You may not see it in your top-line risk reports, but PFAS could quietly derail your operations, supply chain, or reputation. Known as “forever chemicals” for their persistence in the environment, PFAS (per- and polyfluoroalkyl substances) have been widely used in manufacturing for decades to impart water, grease, and stain repellency, thermal and chemical stability, low friction, and surface-active properties. PFAS are integral to the performance and durability of thousands of products across industries.  
  
Until recently, most manufacturers viewed PFAS as a future issue. But in 2025, that mindset is no longer enough. With increasing global regulations, public scrutiny, and litigation, PFAS has become a strategic business risk.  

One of the biggest misconceptions manufacturers still hold is that if PFAS aren’t listed in Safety Data Sheets (SDS), they must not be present at significant concentrations. This assumption overlooks both the regulatory and material complexities of PFAS. In reality, most PFAS aren’t legally required to be listed because they haven’t been classified as hazardous. PFAS can also show up unintentionally in materials like recycled plastics or biosolids, making them easy to overlook. These are materials that contain PFAS not because they impart a specific performance characteristic, but because of their origin. Manufacturers also often misunderstand the distinction between “intentionally added” PFAS, which are deliberately added to deliver properties like durability or chemical resistance, and PFAS that are present incidentally. This nuance is critical. Even if a company does not deliberately use PFAS, they may still be exposed to risk through upstream materials or processes, creating hidden liabilities.  

Real-world cases underscore the danger of this blind spot. Several U.S. manufacturers have faced lawsuits over PFAS contamination in local drinking water, even when they didn’t produce PFAS themselves. In Europe, consumer goods brands have had to recall products after discovering fluorinated compounds in packaging, which were introduced by third-party suppliers without the brands’ knowledge. There are cost effective, proactive steps your business can take to minimize current and future PFAS-related business risks.  

As our understanding of PFAS pollution's harmful effects increases, the issue is gaining more attention. A ChemSec report estimated the global societal cost of PFAS pollution at €16 trillion, primarily from cleanup, health impacts, and lost productivity. Governments are therefore ramping up action. In the U.S., the Environmental Protection Agency (EPA) has designated certain PFAS compounds as hazardous under CERCLA, paving the way for broader liability enforcement. Meanwhile, Europe is considering a near-total ban on the production, use and sale of PFAS. What makes this different from typical chemical regulation? It potentially affects the whole class of over 10,000 PFAS compounds and could impact the sales of thousands of products where PFAS are knowingly or unknowingly used.  
  
In 2025, one of the most urgent regulatory developments is the EU’s REACH restriction proposal, which could ban over 10,000 PFAS compounds.  If passed, the restriction could ban many uses of PFAS within the next 3 years, with longer exemptions – up to an additional 18 years –  for others. In the U.S., many states are taking the lead by banning or restricting PFAS in specific product categories such as firefighting foam, children’s products, and food packaging. Some states, like Maine and Minnesota, are going even further by banning PFAS in all products. The regulatory trend is clear. For manufacturers with global distribution, restrictions on PFAS in commerce will disrupt the status quo.  

Manufacturers, whether knowingly using PFAS or not, are increasingly being held accountable due to their role in complex, opaque supply chains. Risk extends well beyond legal compliance. This is about business continuity, operational agility, and market access. Yet many companies are still not modeling PFAS as a business risk. The more proactive ones are integrating PFAS into enterprise risk registers and ESG risk mapping. This is especially true for those in consumer-facing industries or with exposure to highly regulated markets.  

Regulators and insurers are also shifting their stance. Insurers, in particular, are beginning to treat PFAS like asbestos: high risk, long tail, and difficult to insure. Some carriers are excluding PFAS-related liabilities from new policies altogether. Others are developing new legal theories and litigation strategies to limit exposure under existing coverage.