe as of 2026-10-13. The table below shows which PFAS definition sits behind which question.

Minnesota's statute defines PFAS as "a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom" (Minn. Stat. 116.943, 2025). The TSCA definition is built on structure instead: a chemical substance must contain one of three named sub-structures, such as R-(CF2)-CF(R')R'' where both carbons are saturated (40 CFR 705.3, 2026). A molecule whose only fluorinated group is a single CF3 on an aromatic ring appears to meet the OECD and Minnesota wording but none of the three TSCA sub-structures (inference from the definition texts). The same raw material can therefore be a yes under one PFAS definition and a no under another. If the form names no definition, state the one you applied and offer the result under the others. Never write "PFAS-free" without naming the definition behind it.

Which rule is behind each PFAS questionnaire question?

Each common PFAS questionnaire question traces to a specific rule, and the answer should address that rule's test rather than give a generic yes or no. The table below maps the questions customers ask to the rule behind each one and its status as of 2026-10-13.

The first row decides the most for US customers. The TSCA section 8(a)(7) submission period begins on 31 January 2027 at the latest (Federal Register 2026-07062, 2026), so answers that cite the earlier 13 October 2026 deadline are out of date. TSCA asks for information "known to or reasonably ascertainable by" the reporter, which includes "all information that a reasonable person similarly situated might be expected to possess, control, or know" (40 CFR 705.3, 2026). Customers likely use supplier questionnaires to show that diligence (inference). Minnesota asks a different question: whether PFAS was deliberately added to perform a function. The EU universal PFAS restriction was still under ECHA committee evaluation in 2026 (ECHA, 2026), so an answer about it describes exposure to a possible rule, not compliance. Restrictions on specific PFAS already apply in the EU: PFHxA, its salts and related substances are restricted in mixtures supplied to the general public from 10 October 2026, at 25 ppb for PFHxA and its salts or 1 000 ppb for related substances, under REACH Annex XVII entry 79 (Regulation (EU) 2024/2462, 2024), so an EU answer should also state compliance with restrictions in force.

What evidence supports a no intentionally added PFAS statement?

A no intentionally added PFAS statement is supported by the full formulation down to CAS numbers, a dated supplier declaration for every raw material, and a record of what each declaration covers. Testing alone does not support it, because the statement is about why a substance is in the product, not how much of it is there.

Minnesota defines intentionally added as "PFAS deliberately added during the manufacture of a product where the continued presence of PFAS is desired in the final product or one of the product's components to perform a specific function" (Minn. Stat. 116.943, 2025). The test is function, so the evidence for a no intentionally added PFAS statement is formulation records and supplier statements on each ingredient's composition. MPCA states that PFAS contamination from recycled materials would not be considered intentionally added (MPCA, 2026).

Analytical results add to that evidence, but their limits belong in the answer. EPA Method 1633A tests for 40 PFAS compounds in wastewater, surface water, groundwater, soil, biosolids, sediment, landfill leachate and fish tissue (EPA, 2026). A non-detect speaks only to those 40 analytes, and a lubricant or cleaner is not one of the listed sample types (inference). EPA Method 1621 for adsorbable organic fluorine "tells the user that organofluorines are present but cannot identify which specific organofluorines are present" (EPA, 2026). If you cite any PFAS test, name the method, the analyte list, the reporting limit and the sample matrix.

How do you answer when a raw material supplier has not responded?

When a raw material supplier has not responded, answer for the raw materials you have evidence for, mark the missing one as unknown in the PFAS answer, and say how much of the product it represents. A missing reply is not a no.

Minnesota's PFAS reporting guidance gives a working model for this case. MPCA keeps the reporting duty with the manufacturer when a supplier is silent: "If a supplier is unresponsive, you must continue to request the required information and report using the best available information" (MPCA, 2026). The same guidance lists the steps after due diligence: continue requesting the information, document all outreach, report using the best available information, and use allowed unknown values where appropriate (MPCA, 2026). Records of that outreach must be kept for at least five years after the product is removed from the supply chain (MPCA, 2026).

The same habits work for a customer PFAS questionnaire under any rule. In the answer, name the raw material by function rather than by supplier, give its share of the formulation, state the date of your first request and the follow-ups, and say what you will do when the reply arrives. If the material's function makes PFAS unlikely, you can say so as an inference with the reason, but keep its status as unknown. Customers can work with a bounded gap. They cannot work with a no that later turns out to be a guess.

Example PFAS questionnaire answer (illustrative)

The example below is an illustrative PFAS questionnaire answer for a water-based industrial degreaser, with each statement marked known, inferred or unknown. The product name, raw material counts, percentages and dates are illustrative and do not come from a real case. The table shows the statements as they would appear in the answer (illustrative):

The key row in this illustrative PFAS answer is the corrosion inhibitor: the answer says its status is unknown for a component at 0.2% w/w (illustrative), records the outreach, and gives the inference separately with its reason. A customer screening at 0.1% can see that the unknown component could matter at their threshold and decide whether to ask for more (illustrative). The answer to "Is PFAS intentionally added?" then reads: not in 11 of 12 raw materials; unknown for one corrosion inhibitor blend, follow-up open. That sentence is longer than a plain "No", and it is accurate.

How often should a PFAS declaration be renewed?

A PFAS declaration should be renewed on a fixed review date and whenever the formulation, a supplier or a rule changes, whichever comes first. No regulation reviewed here sets one renewal period for customer declarations (inference from the rules reviewed here), so customer forms set their own. One published supplier PFAS declaration form asks suppliers to re-submit "in the event of changes to the declaration or no less than 24 months after the 'Signature date'" (Camira Fabrics, FORM-COMP-046 R1, accessed 2026).

Rule events are the more urgent trigger for renewing a PFAS declaration as of 2026-10-13. EPA expects its final rule on the substance of TSCA section 8(a)(7) reporting, which may change exemptions and the reporting period, to be issued before 31 January 2027 (Federal Register 2026-07062, 2026). Updates to Minnesota PFAS in products reports, when required, are due each year on 1 February (MPCA, 2026). The EU universal PFAS restriction was still before ECHA's committees in 2026 (ECHA, 2026).

A practical rule is to put a review date on every PFAS answer that falls no later than the next known rule event, and to tie the declaration to change control so that a raw material or supplier change triggers a new answer before shipment. Stating the review date in the answer also tells the customer when the inferred and unknown items will be revisited.

Why do PFAS questionnaire answers fail customer review?

PFAS questionnaire answers often fail customer review for five reasons: no definition, a yes or no that hides unknowns, a test result used as proof of absence, a screening value treated as law, and stale rule dates. Each overstates what the supplier knows.

The first is the missing definition. A "PFAS-free" claim without a named definition cannot be checked, because the OECD 2021, US TSCA and Minnesota definitions cover different substances (OECD, 2021; 40 CFR 705.3, 2026; Minn. Stat. 116.943, 2025).

The second is the silent supplier answered as a no. MPCA's guidance treats an unresponsive supplier as a gap to report with the best available information and allowed unknown values, not as a negative (MPCA, 2026).

The third is a test report stretched too far. A targeted method such as EPA Method 1633A covers 40 named PFAS compounds (EPA, 2026), so a non-detect does not show that other PFAS are absent (inference).

The fourth is a screening value presented as a legal limit. Some customer forms ask about PFAS above 0.1% w/w (Camira Fabrics, FORM-COMP-046 R1, accessed 2026), and EPA proposed a 0.1% de minimis exemption for TSCA reporting (Federal Register 2025-19882, 2025). That exemption is not final, and Minnesota's intentionally added test turns on function, not concentration (Minn. Stat. 116.943, 2025).

The fifth is a stale date. Answers citing a TSCA PFAS deadline of 13 October 2026 are out of date; submissions now start on 31 January 2027 at the latest (Federal Register 2026-07062, 2026).

PFAS questionnaire answer checklist

Run this PFAS questionnaire answer checklist before the answer goes to the customer. Each line should be true of the final document.

• The products, codes, formulation revision and site are named, and the answer covers nothing else.

• The PFAS definition is named with its source, and the answer says which definition each statement uses.

• The intentional-use statement is kept separate from any statement about presence or concentration.

• Every raw material has a status of known, inferred or unknown, with the basis for each.

• Each unknown item gives the component's function, its share of the formulation and the outreach dates.

• Each inference gives its reason in the same sentence and is not counted as known.

• Any test cited names the method, the analyte list, the reporting limit and the sample matrix.

• Any concentration threshold is attributed to the customer form or to a named rule, never presented as universal.

• Rule dates were checked on the official source on the date of the answer.

• The answer carries its own date, a review date and the change events that trigger a new answer.

• The signatory can show the evidence for each section on request.

Lubinpla works from a company's own documents, such as SDS, TDS and supplier certificates, and returns one cited document for review, with the user approving each step.