Written on: July 1, 2026 by Nicholas Georges
Fluorinated organic compounds, once recognized for their unique chemical properties, are now broadly categorized as PFAS (per- and polyfluoroalkyl substances).i Regulatory scrutiny of this diverse class of chemicals now extends across a wide range of products, including sprays, making PFAS a critical issue for formulators, raw material suppliers, packaging engineers and marketers.
For manufacturers of personal care products, household products, lubricants, paints and coatings, pesticides and automotive products, PFAS is no longer a future concern—it is a present-day business challenge reshaping the marketplace.
A growing patchwork of State laws, evolving retailer requirements, increasing litigation risk and heightened consumer awareness are transforming the regulatory and commercial landscape at an accelerating pace.
As of early 2026, PFAS restrictions and reporting requirements for cleaning and personal care products had already taken effect in several States, including Colorado, Connecticut, Illinois, Maine, Minnesota and Vermont. Additional requirements are expected in Maryland, New Jersey, New Mexico and Washington State, while existing State programs are poised to expand over time.
For companies selling products nationally in the U.S., the challenge is clear: regulations enacted in one State often become the de facto national standard. Maintaining separate formulations, distribution channels and compliance systems for different States is often impractical. As a result, many companies have already reformulated—or are actively reformulating—products nationwide to avoid fluorinated organic chemistries.
While States are driving much of the regulatory activity, Federal oversight continues to expand. The U.S. Environmental Protection Agency (EPA) is increasing PFAS-related reporting and oversight activities, including risk-management requirements under the Toxic Substances Control Act (TSCA), adding PFAS chemicals to the Toxics Release Inventory (TRI) and proposing to include PFAS as a class in the draft Sixth Contaminant Candidate List (CCL 6) under the Safe Drinking Water Act.
Retailers are also influencing the marketplace by requiring suppliers to certify that products are PFAS-free or contain no intentionally added PFAS. In some cases, these requests extend deep into the supply chain, creating compliance challenges for manufacturers because PFAS may be introduced through upstream chemistries, raw materials, manufacturing processes or inadvertent contamination.
Complicating matters further are inconsistent regulatory definitions and the lack of validated testing methodologies in complex matrices. Depending on the jurisdiction, PFAS may refer to several thousand, or more than 15,000, compounds. Some regulations focus on intentionally added PFAS, though definitions of “intentionally added” vary significantly. Others rely on detectable fluorine thresholds. Certain jurisdictions exempt fluoropolymers or substances listed under the EPA’s Significant New Alternatives Policy (SNAP) Program—including aerosol propellants—while others make no distinction among different categories of fluorinated chemistry.
This fragmentation creates substantial compliance complexity. Faced with uncertainty, some companies are pursuing the simplest path forward: eliminating fluorinated chemistries wherever technically feasible.
Increasingly, that decision is driven by more than regulatory compliance alone. Companies are positioning fluorine-free technologies as part of broader sustainability and risk-management strategies, emphasizing reduced regulatory burden and litigation exposure. As a result, marketing products as “PFAS-free” may become an increasingly common market expectation.
However, reformulation is rarely straightforward. Fluorinated organic chemistries often provide performance characteristics that are difficult to replicate, forcing manufacturers to evaluate trade-offs among cost, performance and/or processing.
For many companies, the key questions have become practical ones:
Companies that can confidently answer these questions will be better positioned to navigate an increasingly complex regulatory environment. While the details of PFAS regulation will continue to evolve, the uncertainty surrounding PFAS is unlikely to disappear anytime soon.
The Household & Commercial Products Association (HCPA) recently developed a PFAS Compliance Tool & Primer designed to help companies understand and manage their regulatory obligations. To learn more, please contact me at ngeorges@thehcpa.org. SPRAY
i The regulatory definition for PFAS varies based on jurisdiction, but the most restrictive definition is one fully fluorinated carbon atom. Fluorinated organic compounds that don’t have at least one fully fluorinated carbon atom are not considered as PFAS under any jurisdiction.
