California PFAS Regulations: A Compliance Checklist for Consumer Products

First published: 12 Feb 2026

Per- and polyfluoroalkyl substances (PFAS), often called “forever chemicals,” have long been used to make consumer products water-, stain-, and grease-resistant. Their durability, however, is the reason they are now under intense regulatory scrutiny: PFAS persist in the environment and accumulate over time, posing significant health and ecological risks.

As a result, structured PFAS testing and documented compliance strategies are becoming essential for market access. Businesses seeking regulatory clarity often ask how to test for PFAS, how to obtain PFAS certification, and how to interpret results from an accredited PFAS lab.

PFAS compliance in California now sits on two tracks. Proposition 65 requires warnings based on exposure risk, not a categorical ban. While the law itself is older, PFAS became a meaningful Prop 65 issue later, with PFOA and PFOS added to the list in 2017 (warning requirements took effect in 2018).

Since then, California has moved aggressively with newer PFAS-specific product laws that impose broad restrictions and thresholds by category. The result is a layered compliance landscape requiring targeted analysis, TOF screening, and clear documentation from recognised testing laboratories.

The Regulatory Landscape: A Layered Approach

To ensure market access, brands must navigate both “tracks” of regulation simultaneously.

Track 1: The Exposure Warning (Proposition 65)

• The Mechanism: Prop 65 is a “Right to Know” law. It does not ban PFAS. Instead, it requires a “clear and reasonable” warning label if consumer exposure to a listed chemical exceeds the “Safe Harbor Level.”
• The Target: Specific listed chemicals (e.g., PFOA, PFOS, PFNA, PFHxS), not the entire class of PFAS.
• Compliance: Requires Targeted Analysis (to identify the specific chemical) and an exposure assessment.

Track 2: The Categorical Restrictions (New Product Laws)

These newer statutes target specific product categories and generally prohibit any “intentionally added” PFAS or PFAS above a specific total organic fluorine (TOF) threshold.

• Textiles and apparel (AB 1817): Bans the manufacture and sale of textile articles containing intentionally added PFAS. It establishes Total Organic Fluorine (TOF) thresholds: 100 ppm starting January 1, 2025, dropping to 50 ppm by January 1, 2027.
  • Note: Outdoor apparel for severe wet conditions has extended timelines but requires mandatory disclosure starting in 2025.
• Cosmetics (AB 2771): Prohibits the sale of cosmetics with intentionally added PFAS effective January 1, 2025.
• Food packaging and cookware (AB 1200): Bans PFAS in plant-based food packaging. It also requires specific online and on-product disclosures for cookware handles and food-contact surfaces containing PFAS.
• Children’s/juvenile products (AB 652): Since July 1, 2023, California has prohibited new juvenile products containing intentionally added PFAS or PFAS at or above 100 ppm TOF, with manufacturers required to use the least‑toxic alternative when reformulating; exclusions apply to children’s electronics, medical devices, inaccessible parts, and adult mattresses.

Enforcement & Future Registration (AB 347)

AB 347 grants the Department of Toxic Substances Control (DTSC) enforcement power over the product bans (AB 1817, AB 1200, AB 2771). While bans are effective sooner, this bill creates a future framework for:

• Test Methods: DTSC to publish accepted methods by Jan 1, 2029.
• Registration: Manufacturers must register compliance statements by July 1, 2029.

 

The Compliance Checklist for Consumer Product Brands

1. Map your portfolio against California’s PFAS restrictions

• Identify impacted categories: textiles (garments, home textiles), juvenile products, cosmetics, cookware, and plant-based food packaging. Compile a bill of materials for each SKU to flag PFAS‑treated inputs (e.g., durable water repellents, grease‑resistant coatings).
• Clarify “intentionally added”: Determine if PFAS serves a functional purpose. If yes, the product is likely prohibited under AB series regulations.
• Verify thresholds: Ensure textiles meet the current 100 ppm TOF limit (moving to 50 ppm in 2027).

2. Tighten supplier engagement and traceability

• Contractualize PFAS controls: Request PFAS compliance declarations from mills, finishers, chemical suppliers and packaging converters. Include PFAS clauses in contracts and quality agreements.
• Audit Processes: Explicitly map treatment steps (DWR finishes, stain guards, grease barriers) that historically relied on PFAS and inspect them.
• Add change-control triggers: any finish/recipe change, resin swap, or post-treatment change should trigger pre-approval and a re-test decision.
• Centralise evidence: retain supplier declarations, change-control history, test reports, and certificates to respond quickly to retailer/regulator questions (AB 1200/1817/2771) and to support Prop 65 defensibility.

3. Choose the right testing strategy for your product

California’s framework blends targeted PFAS analysis (identifying and quantifying specific compounds) with TOF screening to indicate overall PFAS presence, which is especially relevant for non‑Prop 65 compliance checks.

• Total Organic Fluorine (TOF): The industry standard for screening against product bans (Track 2). It provides a quick indicator of total PFAS presence.
• Targeted PFAS analysis: Since Prop 65 applies to specific listed chemicals (e.g., PFOA, PFOS), you must quantify the specific compound to assess exposure risk. TOF alone is insufficient for Prop 65 defense.
• Strategy: Use TOF for broad compliance screening; use Targeted Analysis for root-cause investigation or Prop 65 verification.

4. Labelling, disclosure and claim‑management

• • Cookware disclosure (AB 1200): Ensure website and packaging disclosures are worded strictly according to the statute.
  • Textile/certain apparel disclosures: For outdoor apparel using the “severe wet conditions” extension, you must include the disclosure “Contains PFAS chemicals” starting in 2025.
  • Proposition 65: If exposure to listed PFAS (e.g., PFOA, PFOS, PFNA) exceeds safe harbor levels, provide clear and reasonable warnings.
  • Marketing Claims: Avoid “PFAS-Free” claims unless you have multi-method data (TOF + Targeted) to back it up. Use “no intentionally added PFAS” or “Compliant with AB 1817” for greater safety.

5. Safer Consumer Products (SCP) & Future Risks

Don’t ignore the DTSC’s Safer Consumer Products (SCP) framework. The DTSC can list specific product-chemical combinations as “Priority Products.”

• Action: Screen your portfolio against DTSC Work Plans.
• Risk: If targeted, you may need to submit an Alternatives Analysis or remove the chemical entirely.

6. Phase‑out planning and safer material substitution

• Prioritise high‑risk SKUs: Focus first on high-volume California items with historical PFAS use (outerwear, stain‑resistant home textiles, long‑wear cosmetics, grease‑proof packaging).
• Evaluate alternatives carefully: Non‑fluorinated repellents and barrier chemistries are progressing rapidly; validate performance and durability while screening for hazard to reduce “regrettable substitution” risk.
• Iterative testing: Use TOF screening during R&D to confirm fluorine reductions; follow with targeted analysis if supplier substitutions may introduce specific PFAS residues.

Common pitfalls (and how to avoid them)

1. Confusing the Two Tracks: Assuming passing a Prop 65 test means you comply with AB 1817 (or vice versa). Prop 65 targets specific chemicals; AB 1817 targets total fluorine. You must check both.
2. Relying on SDS alone: PFAS often exist below disclosure thresholds in SDS or are hidden in proprietary blends. Always confirm with testing. 
3. Overlooking “Minor” Parts: Thin coatings or wipe‑clean finishes on products can quietly push TOF over 100 ppm; test representative components to confirm compliance before sale.
   

How Eurofins Sustainability Services can help

Complying with California’s PFAS rules is complex. We simplify the path, blending technical rigour with practical empathy for your teams and timelines.

End‑to‑end PFAS compliance support

• TOF screening: Precise total organic fluorine measurement for textiles, apparel, footwear, packaging and other consumer goods, to verify threshold compliance (100 ppm or 50 ppm). 
• Targeted PFAS analysis: LC‑MS/MS methods adapted from EPA/FDA protocols to identify specific compounds when required, including Proposition 65 support.
• Accredited laboratory network:  Our ISO/IEC 17025-accredited global lab network supports the full product lifecycle, including early-stage R&D, material qualification, production testing and compliance documentation.

Supply chain and materials advisory

• Supply Chain Audits: We design audit protocols to secure credible declarations from your mills and converters.
• Material substitution: Guidance on alternative chemistries, with iterative test plans to validate performance and compliance (no de minimis surprises).
• Regulatory road‑mapping: Translating statutory text into actionable SOPs. 

Documentation and claims governance

• Evidence packs for retailer submissions and DTSC readiness: test reports, method notes, detection limits, and quality assurance records.
• Claims review: We stress‑test “PFAS‑restricted/no intentionally added PFAS” marketing language against your test data, helping you avoid the pitfalls that lead to challenges. 

Sample California PFAS Compliance Action Plan

Phase 1: Portfolio Assessment

• Review all SKUs sold in California within regulated categories; prioritise high-risk items with a history of PFAS use.

Phase 2: Supplier Engagement

• Obtain PFAS declarations and process documentation.
• Implement change-control triggers.

Phase 3: Baseline Testing

• Run TOF screening for priority SKUs; schedule targeted PFAS analysis where compound-specific verification is needed (including Prop 65 assessments).

Phase 4: Labelling and Disclosure Preparation

• Apply mandatory disclosures for Cookware (AB 1200) and Prop 65 warnings where exposure risks exist.

Phase 5: Documentation:  

• Build the internal technical file (Test Reports + BOMs) in preparation for future AB 347 registration requirements.

Final Thought

California’s PFAS regulations are raising the bar for product stewardship. With robust testing strategies, supplier engagement, and clear documentation, businesses can meet compliance requirements while strengthening sustainability commitments.

Organisations seeking clarity on how to test for PFAS can benefit from structured compliance programmes and expert guidance.

Need tailored support or a testing quote?

We can scope a phased program for your California SKUs, starting with TOF screening and providing targeted PFAS analyses where needed. Contact us to schedule an exploration meeting.

Not legal advice: This article is general information for compliance planning and does not replace legal counsel.