By Krystal Spickler, program manager, Supply Chain team, UL Solutions
What retailers need to know:
Per- and polyfluoroalkyl substances (PFAS), often called “forever chemicals” due to their persistence in the environment and human body, are found in a wide array of consumer products, including cosmetics, cookware, textiles, paints, pesticides and food packaging. These substances are under increasing regulatory scrutiny due to their potential health risks and environmental impacts.
Retailers face mounting challenges from evolving regulations, consumer expectations and supply chain disruptions. With differing definitions – some encompassing up to 10,000 substances – and regulations in development worldwide navigating the complexities of PFAS compliance has never been more critical. So, what does greater awareness of PFAS really mean for retailers, and how can they adapt to this shifting landscape?
Below, we discuss emerging regulatory, risk management and operational issues retailers should consider as stakeholder interest in PFAS increases.
Key PFAS considerations for retailers
1. Growing regulatory pressure
Implication:
Regulatory landscapes are increasingly complex, with new requirements emerging globally and regionally.
For example:
- U.S. state-level laws: Some states such as Maine and Minnesota now require disclosure and eventual bans on PFAS in all consumer products, affecting both formulated products (e.g., cosmetics, cleaning agents) and articles (e.g., textiles, food packaging).
- Federal regulations: The U.S. Environmental Protection Agency’s (EPA) PFAS Recordkeeping and Reporting Rule under the Toxic Substances Control Act (TSCA) imposes reporting requirements that impact retailers.
- International requirements: Canadian and EU regulations are also tightening, with Canada requiring reporting of specific PFAS and both jurisdictions developing future restrictions.
Action steps for retailers:
- Conduct a comprehensive audit of your product assortments to identify items containing PFAS.
- Stay informed on jurisdiction-specific rules and deadlines to support compliance.
- Develop a strategy to phase out PFAS-containing products or work with your supply chain to evaluate alternatives where required.
How UL Solutions helps:
Leverage ULTRUS™ WERCSmart® retail product compliance software to efficiently screen thousands of products for chemicals of concern and build scalable compliance programs to manage regulatory requirements.
2. Consumer demand for transparency and safer products
Implication:
Consumers are increasingly aware of PFAS risks. Results of a recent CivicScience survey show that over half of U.S. adults are concerned about the health and environmental impacts of PFAS, with many respondents preferring retailers that ban PFAS in their products.
Action steps for retailers:
- Enhance transparency by clearly labeling products and offering information about their chemical safety.
- Implement or update a Restricted Substance List (RSL) to proactively address chemicals of concern.
- Explore opportunities to market product lines that are not formulated with PFAS chemicals as a competitive advantage.
How UL Solutions helps:
Use ULTRUS™ PurView® software to implement a restricted substance list and/or build a product curation program to identify and sell products without intentionally-added PFAS and empower informed consumer purchasing.
3. Supply chain disruptions
Implication:
As manufacturers phase out PFAS chemicals, supply chains may encounter shortages of replacement materials, rising costs and a need for process changes. Retailers that rely on private-label brands are especially susceptible to these disruptions.
Action steps for retailers:
- Engage suppliers early to understand their plans for PFAS phaseouts and assess the availability of alternative materials.
- Collaborate with suppliers to explore alternatives to PFAS and mitigate potential delays or cost increases.
- Diversify sourcing to reduce dependency on single suppliers or regions.
- Update or create an RSL based on a forward-looking chemical management strategy.
How UL Solutions helps:
- Use ULTRUS™ PurView®’s formulation sandbox to identify problematic ingredients and develop new or reformulated products free of PFAS chemicals.
- Use ULTRUS™ Prospector® to identify alternative ingredients and materials.
- Share updated RSL requirements with all suppliers.
4. Health and environmental risks
Implication:
PFAS persist in the environment and accumulate in the human body, with studies linking certain PFAS to health risks like increased cholesterol, thyroid disease, and cancer. Retailers may face reputational risks if associated with PFAS-laden products.
Action steps for retailers:
- Use awareness of PFAS-related risks as an opportunity to lead sustainability efforts, reducing reliance on harmful chemicals.
- Partner with third-party experts or certification bodies to validate product claims and reinforce credibility with eco-conscious consumers.
How UL Solutions helps:
Leverage UL Solution’s PFAS Testing Services for Consumer Products to help validate and demonstrate that claims of non-detectable PFAS levels in your products are accurate, truthful and credible.
5. Operational challenges
Implication:
Retailers must prepare for potential costs and operational complexities related to compliance, meet reporting and labeling requirements and implement jurisdiction-specific sales restrictions on PFAS-containing products.
Action steps for retailers:
- Invest in compliance management systems to streamline reporting and product handling processes.
- Create cross-functional teams to manage PFAS-related challenges, including legal, procurement and product development stakeholders.
- Build contingency plans for phased recalls or adjustments to product offerings based on regulatory changes.
How UL Solutions helps:
Leverage ULTRUS™ WERCSmart® to identify products containing PFAS, generate reports for internal stakeholders and build scalable operational processes to empower PFAS compliance for your front-line employees.
As PFAS “forever chemicals” attract more and more attention from regulators, investors and consumers, retailers face evolving challenges in terms of compliance, supply chain transparency, reputational risk and product development. Proactive adjustment of internal processes along with implementing appropriate third-party chemical and regulatory management technologies can help companies address these challenges and enhance their product stewardship and sustainability profiles.
To learn more about PFAS chemicals, read our comprehensive white paper on PFAS Chemicals.
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