Regulatory Compliance

PFAS

Per- and polyfluoroalkyl substances, often referred to as PFAS, are a diverse group of chemistries characterized by the strong bond between fluorine and carbon atoms. Because of this strong bond, PFAS provide products with strength, durability, stability and resilience. These properties result in the reliable and safe function of many products, including those used in medical, pharmaceutical, food packaging, aerospace and automotive applications.

In performance textiles used in the residential furniture industry, PFAS created oil- and water-repellency, cleanability of oil- and water-based stains and breathable moisture barriers to wind and rain. Initially developed for outdoor furniture, performance fabrics containing PFAS migrated to the indoor furniture market in the 1990s as advanced technology brought color, texture and a softer hand to these high-quality textiles.

Around the same time, however, concerns were growing about the effects of long-term, low-level exposure to specific PFAS, including perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). The strong bond that makes these particular chemicals useful in so many industries breaks down slowly in the environment, leading to the nickname “forever chemicals.” By the early 2000s, research was finding widespread PFOS contamination in fish, birds and mammals. By 2011, studies were associating PFOA with health problems, including thyroid disease and kidney and testicular cancer.

The National Council of Textile Organizations (NCTO) states that PFOA and PFAS were never intentionally added as a treatment in the U.S. textile finishing process. Nevertheless, the PFAS they did use were lumped in with PFOA and other PFAS by environmental groups and policymakers when they began regulating these substances.

PFAS Regulation

The U.S. Environmental Protection Agency (EPA) announced its PFAS Strategic Roadmap in October 2021 to protect the environment from PFAS contamination. In November 2023, the agency issued a one-time reporting and record-keeping rule to generate data for use in developing regulations.

The reporting rule required all manufacturers and importers of articles containing PFAS between 2011 and 2022 to report information to EPA. Required information includes production volumes, chemical identity, worker exposures and means of disposal.

In November 2025, EPA released a proposal to narrow the scope of its reporting regulation, requiring data only from domestic manufacturers that import components (such as fabric) containing PFAS. Importers would be exempt if the proposal is finalized.

This revision also proposes to compress the submission period from six months to three months, and the reporting window would begin 50 days after the final rule’s effective date.

What it Means for AHFA Members

For companies that began preparations under the 2023 rule, the proposed revisions either eliminate reporting entirely for importers or streamline it. This is still a proposed revision, so AHFA member companies should evaluate how the proposal could impact their operations and, if they anticipate being required to report, prepare for a compressed submission window if a final rule adopts these changes.

State-Level PFAS Regulation

Instead of relying on the federal government to regulate PFAS, some states have adopted their own PFAS regulations. As of early 2026, at least 30 states have implemented or considered policies regulating PFAS, with 13 states enacting specific legislation.

Although each state’s PFAS regulations are unique, they tend to share some common elements. Most define PFAS as fluorinated organic chemicals containing at least one fully fluorinated carbon atom. Instead of regulating specific PFAS, states have been restricting the entire class of chemicals, focusing on PFAS that have been intentionally added to certain product categories, including firefighting foam, food packaging, children’s products, cosmetics, carpet, textiles and furniture.

Textiles containing intentionally added PFAS are regulated in nine states, including California, Colorado, Connecticut, Maine, Minnesota, New Mexico, New York, Vermont and Washington.

Each year brings changes and new regulations. AHFA is proactively monitoring state activity and working to keep member companies informed.


Updated March 2026