I fully agree—PFAS is currently one of the most challenging topics. From a formulator’s perspective, two key issues stand out: the push towards extremely low limits (ppb); the introduction of total Fluorine as a parameter, which can be misleading since Fluorine is not always linked to PFAS This creates real uncertainty across the value chain. Some key questions we are facing: How do we correctly interpret total Fluorine? And how do we manage trace findings when the source is unclear? Open discussions like this are essential to bring clarity and alignment.

I completely agree with your comment. Thank you very much for bringing up these points. We will be creating the PFAS communication where we will try to address the issues that are raised here. Total fluorine is surely a misleading parameter if used singularly (and as a standalone). However, I feel its a good opportunity to see/check/test the intentional addition of any PFAS related substances at a glance. Hence, This can be surely a good "screening" method and not confirmatory method. With respect to the trace impurities, there could be multiple sources. With respect to the supplier, having poor chemical management, using old/unwashed/stored containers made of PTFE, cross-contamination from out sourced material, recycled material containing PFAS in them etc. From formulators perspective, any sources of fluorinated compounds as inputs, intentional usage of certain inactive compounds in formulations (e.g. use of antistatic agents in Dye formulations or lubricant material in printing-ink) can contaminate your final formulations. These are some sources that can be avoided easily. However, other sources such as ppb level of contamination in the Input water, containers and instrument or equipments is probably an unintentional sources. However, regulatory requirements are certainly at ppb level and this needs to be addressed. Do you think it should be taken up further with the regulatory bodies as well?

I fully agree with your considerations. Total Fluorine can certainly be a useful screening tool to identify potential intentional use of PFAS-related substances, but it should not be considered a standalone compliance parameter. As you highlighted, Fluorine can originate from sources that are not related to PFAS, making its interpretation complex and potentially misleading. For this reason, I believe it is essential to continue this discussion with regulatory bodies and brands. Setting requirements based solely on a Total Fluorine limit, without adequate context, could create significant uncertainty and implementation challenges for formulators, suppliers, and brands alike. A harmonized and scientifically sound approach is needed to ensure that regulatory objectives can be achieved while remaining technically feasible and manageable across the entire value chain

That is not only a valid point but it also emphasises the requirement of scrutiny involving all the stakeholders (including testing facilities) before approving the testing methods. May I ask if anyone here knows if there are any open cases/petitions on TF as the only method for confirming the PFAS ongoing? is anybody participating in such discussions with regulatory bodies?