PFAS in products: due diligence for Australian businesses

Start with the product and the exact PFAS — not a blanket assumption.

PFAS are a large group of fluorinated chemicals used for functions such as resistance to water, oil, stains, heat, chemicals or abrasion, and as surface-treatment, dispersion or wetting agents. Their presence cannot be assessed reliably from a product name or a broad supplier assurance alone.

Australia does not apply one identical rule to every PFAS and every product. The legal position can depend on the exact chemical, concentration, product or article, intended use, whether the activity is import, manufacture, use, release or disposal, and the Commonwealth, state or territory framework that applies. A business should avoid treating 'PFAS' as either universally permitted or universally banned.

Map where PFAS may appear across the product and supply chain.

PFAS risk may sit in a chemical mixture, a coating, a treatment applied by a subcontractor, a processing aid, an impurity or a precursor that can degrade to another PFAS. Scope the finished product and the materials, components and manufacturing steps behind it.

• Prioritise products marketed as non-stick, stain-resistant, water-resistant, grease-resistant, heat-resistant or easy-clean.
• Review textiles, footwear, furniture, carpets, cookware, food-contact materials, packaging, cosmetics, cleaning products, coatings, paints, inks, electronics and firefighting products where relevant.
• Identify the legal entity importing or manufacturing the chemical, product or article and the entity controlling product specifications and supplier approval.
• Distinguish a product designed to release a chemical from an article that is not designed to release it; the distinction can affect AICIS obligations, but it does not remove the need to check applicable IChEMS measures for high-concern chemicals in articles.

Build an evidence file that goes beyond a 'PFAS-free' declaration.

A declaration is useful only when its scope, terminology and supporting basis are clear. Ask the supplier to identify what was checked, the definition or list used, the exact product, batch and production sites covered, and whether the response addresses intentionally added PFAS, impurities, precursors and processing aids.

• Obtain the chemical name, CAS number, function, concentration or concentration range and the point in production where it is used.
• Ask whether any fluorinated chemistry is intentionally added, including by component, fabric, coating, packaging or treatment suppliers.
• Confirm whether the declaration covers the finished item, every relevant component, all production sites and the current formulation or bill of materials.
• Record evidence supporting the answer, such as specifications, safety data, formulation information, test reports or an accountable supplier declaration.
• Use a confidential chemical data provider or other controlled route where the supplier will not disclose proprietary details directly, rather than accepting an unexplained information gap.

Check the relevant Australian chemical and product controls.

For industrial chemical introductions, check the exact chemical against the Australian Inventory of Industrial Chemicals and follow the AICIS categorisation rules. Certain designated fluorinated chemicals are specified classes of introduction and can require assessment where a listed introduction or another lawful pathway is not available.

Check the current IChEMS Register for the exact chemical and the measures that apply. PFOS, PFOA, PFHxS and related substances are in Schedule 7 with prohibitions and restrictions. The online register was expanded in June 2026 to include additional PFAS in different schedules, reinforcing the need to search by chemical identity rather than relying on a static shortlist.

• Read any permitted-use, concentration, unintentional trace contamination, article, storage, handling and waste provisions precisely.
• Confirm how relevant IChEMS standards have been adopted or implemented in the Commonwealth, state or territory rules governing the activity.
• Check overlapping regimes for consumer product safety, cosmetics, therapeutic goods, agricultural or veterinary products, food contact, workplace chemicals, transport and waste where relevant.
• Keep proposed restrictions, voluntary phase-outs and customer specifications separate from requirements that are already legally in force.

Use risk-based testing — and define what the test must prove.

Testing should answer a defined question about a defined product, chemical list and limit. A result described only as 'PFAS compliant' or 'not detected' may be misleading if the method, analyte list, sample, reporting limit or production scope is unclear.

Official IChEMS industry guidance describes a tiered approach using administrative controls and analytical measures. It notes that total organic fluorine can be used as a screening approach and that targeted techniques may be needed. For PFOA, the guidance identifies a combination of total oxidisable precursor analysis and liquid chromatography–mass spectrometry as a strong way to demonstrate compliance with the PFOA standard. The appropriate method still depends on the product, chemical and decision being tested.

• Write a testing brief that identifies the exact item, component, batch, analytes, limits, methods and required reporting limits.
• Use a laboratory with suitable capability and verify that the report matches the supplied sample and current production.
• Investigate screening signals, unexpected fluorine or results close to a limit rather than treating a single summary page as conclusive.
• Combine testing with supplier, formulation and process evidence; a passing sample does not prove that every future batch or undisclosed component is controlled.
• Treat targeted PFOS, PFOA and PFHxS analysis and total or organic fluorine screening as complementary evidence: targeted analysis can miss other PFAS or precursors, while fluorine screening does not identify the chemical present.

Make a documented supply decision and control any claim.

• Record whether the product may proceed, must be held, needs conditions, requires further evidence or should be rejected.
• Identify the exact legal, customer and internal specifications used for the decision and preserve the supporting version of each source.
• Do not make a broad 'PFAS-free', 'non-toxic' or environmentally safe claim unless the wording, scope, evidence and reasonable customer understanding are supportable.
• Where evidence is incomplete, describe the limitation accurately and assign an owner and deadline rather than converting uncertainty into approval.

Respond proportionately when the evidence reveals a problem or remains incomplete.

Do not assume that a suspected PFAS issue automatically requires a consumer recall or destruction. The response depends on the chemical, concentration, activity, product status, stock location, claims and applicable law. Obtain specialist advice before choosing a legal or waste pathway.

• Place affected new orders and stock on a controlled hold while the facts are established.
• Identify the exact SKUs, components, batches, suppliers, import dates, stock locations and quantities already supplied.
• Confirm the chemistry and test basis, then assess current supply, customer communications, claims, notification and waste obligations separately.
• Do not treat a supplier's 'unsure' response as clearance; assign follow-up evidence, an owner and a decision deadline.

Keep the decision current through supplier and product change control.

Replacing one named PFAS with another fluorinated chemical may not resolve the legal, environmental or claims risk. Require notification before changes to formulations, coatings, components, sites, subcontractors or raw materials. Recheck the applicable registers and standards, reassess alternatives and retest where the change could affect the evidence.

PFAS product due-diligence checklist.

• Create a risk-ranked product and material inventory.
• Map the importer, manufacturer, supplier, sites and relevant product functions.
• Collect exact chemical identity, concentration, use and supplier evidence.
• Search current AICIS Inventory and IChEMS Register entries and applicable local requirements.
• Set product-specific specifications, contractual requirements and supplier notification duties.
• Plan proportionate screening or targeted testing with clear decision limits.
• Document approval, hold, escalation and claim decisions.
• Monitor regulatory, supplier and product changes and schedule evidence rechecks.

Questions to ask

Focus on the decision and the evidence.

1. 01

   Which products, components, materials and suppliers have a plausible PFAS function or exposure?

2. 02

   What are the exact chemical identities, CAS numbers, concentrations and reasons for use?

3. 03

   Which AICIS, IChEMS, product, workplace, waste or state and territory requirements apply?

4. 04

   Does the evidence support the supply decision and any PFAS-related marketing claim?

5. 05

   What testing, supplier notification and change controls will keep the decision current?

Primary sources

Check the controlling material.

• Official PFAS information for industrial chemical introducers ↗
• Official categorisation guidance for fluorinated chemicals ↗
• Official IChEMS Online Register ↗
• Official IChEMS industry compliance guidance ↗
• Official IChEMS Minimum Standards ↗

Related resources

Continue with this topic.

Recommended training

Practical support

Apply the guidance to your facts.

Identify the exact product, claim, customer journey, supplier, legal entity or process involved. Preserve the information that supports the current position, record unresolved facts, assign an owner and confirm the point at which specialist review is required.

Important information

Check the current position.

This resource is general information, not legal advice. Laws, official guidance and proposals can change. Do not rely on a title or summary alone to decide whether a requirement applies to a particular entity, product or activity.