PFAS: Why product stewardship is now a strategic lever

20-09-2026

PFAS regulation is becoming a market access issue. And companies that treat the transition away from PFAS as a product stewardship exercise will be better placed to protect customers, manage liability, and make defensible decisions before regulatory deadlines become operational constraints.

Scientist in protective clothing and blue gloves holding a test tube with a clear liquid

A structural shift in chemical risk

The proposed EU restriction on PFAS represents a structural shift in chemical risk management. Unlike most previous restrictions, it applies a broad, class-based approach to a large group of fluorinated chemicals used across products, materials, manufacturing processes and supply chains – rather than a limited number of well-defined substances

This creates a new challenge for industry. Organisations must look at the PFAS present in raw materials, components, formulations, process aids, finished products, and complex articles where composition information is difficult to obtain.

In addition, PFAS may also occur as impurities or residual constituents that aren’t immediately visible through conventional compliance processes. As a result, many organisations may struggle to establish a complete understanding of where PFAS are present across their products, operations, and value chains.

Therefore the challenge isn’t just regulatory. It’s about visibility, decision making, and transition planning.

Companies need to identify potentially affected uses, understand dependencies, assess alternatives, and make investment and product decisions despite incomplete information and continuing uncertainty. For many organisations, the first question isn’t how do I comply with the restriction? It’s where are PFAS embedded in the business?

A managed approach to PFAS phase-out

The proposed regulation treats PFAS as a class because persistence, mobility, and long-term accumulation create risks that are difficult to reverse once releases have occurred. The European Chemicals Agency’s committees is proposing a managed move away from PFAS use, with targeted derogations where alternatives aren’t yet technically or socio-economically feasible.

These derogations remain particularly relevant for certain essential applications, including parts of the semiconductor, healthcare (medicinal products and medical technology), and energy sectors. And waste and recycling operators may continue to manage PFAS related challenges arising from historic uses long after restriction deadlines have passed.

Companies that rely on derogations will need to justify why use remains necessary, substantiate the availability of alternatives, and maintain control measures that can withstand regulatory and customer scrutiny. They must also meet strict concentration limits, reporting obligations, labelling requirements, and emission control measures for continued use.

The signal for industry is clear: derogations are intended to create time for transition, not to preserve the status quo. Companies must still move towards substitution and continued PFAS use will become increasingly difficult to justify.

Understanding your exposure

Measures including monitoring emissions, treating wastewater, and checking compliance against known substances remain necessary, but they don’t address the full business exposure created by a market-wide restriction.

Even if you may manage your organisation’s emissions responsibly you could still lose market access if PFAS are present in products, imported components, or critical materials without a viable derogation or substitution pathway.

The main risks lie in product portfolios and value chains, where:

PFAS may be embedded in components that become subject to market restrictions
Supplier information may be incomplete or unreliable, leaving companies uncertain about the actual PFAS content of products placed on the market
Substitution decisions may be delayed until the regulatory route is fixed, leaving too little time for qualification, performance testing and customer approval
Products already on the market may create downstream exposure, especially where environmental persistence, end-of-life management or historic use patterns become relevant in future claims

Substitution can be constrained by performance requirements, technical feasibility, qualification cycles, and supply chain availability – factors that take time to address. Companies that wait for the final legal text before acting are likely to be too late for a controlled transition. So you need to act now.

Reducing PFAS requires looking beyond your own facility. Effective reduction means addressing PFAS in your processes, your supply chain, and your waste streams.

Angélo Blanken - RuttenConsultant Chemicals Management

PFAS create risks across your entire value chain

Many manufacturers and downstream users have limited visibility and control over PFAS contained in purchased materials, components and articles. Supplier declarations may be incomplete, legacy data may not reflect current formulations, and PFAS may be present in articles or complex materials where composition data is difficult to obtain.

Equipment, coatings, seals, membranes, firefighting systems, lubricants, maintenance materials, and infrastructure can all create dependencies that aren’t visible in a traditional chemical inventory.

In critical applications, alternatives may not yet meet the required combination of durability, chemical resistance, temperature performance, or safety. This can make the transition less gradual than expected for some sectors. And may cause production, maintenance, or product availability to stall.

Customers are also increasingly asking for PFAS-free products, clearer material transparency, and evidence that alternatives have been assessed. And this rise in public scrutiny is also increasing the pressure on companies to transition to PFAS-free alternatives sooner rather than later.

Three shifts to achieve product stewardship

The question you need to answer goes beyond whether a substance is compliant today. You need to establish whether a product, process, or supply chain will remain viable under foreseeable regulatory, customer and liability conditions.

For PFAS, this requires three practical shifts.

1. Move from a substance focus to a functionality focus

2. Move from data collection to risk prioritisation

3. Move from reactive compliance to proactive scenario planning

Delays amplify risk

Waiting for legal certainty may feel smart, but it can take away the time needed for supplier engagement, testing, redesign, qualification, and customer alignment. Once the restriction enters into force, regulatory timelines will be fixed but technical uncertainty will remain.

Your biggest risk is delaying action. Companies that are slow to act may face loss of market access, forced substitution under time pressure, higher costs from late-stage redesign, supply chain disruption, and greater exposure to liability or reputational damage.

Early movers have a huge advantage. They can shape substitution pathways, align suppliers, reduce uncertainty, and build credibility with customers who are already asking for safer, more transparent products.

Get expert support to begin your transition

At Haskoning, we’re committed to helping you translate regulatory complexity into operational decisions. And to determine what regulations mean for products, assets, suppliers, investment choices, and customer commitments.

A robust PFAS response begins with mapping PFAS across products, assets, and value chains – including less obvious sources such as maintenance materials and equipment. And a mass balance view to identify where PFAS are incorporated into products, released to waste streams, or transferred through the supply chain.

This helps focus efforts on the most significant regulatory, operational, and commercial risks. From there, you can develop substitution and mitigation pathways that are both technically feasible and regulatorily defensible.

Product stewardship provides a bridge between regulations and technical feasibility by combining substance information, exposure data, supplier input, and business priorities, to inform decisions about the best steps to take at any given time.

We combine regulatory insight, technical risk assessments, and practical implementation to protect your market access, support safer substitution, and empower informed decisions under regulatory uncertainty.

Get in touch with our expert team, to start your PFAS transition, today.

Managing PFAS risk in a changing landscape

PFAS risk is moving fast. This whitepaper explores where PFAS may affect your organisation and shares practical steps to reduce exposure, choose better alternatives, and plan for safer, more resilient operations.