PFAS Quietly Reaches 60% of Specialty Chemicals by 2028

Summary: The per- and polyfluoroalkyl substances (PFAS) regulatory perimeter has shifted from a class-of-concern conversation in 2021 to an enforced market access constraint in 2026. Five EU Member States have advanced a universal REACH restriction covering the entire PFAS class (estimated 10,000 substances), the US EPA designated PFOA and PFOS as CERCLA hazardous substances effective July 2024, and the TSCA Section 8(a)(7) reporting window closes October 13, 2026. Maine (LD 1503) and Minnesota (Amara's Law) add concrete sales-ban dates between 2025 and 2032. This article reconstructs the timeline at category resolution, quantifies the share of specialty-chemical SKUs exposed to one or more instruments, examines the performance penalty of non-fluorinated substitutes, and translates the total cost of ownership for a manufacturer with USD 80 to 250 million in revenue. The conclusion is that reformulation is no longer a five-year R&D project. It is a portfolio decision compressed into a 24 to 30 month window beginning in 2026, with roadmaps that diverge sharply between coatings, lubricants, surfactants, adhesives, and water-treatment chemistries. It closes with a crosswalk mapping each instrument to the affected category and the required operator action.

Table of Contents

I. Why the PFAS Migration Is Now an Operating Question, Not a Research Question

II. Regulatory Timeline: EU REACH, US EPA, State-Level Bans

III. What Performance Does a Specialty Chemical Lose When PFAS Is Removed?

IV. What Does Reformulation Actually Cost a Mid-Size Manufacturer?

V. Reformulation Strategy by Product Category

VI. Key Takeaway

VII. References

I. Why the PFAS Migration Is Now an Operating Question, Not a Research Question

The Committee for Risk Assessment of the European Chemicals Agency adopted its final opinion on the universal REACH PFAS restriction on March 3, 2026, and the Socio-Economic Analysis Committee issued its draft opinion on March 10, 2026, with the European Commission expected to draft binding legislation for a member-state vote in early 2027 (ECHA, 2026). At the same point on the calendar, the US Environmental Protection Agency has confirmed it will defend the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance designation for perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), in force since July 8, 2024 (Holland and Knight, 2025). Two state statutes, Maine's LD 1503 and Minnesota's Amara's Law, already removed certain product categories from the market on January 1, 2025 and January 1, 2026 (Maine DEP, 2025; Minnesota MPCA, 2026).

For a specialty chemical manufacturer, the operational consequence of this convergence is that the substitution catalog and the regulatory clock are no longer matched. Independent assessment of PFAS-free fluoropolymer alternatives shows that silicone-based replacements reach 108 to 111 degrees water contact angle against a fluoropolymer baseline of 110 to 120 degrees, but their hexadecane (oil) contact angle of 47 to 52 degrees falls below the fluoropolymer benchmark of 70 to 75 degrees (Glüge et al., 2024). The implication is that a portfolio of stock keeping units (SKUs) cannot be migrated by a single drop-in substitute. Each application class requires its own reformulation pathway, and the available pathways do not all close before the regulatory deadlines.

Lubinpla is a specialty chemical AI agent company that serves chemical manufacturers, distributors, and plant operators through two products: AI Shooting, a per-case specialty chemicals analysis service that returns an evidence-based written report for a single submitted problem, and AI Crew, a subscription platform of specialized AI agents that run technical-sales, customer-support, and operations workflows continuously inside the customer's data environment. This article is written for purchasing leads, product managers, and process engineers at chemical companies who must decide which SKUs to reformulate, which to defend under a derogation, and which to retire before 2028.

II. Regulatory Timeline: EU REACH, US EPA, State-Level Bans

The three regulatory instruments with binding force on specialty-chemical portfolios in the 2026 to 2028 window are the EU REACH universal restriction proposal, the US EPA CERCLA hazardous substance designation together with the TSCA Section 8(a)(7) reporting rule, and the Maine and Minnesota state statutes. Each carries a different mechanism of action: REACH limits placing-on-market, CERCLA creates retroactive cleanup liability for historic releases, TSCA mandates information disclosure, and the state laws impose direct sales bans by product category. A manufacturer exposed to all three is exposed to four independent enforcement clocks.

What Does the EU REACH Universal PFAS Restriction Actually Restrict?

The REACH dossier was submitted on January 13, 2023 by the competent authorities of Germany, the Netherlands, Sweden, Denmark, and Norway, and proposes restriction of approximately 10,000 substances under the Organisation for Economic Co-operation and Development (OECD) 2021 definition of PFAS (ECHA, 2023; OECD, 2021). The OECD 2021 definition specifies any fluorinated substance containing at least one fully fluorinated methyl or methylene carbon atom without hydrogen, chlorine, bromine, or iodine attached, which expanded the 2011 Buck definition that required two or more connected saturated CF2 groups (OECD, 2021).

The structure of the restriction is a general 18-month transition period from entry into force for restriction options RO1 and RO2, followed by use-specific derogations of five years for medium-feasibility substitutions, 12 years for difficult substitutions, and 13.5 years for cases where alternatives have not yet been identified or require certification cycles longer than 6.5 years (Linklaters, 2025). The updated August 2025 dossier identified 74 derogated uses, up from 26 in the 2023 version, including additions for printing, sealing, and medical applications (Linklaters, 2025; ECHA, 2026).

Which US EPA Instruments Apply, and What Is the October 13, 2026 TSCA Deadline?

The US EPA designated PFOA and PFOS as hazardous substances under CERCLA Section 102(a) in a final rule issued May 8, 2024 with effective date July 8, 2024, the first time the agency used Section 102(a) to designate substances not already listed under another environmental statute (US EPA, 2024). The CERCLA designation creates retroactive joint-and-several liability for historic releases at concentrations triggering the reportable quantity of one pound. The agency confirmed on September 17, 2025 that it will continue to defend this designation in litigation (Holland and Knight, 2025).

The TSCA Section 8(a)(7) PFAS reporting rule requires any entity that manufactured or imported PFAS in any year between 2011 and 2022 to submit chemical identity, use, volume, byproduct, environmental and health effect, worker exposure, and disposal information to the EPA. After an interim final rule on May 13, 2025, the data submission window opens April 13, 2026 and closes October 13, 2026 for most reporters, with a small-business article importer extension to April 13, 2027 (US EPA, 2026; Faegre Drinker, 2025).

Which US State Laws Are Already Removing Categories From the Market?

Minnesota's Amara's Law (Minnesota Statutes Section 116.943), effective January 1, 2025, bans intentionally added PFAS in cleaning products, cookware, cosmetics, dental floss, juvenile products, menstrual products, fabric treatments, ski wax, carpets and rugs, and upholstered furniture, with indoor textile furnishings added January 1, 2026 and a broader prohibition advancing in 2032 unless a Currently Unavoidable Use designation is granted (Minnesota MPCA, 2026). Maine's LD 1503 ban took effect January 1, 2026 for cleaning products, cookware, cosmetics, juvenile products, and additional categories, with artificial turf and severe-weather outdoor apparel added January 1, 2029, and a near-universal ban on intentionally added PFAS effective January 1, 2032 (Maine DEP, 2025).

Figure 1. Stacked Regulatory Clock 2024 to 2032

Instrument	Effective date	Mechanism	Specialty-chemical scope
CERCLA PFOA/PFOS designation	2024-07-08	Retroactive cleanup liability, reportable quantity 1 lb	Historic releases from coating, lubricant, and surfactant plants
Minnesota Amara's Law tier 1	2025-01-01	Sales ban	Cleaning, cookware, cosmetics, fabric treatment, ski wax
Maine LD 1503 tier 1	2026-01-01	Sales ban	Cleaning products, cookware, cosmetics, juvenile products
TSCA Section 8(a)(7) reporting window opens	2026-04-13	Mandatory disclosure 2011 to 2022	All manufacturers and importers of PFAS substances
TSCA Section 8(a)(7) deadline	2026-10-13	Reporting close	All non-small-business reporters
EU REACH restriction expected adoption	early 2027	Placing-on-market restriction with derogations	All 10,000 OECD-defined PFAS, 74 derogated uses
EU REACH 18-month transition expires	mid 2028	Most non-derogated uses banned	Coatings, surfactants, textile treatments, food contact
Maine LD 1503 tier 2	2029-01-01	Sales ban extension	Artificial turf, severe-weather outdoor apparel
EU 5-year derogation expires for medium-feasibility uses	early 2032	Restriction applies	Mid-difficulty substitutions
Maine and Minnesota near-universal ban	2032-01-01	Sales ban (intentionally added)	All categories without Currently Unavoidable Use designation

The cumulative effect of stacking these instruments is that a substantial portion of the 2025 specialty-chemical stock-keeping list will be either non-compliant or compliant only under a derogation by 2028. A worked estimate, based on the OECD 2021 definition's expansion of the PFAS universe to over seven million PubChem entries and the Beroe and Patsnap analyses indicating that fluorinated chemistry is embedded in approximately 60 percent of industrial coatings, lubricants, and surfactant lines (Beroe, 2024; Patsnap, 2026), suggests the 60 percent exposure figure cited in the title is consistent with a mid-case scenario rather than a worst case. Companies should treat the 60 percent figure as a portfolio audit trigger, not a forecast.

III. What Performance Does a Specialty Chemical Lose When PFAS Is Removed?

The performance gap between PFAS chemistry and the available non-fluorinated alternatives is not uniform across applications. PFAS achieves three properties simultaneously, oleophobicity, hydrophobicity, and thermal stability above 200 degrees Celsius, and no single non-fluorinated chemistry replicates all three (Glüge et al., 2024). Reformulation, in practice, means accepting a specific performance reduction in exchange for compliance, and the engineering question is which performance metric the application can tolerate losing.

How Large Is the Performance Gap by Substitute Class?

Silicone-based polymers and polysiloxanes reach 108 to 111 degrees water contact angle against the PFAS baseline of 110 to 120 degrees, which is acceptable for most water repellency requirements (Glüge et al., 2024). The same class achieves 47 to 52 degrees hexadecane contact angle against a PFAS reference of 70 to 75 degrees, which is a material loss in oil and grease resistance and disqualifies silicones from food packaging applications that require fat barrier performance (Glüge et al., 2024). Organosilane surface treatments perform similarly on water and similarly poorly on oil.

Bio-based hydrophobic coatings derived from waxes and natural lipids reach lower thermal-stability ceilings, typically 120 to 150 degrees Celsius, against PFAS resistance to 250 degrees and above (Patsnap, 2026). Ceramic and sol-gel coatings retain thermal stability but require curing temperatures and substrate adhesion conditions that limit retrofit compatibility with existing application lines.

Figure 2. Performance Trade-off Map for Non-Fluorinated Substitutes

Substitute class	Repellency: water / oil (contact angle)	Thermal ceiling	Cost premium vs. PFAS baseline
PFAS fluoropolymer (reference)	110 to 120 deg / 70 to 75 deg	>250 deg C	0% (baseline)
Silicone-based polymer	108 to 111 deg / 47 to 52 deg	200 deg C	15 to 35% premium (FactMR, 2026)
Organosilane surface treatment	100 to 110 deg / 40 to 50 deg	180 deg C	10 to 25% premium
Bio-based wax coating	95 to 105 deg / 35 to 45 deg	120 to 150 deg C	5 to 20% premium
Ceramic / sol-gel	90 to 105 deg / 40 to 50 deg	>300 deg C	25 to 45% premium
Polyolefin barrier film	95 to 100 deg / 30 to 40 deg	100 to 130 deg C	5 to 15% premium

*Figure 3. Where the substitution penalty actually lands (range midpoints). Non-fluorinated chemistries hold water repellency close to the fluoropolymer reference; the gap is oil repellency, which is why oil-critical applications are the hard cases.*

The interpretation of the figure is that water-repellency-driven applications (textile water resistance, roofing membranes, automotive exterior coatings) can in most cases be migrated to silicone or organosilane chemistry without intolerable property loss. Combined oil-and-water repellency applications (food packaging fat barriers, industrial release coatings, firefighting foams) cannot. Thermal-extreme applications (semiconductor processing chemistry, aerospace fluids, high-temperature lubricants) require ceramic, sol-gel, or unlimited derogations under the EU restriction.

Which Analytical Standards Verify Reformulated Products Are Compliant?

Two analytical standards anchor compliance verification: ASTM D7979-20 specifies determination of selected PFAS in non-potable water, sludge, influent, effluent, and wastewater by liquid chromatography tandem mass spectrometry (LC-MS/MS), and is the first validated method for non-drinking-water aqueous matrices developed by the US EPA Region 5 Laboratory (ASTM International, 2020). ISO 21675:2019 specifies determination of PFAS in non-filtrated waters including drinking water, fresh water, sea water, and waste water containing less than 2 grams per liter solid particulate using solid-phase extraction and LC-MS/MS, validated for up to 30 PFAS depending on water type at a limit of quantification of 0.2 nanograms per liter or better (ISO, 2019). Reformulators should confirm with their analytical laboratory which method is used in the regulatory jurisdiction that governs the destination market, because EPA Method 537.1, EPA Method 1633, ASTM D7979, and ISO 21675 are not freely interchangeable across matrices.

IV. What Does Reformulation Actually Cost a Mid-Size Manufacturer?

For a specialty chemical manufacturer with USD 80 to 250 million in annual revenue and approximately 150 to 600 SKUs, the cost of PFAS migration is the sum of four cost categories: reformulation research and development, raw material premium, application-line revalidation, and customer requalification. Industry analysis indicates PFAS-free materials carry a 15 to 35 percent price premium against the fluorinated baseline (FactMR, 2026). Reformulation R&D for a single SKU in a coatings, lubricant, or surfactant line typically runs USD 80,000 to 250,000 depending on substrate validation requirements, with timelines of 12 to 24 months per SKU (Patsnap, 2026; worked estimate based on cited substitution case timelines).

How Should a Mid-Size Manufacturer Sequence the Reformulation Spend?

The dominant variable is whether the SKU is exposed to a sales-ban regulatory instrument (Maine, Minnesota, EU REACH) or a liability and disclosure instrument (US EPA CERCLA and TSCA). Sales-ban exposure forces SKU retirement or reformulation by a hard date. Liability and disclosure exposure forces a portfolio audit, an emissions inventory, and historic-release accounting, but does not by itself force product withdrawal. The first cost-sequencing decision is therefore to triage the SKU portfolio by regulatory mechanism, not by revenue contribution. A high-revenue SKU exposed only to TSCA can be reformulated on a 36-month track, whereas a low-revenue SKU exposed to Maine LD 1503 tier 1 must be retired or reformulated by January 1, 2026.

Figure 4. TCO Snapshot for a Representative Mid-Size Reformulation Program

Cost category	Per-SKU range	Portfolio assumption	Total range
R&D and lab-scale formulation	USD 80,000 to 250,000	30 SKUs reformulated of 200 total	USD 2.4 to 7.5 million
Raw material premium (annual)	15 to 35% of input cost	USD 25 million PFAS input cost	USD 3.75 to 8.75 million per year
Application-line revalidation	USD 50,000 to 150,000 per line	5 production lines affected	USD 0.25 to 0.75 million
Customer requalification (per major account)	USD 20,000 to 60,000	12 major accounts	USD 0.24 to 0.72 million
Discontinued SKU stranded inventory write-off	0.5 to 2% of annual revenue	USD 150 million revenue base	USD 0.75 to 3.0 million
Cumulative two-year program (mid-case)			USD 12 to 18 million

The TCO model deliberately excludes CERCLA cleanup liability, which is event-driven and not predictable on a manufacturing-line budget. A manufacturer with documented historic PFOA or PFOS use at a US site should treat the CERCLA exposure as a separate risk register item with its own contingency reserve, and should consult environmental counsel rather than relying on a reformulation budget line.

What Does the Reformulation Spend Buy?

The strategic output is preserved market access in EU, US federal, and US state jurisdictions through 2032, an updated safety data sheet portfolio aligned to the post-restriction regulatory environment, and a stronger position in customer-driven sustainability audits that increasingly include PFAS disclosure questionnaires. The spend does not buy a property-equivalent replacement for the most demanding PFAS applications, and manufacturers serving those niches should plan their derogation strategy in parallel with the reformulation program rather than as a fallback.

V. Reformulation Strategy by Product Category

Reformulation strategy must be set at category resolution because the regulatory instruments do not affect categories uniformly and the substitute pathways do not perform uniformly. The Compliance Crosswalk below maps each regulatory instrument to the product category it most directly constrains and to the corresponding operator action.

Figure 5. Compliance Crosswalk: Regulation x Product Category x Required Action

Product category	EU REACH restriction (effective mid-2028)	US federal and state exposure	Required operator action
Industrial coatings and surface treatments	In scope, 18-month transition for non-derogated uses	TSCA reporting + potential CERCLA liability at plant sites. Maine LD 1503: Out of tier 1; in scope by 2032. Minnesota Amara's Law: Out of tier 1; in scope by 2032	Reformulate to silicone or sol-gel where oil-resistance is non-critical; file derogation for high-thermal applications
Specialty lubricants and hydraulic fluids	In scope, derogation likely for aerospace and high-temperature uses (OECD, 2025)	TSCA reporting. Maine LD 1503: Out of scope (industrial). Minnesota Amara's Law: Out of scope (industrial)	Audit thermal stability requirement; reformulate ester or polyalphaolefin where ceiling <=200 deg C; document derogation case for >200 deg C uses
Surfactants and emulsifiers	In scope, no general derogation	TSCA reporting. Maine LD 1503: Indirect via cleaning products tier 1 (2026). Minnesota Amara's Law: Tier 1 cleaning products (2025)	Reformulate to non-fluorinated surfactant chemistry on 18 to 24 month timeline; verify by ASTM D7979 or ISO 21675
Adhesives and sealants	In scope, derogation proposed for sealing applications (Linklaters, 2025)	TSCA reporting. Maine LD 1503: Out of tier 1. Minnesota Amara's Law: Out of tier 1	Maintain fluorinated chemistry only under documented sealing derogation; transition non-sealing adhesives
Food contact and packaging treatments	In scope, no derogation expected	TSCA reporting. Maine LD 1503: Out of tier 1 (cookware in tier 1). Minnesota Amara's Law: Out of tier 1 (cookware in tier 1)	Reformulate to bio-based wax or polyolefin barrier; accept reduced thermal ceiling
Water treatment chemistries	In scope (process chemicals); destruction technologies exempt	CERCLA liability for releases. Maine LD 1503: Out of scope. Minnesota Amara's Law: Out of scope	Audit PFAS content in flocculants, antifoams, scale inhibitors; switch to non-fluorinated equivalents
Textile treatments and fabric finishes	In scope, no general derogation	TSCA reporting. Maine LD 1503: Tier 1 (fabric treatments). Minnesota Amara's Law: Tier 1 (fabric treatments, ski wax)	Reformulate to silicone or organosilane; verify oil-repellency loss is acceptable to customer
Cosmetic and personal care chemistry	In scope, no derogation expected	TSCA reporting. Maine LD 1503: Tier 1 (2026). Minnesota Amara's Law: Tier 1 (2025)	Discontinue fluorinated ingredients or reformulate within 12 months

Which Strategic Posture Should Each Category Take?

Coatings and adhesives manufacturers should pursue a dual-track strategy: reformulation for mass-market applications and derogation filing for high-performance niches. Lubricants and hydraulic fluid manufacturers should focus reformulation effort on the medium-temperature segment, because the EU restriction is expected to grant time-limited or unlimited derogations for high-temperature aerospace and turbine applications where alternatives are not yet qualified (OECD, 2025). Surfactant and cosmetic chemistry manufacturers should treat the state-level deadlines as the binding constraint and pull reformulation timelines into 2025 to 2026, not 2028. Water treatment chemistry manufacturers should audit their existing flocculant and antifoam portfolios against the OECD 2021 PFAS definition, because the expanded definition captures substances that were not flagged under the 2011 Buck definition.

The single highest-leverage action across all categories is the SKU-level portfolio audit. Without a documented map of which SKUs contain OECD-defined PFAS, which jurisdictions they ship into, and which regulatory clock applies, no reformulation budget can be sized accurately and no derogation filing can be prepared in time.

VI. Key Takeaway

• Treat the 60 percent specialty-chemical PFAS exposure figure as a portfolio audit trigger to be confirmed at SKU level, not as a forecast. Begin the audit against the OECD 2021 definition, not the 2011 Buck definition.

• Sequence reformulation spend by regulatory mechanism, not by revenue. SKUs exposed to Maine or Minnesota sales bans must move first, followed by EU REACH non-derogated uses, then TSCA-only and CERCLA-only exposures.

• Plan for a 15 to 35 percent raw material premium on non-fluorinated substitutes and a 12 to 24 month reformulation cycle per SKU. Mid-size manufacturers should budget USD 12 to 18 million across a two-year program covering approximately 30 reformulated SKUs.

• Accept that no single substitute class replicates the combined oleophobicity, hydrophobicity, and thermal stability of PFAS. Choose the property the application can afford to lose and select the substitute class on that basis.

• File derogations in parallel with reformulation for any application where the 18-month EU transition period is insufficient. Treat unlimited and 13.5-year derogations as documented strategic positions, not as a fallback.

• Verify reformulated products with ASTM D7979 or ISO 21675 LC-MS/MS analysis. Confirm which method is required by the destination jurisdiction before submitting to a contract laboratory.

AI Shooting can map a specialty-chemical SKU portfolio against the current PFAS restriction proposals and the OECD 2021 definition, returning a written category-level exposure report with citations to the EU REACH dossier, US EPA rules, and Maine and Minnesota statutes. The standards summary and full regulatory text are also available through the European Chemicals Agency public consultation page at https://echa.europa.eu/restrictions-under-consideration/-/substance-rev/72301/term and the US EPA TSCA Section 8(a)(7) reporting hub at https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping.

VII. References

ASTM International. (2020). *ASTM D7979-20 Standard Test Method for Determination of Per- and Polyfluoroalkyl Substances in Water, Sludge, Influent, Effluent, and Wastewater by Liquid Chromatography Tandem Mass Spectrometry (LC/MS/MS)*. ASTM International, West Conshohocken, PA. https://store.astm.org/d7979-20.html

Beroe Inc. (2024). *Potential safer substitutes for PFAS (Forever Chemicals)*. Beroe Market Intelligence. https://www.beroeinc.com/resource-centre/insights/potential-safer-substitutes-pfas-forever-chemicals/

European Chemicals Agency. (2023, February 7). *ECHA publishes PFAS restriction proposal*. ECHA News. https://echa.europa.eu/-/echa-publishes-pfas-restriction-proposal

European Chemicals Agency. (2026, March). *ECHA Committees Advance Broad PFAS Restriction Under REACH: RAC final opinion adopted 3 March 2026, SEAC draft opinion 10 March 2026*. ECHA. https://www.echa.europa.eu/-/echa-publishes-updated-pfas-restriction-proposal

Faegre Drinker Biddle and Reath LLP. (2025, May). *EPA Extends TSCA 8(a)(7) PFAS Reporting to October 2026*. Faegre Drinker Publications. https://www.faegredrinker.com/en/insights/publications/2025/5/epa-extends-tsca-8a7-pfas-reporting-to-october-2026

FactMR. (2026). *PFAS-Free Fluoropolymer Alternatives Market Size, Share and Forecast to 2036*. FactMR Industry Reports. https://www.factmr.com/report/pfas-free-fluoropolymer-alternatives-market

Glüge, J., Scheringer, M., Cousins, I. T., DeWitt, J. C., Goldenman, G., Herzke, D., Lohmann, R., Ng, C. A., Trier, X., and Wang, Z. (2024). From "forever chemicals" to fluorine-free alternatives: Identifying alternatives to PFAS requires weighing trade-offs and uncertainties. *Environmental Science and Policy*. https://pmc.ncbi.nlm.nih.gov/articles/PMC11313905/

Holland and Knight LLP. (2025, October). *EPA's PFAS Rulemaking Trajectory: Key Updates Across CERCLA, TSCA, RCRA, SDWA and CWA*. Holland and Knight Insights. https://www.hklaw.com/en/insights/publications/2025/10/epas-pfas-rulemaking-trajectory-key-updates

International Organization for Standardization. (2019). *ISO 21675:2019 Water quality - Determination of perfluoroalkyl and polyfluoroalkyl substances (PFAS) in water - Method using solid phase extraction and liquid chromatography-tandem mass spectrometry (LC-MS/MS)*. ISO, Geneva. https://www.iso.org/standard/71338.html

Linklaters LLP. (2025, August). *Revision of EU PFAS restriction proposal: New approach or continuity?* Sustainable Futures. https://sustainablefutures.linklaters.com/post/102l4do/revision-of-eu-pfas-restriction-proposal-new-approach-or-continuity

Maine Department of Environmental Protection. (2025, December). *PFAS in Products: LD 1503 Implementation and Phase-Out Schedule*. State of Maine DEP. https://www.maine.gov/dep/spills/topics/pfas/PFAS-products/

Minnesota Pollution Control Agency. (2026). *PFAS in products: Amara's Law (Minnesota Statutes Section 116.943)*. MPCA. https://www.pca.state.mn.us/get-engaged/pfas-in-products

Organisation for Economic Co-operation and Development. (2021). *Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances: Recommendations and Practical Guidance* (ENV/CBC/MONO(2021)25). OECD Publishing, Paris. https://www.oecd.org/en/publications/reconciling-terminology-of-the-universe-of-per-and-polyfluoroalkyl-substances_e458e796-en.html

Organisation for Economic Co-operation and Development. (2025, June). *Per- and Polyfluoroalkyl Substances (PFAS) and Alternatives in Hydraulic Oils and Lubricants*. OECD Series on Risk Management. https://www.oecd.org/content/dam/oecd/en/publications/reports/2025/06/per-and-polyfluoroalkyl-substances-pfas-and-alternatives-in-hydraulic-oils-and-lubricants_14f25ee8/fed2872b-en.pdf

Patsnap. (2026). *PFAS-free fluoropolymer alternatives in 2026: technology landscape and substitution pathways*. Patsnap Research. https://www.patsnap.com/resources/blog/articles/pfas-free-fluoropolymer-alternatives-in-2026/

US Environmental Protection Agency. (2024, May 8). *Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances; Final Rule*. 89 Federal Register 39124. https://www.epa.gov/superfund/designation-perfluorooctanoic-acid-pfoa-and-perfluorooctanesulfonic-acid-pfos-cercla

US Environmental Protection Agency. (2026). *TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances*. US EPA Chemicals under TSCA. https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping