Per- and polyfluoroalkyl substances (PFAS) now occupy a central place in regulatory, scientific, and industrial debates in Europe. Long used for their exceptional technical properties, they are now at the heart of a major regulatory tightening that will come into effect from 2026. This development requires manufacturers, local authorities, and environmental stakeholders to rethink their compliance strategies, relying in particular on increasingly sophisticated, sensitive, and regulated laboratory analyses.
Table of Contents
Introduction: Why PFAS have become a major regulatory and analytical issue
PFAS, ubiquitous and extremely persistent substances
PFAS refers to a large family of synthetic chemical compounds encompassing more than 4,000 different substances, characterized by the presence of carbon-fluorine bonds that are among the most stable known in organic chemistry. This structure gives PFAS physicochemical properties sought after by industry: resistance to heat, oxidation, and chemical agents, as well as anti-adhesive, hydrophobic, and oleophobic properties.
Conversely, this exceptional stability explains their very low biodegradability in the environment. PFAS can persist for several decades, or even centuries, in water, soil, and sediments. This persistence is the origin of their common name: "perennial pollutants." Today, PFAS are detected in almost all environmental compartments, including areas far removed from any direct industrial activity.
Widespread exposure of the population and ecosystems
Due to their widespread use since the 1950s and their environmental dispersion, exposure to PFAS affects the entire population, albeit at varying levels. The main identified routes of exposure are drinking water and food, particularly through contaminated seafood, meat, eggs, and certain vegetables.
This diffuse exposure, combined with bioaccumulation in living organisms, has led health and environmental authorities to significantly strengthen PFAS monitoring. Exposure studies conducted in France and Europe have shown that some legacy PFAS, such as PFOA and PFOS, are detectable in a large majority of individuals, even several years after their ban.
Increasingly documented health and environmental concerns
Scientific knowledge about the effects of PFAS on human health and ecosystems has greatly expanded over the past decade. Several health effects are now supported by a level of evidence deemed sufficient by expert bodies, including impacts on the immune system, lipid metabolism, fetal development, and certain carcinogenic risks.
From an environmental perspective, the presence of PFAS in aquatic environments raises major concerns for the protection of water resources, biodiversity, and soil quality. These findings have led public authorities to consider PFAS not as emerging pollutants, but as priority substances requiring structured and coordinated regulatory action.
The regulatory turning point of 2026 in France and Europe
The year 2026 marks a key milestone in the regulatory management of PFAS. In France, the entry into force of new bans on the manufacture, import, export, and placing on the market of numerous products containing PFAS reflects a strong political will to reduce public exposure and environmental emissions. At the European level, these national measures are part of a broader dynamic of progressively restricting the entire PFAS family within the framework of the REACH regulation and related legislation concerning water and consumer product quality.
These regulatory changes are not limited to prohibitions in principle. They are accompanied by increasingly lower concentration thresholds, expanded lists of substances to be monitored, and strengthened control programs, directly involving analytical laboratories.
The central role of laboratory analyses in PFAS compliance
In this context, laboratory analysis becomes an essential strategic tool. Manufacturers must be able to identify the presence of PFAS in their raw materials, finished products, waste and packaging, often at extremely low concentrations, on the order of micrograms or nanograms per liter.
Regulatory compliance now relies on reliable, traceable, and legally binding analytical results produced by laboratories accredited according to strict standards. Beyond simply meeting thresholds, PFAS analyses also enable companies to anticipate future regulatory changes, secure supply chains, and support efforts to switch to safer alternatives.
This increase in analytical requirements explains why PFAS are now at the crossroads of regulatory, scientific and industrial challenges, and why the 2026 period constitutes a real turning point for all stakeholders.
PFAS: definition, physicochemical properties and industrial uses
Definition of PFAS and classification of substances
Per- and polyfluoroalkyl substances, collectively known as PFAS, refer to a family of synthetic chemical compounds characterized by the presence of partially or fully fluorinated carbon chains. They are generally divided into two main categories: perfluoroalkyl substances, in which all the hydrogen atoms of the carbon chain are replaced by fluorine, and polyfluoroalkyl substances, which are only partially fluorinated.
This distinction is important from an analytical and regulatory perspective, as perfluorinated substances generally exhibit even greater stability and persistence than polyfluorinated substances. To date, more than 4,000 PFAS have been identified, including perfluoroalkyl acids, sulfonates, fluoropolymers, and numerous precursors that can be transformed into persistent PFAS in the environment.
Physico-chemical properties that are the source of their industrial success
PFAS owe their widespread industrial use to their exceptional physicochemical properties. The carbon-fluorine bond is one of the strongest in organic chemistry, giving these substances remarkable resistance to thermal, chemical, and mechanical stresses. PFAS are therefore relatively insensitive to oxidation, hydrolysis, acids, and bases.
They also possess unique surface properties, combining hydrophobicity and oleophobicity. This ability to repel both water and grease explains their use in applications requiring non-stick, waterproofing, or stain-resistant functions. From an industrial perspective, these characteristics have long been considered a major advantage in terms of product durability, performance, and safety.
Environmental persistence and behavior of PFAS
The same properties that make PFAS attractive to industry explain their problematic behavior in the environment. Their very low biodegradability leads to a gradual accumulation in natural environments. Once released, PFAS can be transported over long distances by water and air, contaminating areas far from the initial sources of release.
In aquatic environments, some PFAS are highly mobile and can migrate into groundwater, complicating the protection of drinking water resources. Others tend to bind to sediments or accumulate in living organisms, leading to bioaccumulation and biomagnification along the food chain. These differing behaviors make the analysis and monitoring of PFAS particularly complex.
Main historical industrial uses of PFAS
Since the 1950s, PFAS have been used in a wide range of industrial sectors. In the textile industry, they have been used to give clothing and upholstery fabrics waterproofing and stain-resistant properties. In the cosmetics industry, some PFAS have been used to improve the durability, texture, or water resistance of formulations.
PFAS have also been widely used in food contact materials, including grease-resistant paper and cardboard packaging. Other applications include fire-fighting foams, non-stick coatings for cookware, industrial lubricants, anti-fogging or anti-static agents, and certain electronic and electrical components.
Sources of exposure and known health impacts to date
The main routes of exposure to PFAS
Exposure to PFAS is now considered widespread throughout the population due to the massive dissemination of these substances in the environment and production chains. The main identified route of exposure is ingestion, particularly via drinking water and food.
Drinking water is a major vector of exposure when water resources are impacted by industrial discharges, historical uses of firefighting foams, or leaching from contaminated soils. At the same time, food contributes significantly to exposure, particularly through the consumption of fish and seafood, meat, eggs, fruits, and vegetables grown on contaminated land.
Other routes of exposure exist, although they are generally secondary. Inhalation of contaminated indoor or outdoor air, as well as ingestion of household dust containing PFAS from treated materials, can contribute to overall exposure. In certain occupational settings, higher exposures may also be observed, particularly in industrial sectors with a long history of PFAS use.
Widespread contamination of environmental environments
PFAS are characterized by diffuse contamination of all environmental compartments. Surface water, groundwater, soils and sediments can be contaminated at varying levels, depending on past and present uses, industrial discharges and local hydrogeological conditions.
In aquatic environments, some PFAS exhibit high mobility, facilitating their transfer to groundwater used for drinking water supply. Others, more hydrophobic, tend to adsorb onto sediments or organic matter. This diversity of behavior complicates risk assessment and necessitates analytical strategies tailored to each specific matrix.
Environmental contamination by PFAS is particularly problematic because these substances can persist long after the emission sources have been shut down. Thus, PFAS banned for several years continue to be detected in the environment, justifying the maintenance of enhanced monitoring programs.
Documented health effects and levels of scientific evidence
The scientific literature on the effects of PFAS on human health has grown considerably in recent years. Epidemiological and toxicological studies have identified several effects for which the level of evidence is now considered sufficient by health agencies.
These effects include a decreased immune response, particularly after vaccination, disturbances in lipid metabolism resulting in abnormal cholesterol and triglyceride levels, and a decrease in birth weight observed in newborns exposed in utero. A link between exposure to certain PFAS and an increased risk of kidney cancer has also been demonstrated.
Other potential effects, such as reproductive, fertility, or thyroid function disorders, are still under investigation. For these effects, the level of scientific evidence is considered more limited or heterogeneous, justifying a cautious, prevention-based approach.
PFAS classification and risk recognition
Institutional recognition of the risks associated with PFAS has resulted in official classifications of certain substances. For example, PFOA has been classified as a known human carcinogen, while PFOS is considered a possible carcinogen. These classifications have strengthened the legitimacy of regulatory actions undertaken at the international, European, and national levels.
They have also contributed to changing the perception of PFAS, which are now considered not only as substances for industrial use, but as contaminants of concern to public health. This scientific and regulatory recognition is a key element in justifying the progressive restrictions and strengthened analytical requirements.
Impregnation studies and limitations of the individual approach
Population exposure studies allow for the assessment of overall exposure to PFAS on a collective scale. In France, national campaigns have highlighted the presence of several PFAS in the blood of a large majority of individuals, with variations related to age, sex, dietary habits, and geographical areas.
These studies have, however, shown that individual biological assays have significant limitations. They do not allow for the precise identification of exposure sources or the period during which exposure occurred. Furthermore, there are currently no individual biological thresholds that can define a direct health risk and guide specific medical management.
In this context, the priority of health and regulatory authorities is focused on reducing sources of exposure and monitoring environments and products. Environmental, food, and industrial analyses thus play a central role in preventing risks, rather than focusing on individual, reactive measures.
PFAS Regulations: International, European and French Framework
A gradual international awareness
The regulatory management of PFAS was initially structured at the international level, in response to the recognition of their persistence, potential toxicity, and global dispersal. The Stockholm Convention on Persistent Organic Pollutants, which entered into force in 2004, constitutes the first international legal framework aimed at eliminating or restricting the most concerning chemical substances.
Several PFAS have been progressively integrated into the regulations. PFOS was subject to restrictions as early as 2009, followed by the ban on PFOA starting in 2020. More recently, PFHxS was added to the list of regulated substances, with specific obligations concerning its production, use, and the management of waste containing it. These decisions have laid the foundation for a comprehensive approach aimed at sustainably limiting exposure to PFAS.
The European regulatory framework and the role of the REACH regulation
At the European level, the regulation of PFAS is based mainly on the REACH , which came into force in 2007. This text aims to secure the manufacture, import and use of chemical substances within the European Union, by imposing obligations for registration, evaluation and, where appropriate, restriction or authorization.
Historically, European regulations have focused on certain emblematic substances in the PFAS family, such as PFOS, PFOA, or PFHxS. However, this targeted approach has shown its limitations, due to the very large number of existing PFAS and the possibility of substituting a regulated substance with another PFAS with similar properties.
It is in this context that a proposal for a broad restriction of the entire PFAS family was submitted to the European Chemicals Agency in 2023. This proposal, supported by several Member States including France, aims to progressively ban the manufacture, placing on the market, and use of PFAS, except for uses deemed essential and difficult to replace. This development marks a paradigm shift, moving from substance-by-substance regulation to a comprehensive approach by chemical family.
European requirements specific to water and consumer products
Alongside REACH, other European regulations govern the presence of PFAS in specific matrices. The directive on water intended for human consumption sets maximum values for PFAS in drinking water, either an overall limit for all PFAS or a stricter limit for the sum of substances considered priority substances.
These requirements have direct implications for drinking water network operators, local authorities, and laboratories responsible for health monitoring. They mandate analytical methods capable of detecting and quantifying PFAS at very low concentrations, often on the order of nanograms per liter.
Other European regulations concern materials and articles intended to come into contact with food. They set usage restrictions and migration limits for certain fluorinated substances, thus reinforcing the need to carry out targeted analyses on packaging and materials likely to contain PFAS.
The transposition and strengthening of the regulatory framework in France
France has transposed all of these European requirements into its national law, while going further on certain aspects. The publication of a national action plan dedicated to PFAS has made it possible to structure a strategy based on reducing emissions, monitoring the environment, and protecting the population.
This momentum materialized with the adoption of the law of February 27, 2025, aimed at protecting the population from the risks associated with PFAS. This legislation introduces progressive bans on the manufacture, import, export, and marketing of products containing PFAS, applicable from January 1, 2026, for several categories of everyday consumer products.
French regulations also provide for stricter controls on industrial discharges, particularly from facilities classified for environmental protection. Concentration limits have been set for certain substances, and water monitoring programs have been expanded to include a greater number of PFAS.
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What will change concretely for manufacturers from 2026 onwards?
Clearly defined bans on placing on the market
From January 1, 2026, French regulations introduce explicit bans on the manufacture, import, export, and marketing of several categories of products containing PFAS. These include cosmetics, clothing textiles, footwear, waterproofing agents, and ski waxes.
These bans represent a major shift for many industrial sectors that have historically relied on PFAS to enhance the technical performance of their products. They necessitate a complete overhaul of formulations, manufacturing processes, and sourcing strategies. In the medium term, these measures will be extended to all textiles, including home furnishings, starting in 2030, except for specific exemptions planned for certain technical or industrial uses.
The key concept of residual thresholds and traces of PFAS
The regulation does not only target the intentional presence of PFAS in products. It also introduces a crucial distinction between the intentional use of PFAS and the presence of residual traces. Products containing only traces of PFAS, resulting, for example, from cross-contamination or process residues, are not systematically prohibited.
However, this tolerance is based on the definition of residual concentration thresholds, which are set or specified by regulation. For manufacturers, this means that compliance can no longer be based on self-declaration. It must be demonstrated through quantitative analyses that verify that the measured concentrations remain below the authorized thresholds. This requirement significantly strengthens the role of laboratory analyses in ensuring product compliance.
A broadening of control and monitoring obligations
The regulatory changes coming into effect in 2026 include stricter control requirements, both for products placed on the market and for industrial discharges. Companies are now required to better characterize the presence of PFAS in their raw materials, finished products, and effluents, in order to limit environmental and health impacts.
In some sectors, this monitoring is governed by specific regulatory frameworks, such as those for facilities classified for environmental protection. Operators must then integrate PFAS into their self-monitoring programs, with analysis frequencies and methods adapted to the requirements of the competent authorities.
Increased responsibilities across the entire value chain
The new rules, applicable from 2026, strengthen the responsibility of all economic actors. Manufacturers are directly concerned by the compliance of formulations and processes. Importers and distributors must ensure that the products they place on the market comply with the applicable prohibitions and thresholds, including when the products are manufactured outside the European Union.
This shared responsibility implies improved traceability of the substances used and enhanced communication between the various links in the supply chain. Technical data sheets, supplier declarations, and analysis results become key elements for demonstrating regulatory compliance in the event of an inspection.
Anticipating 2026 to secure industrial activity
For manufacturers, the challenge is not simply to comply with regulatory obligations once they come into effect. Anticipation is a key factor in avoiding supply disruptions, product recalls, or administrative penalties. This involves the early identification of PFAS present in products, the implementation of appropriate analysis plans, and the evaluation of available alternatives.
As 2026 approaches, PFAS compliance is becoming a strategic issue, at the crossroads of regulatory, technical, and economic challenges. Companies able to quickly integrate these new requirements into their organization and processes will have a significant advantage in sustaining their operations in an increasingly demanding regulatory environment.
Direct impacts on PFAS laboratory analyses
The expansion of the lists of PFAS to be analyzed
From 2026 onwards, PFAS analysis strategies can no longer be limited to a few historical substances such as PFOS or PFOA. Regulatory changes require a much broader approach, incorporating extensive lists of PFAS, sometimes grouped as sums of substances or analytical families.
This development reflects a scientific and regulatory reality: many so-called "emerging" or precursor PFAS can transform into persistent compounds in the environment. Laboratories must therefore be able to offer analytical panels covering several dozen PFAS, or even more, to meet the requirements of environmental monitoring programs, health controls, and product compliance obligations.
Lowering the limits of detection and quantification
The strengthening of regulatory requirements is accompanied by a significant lowering of the thresholds to be respected. In the field of drinking water, for example, the maximum permitted levels for PFAS are now at very low levels, often expressed in micrograms, or even nanograms per liter.
For laboratories, this evolution implies an adaptation of analytical methods to achieve detection and quantification limits compatible with these thresholds. This requires precise control of the entire analytical chain, from sample preparation to data processing, to guarantee the reliability of results at very low concentrations.
The diversity of matrices to be analyzed and their specific constraints
PFAS can be present in a wide variety of matrices, each with its own specific analytical challenges. Water, whether drinking water, surface water, or groundwater, requires sensitive methods capable of detecting very low concentrations in relatively simple matrices that are nonetheless susceptible to background contamination.
Conversely, solid or complex matrices, such as soils, sediments, sludge, or finished products, pose additional challenges for analyte extraction and purification. Food contact materials and packaging require specific protocols, often based on migration tests, to assess the potential transfer of PFAS into food.
Increased requirements for quality and traceability of results
Faced with the regulatory and health challenges related to PFAS, the quality of analytical results has become crucial. Authorities and industry expect robust, comparable, and legally binding data. This necessitates the use of laboratories with validated methods, rigorous quality control procedures, and traceability systems that comply with regulatory requirements.
Analyses must be performed under conditions that minimize the risk of cross-contamination, which is particularly high for PFAS due to their frequent presence in laboratory materials and the analytical environment. Therefore, the management of blanks, calibrations, and internal controls is essential to ensure the reliability of the results.
Scientific focus: laboratory analyses of PFAS
Analytical techniques used for PFAS measurement
The analysis of PFAS relies on chromatography and mass spectrometry techniques capable of detecting and quantifying substances present at extremely low concentrations. The current reference method is liquid chromatography coupled with tandem mass spectrometry (LC-MS/MS). This technique offers excellent sensitivity, high selectivity, and the ability to simultaneously analyze dozens of PFAS compounds in a single sample.
LC-MS/MS is used for both aqueous matrices and more complex matrices after appropriate preparation. It allows for compliance with current regulatory requirements, particularly for the monitoring of drinking water, industrial discharges, and consumer products. For specific needs, high-resolution mass spectrometry approaches can be employed to perform untargeted analyses and identify emerging PFAS or precursors not yet regulated.
Sample preparation and methodological challenges
Sample preparation is a critical step in PFAS analysis. Due to their ubiquitous presence, the risk of background contamination is high, including within laboratories. Analytical protocols must therefore incorporate strict precautions regarding the materials used, solvents, consumables, and the analytical environment.
Depending on the matrix being analyzed, different extraction and purification techniques are implemented. For water, concentration steps using solid-phase extraction are generally employed to reach the required limits of quantification. For soils, sludge, or finished products, more complex methods are necessary to efficiently extract PFAS while minimizing interference. Control of these steps directly impacts the reliability and reproducibility of the results.
Importance of laboratory regulatory compliance testing
PFAS analyses intended to demonstrate regulatory compliance must be performed under conditions that guarantee the validity of the results. Laboratories rely on validated methods and quality systems that comply with the requirements of ISO 17025. In France, accreditation granted by COFRAC is an essential guarantee of technical competence and metrological reliability.
Within the framework of PFAS, these requirements are particularly important due to the very low thresholds set by the regulations and the potential consequences of non-compliance. Analytical results must be legally binding and usable in audit, certification, or litigation processes. Traceability of analyses, management of measurement uncertainties, and participation in interlaboratory proficiency testing are integral parts of this quality approach.
PFAS migration tests for materials and packaging
Materials and objects intended to come into contact with food are a potential source of PFAS transfer into food. Migration tests assess this risk by measuring the amount of substances that can migrate from a material into a food-simulating medium.
These tests are conducted in accordance with the regulatory requirements applicable to food contact materials. They combine time and temperature conditions representative of real-world use with targeted analyses of PFAS in migration media. The results allow verification of compliance with regulatory limits and guide the selection of alternative materials or formulations when exceedances are observed.
How to anticipate PFAS compliance in 2026
Identify and map PFAS in supply chains
The first step in anticipating PFAS compliance is to precisely identify the potential presence of these substances throughout the value chain. This involves a detailed inventory of raw materials, additives, processing aids, semi-finished products, and finished products. PFAS can be present intentionally, but also in trace amounts resulting from cross-contamination or the use of precursors.
PFAS mapping relies on both documentary analysis, via safety data sheets and supplier declarations, and targeted laboratory analyses. This combined approach makes it possible to overcome the limitations of self-reported information and obtain an objective view of the actual presence of PFAS in products and processes.
Define an analytical strategy adapted to regulatory requirements
Once potential sources of PFAS have been identified, manufacturers must define an analytical strategy consistent with the regulatory requirements applicable from 2026. This strategy is based on the choice of matrices to be analyzed, the selection of relevant PFAS panels and the definition of control frequencies.
Requirements vary depending on the industry and product use. For example, controls on drinking water are subject to specific standards, while analyses of consumer products or food contact materials must incorporate the concepts of residual levels and migration. A well-defined analytical strategy optimizes analysis costs while ensuring a high level of compliance.
Implement and analytically validate alternative plans
The 2026 regulations strongly encourage manufacturers to replace PFAS with alternatives that have a better environmental and health profile. However, this substitution cannot be considered a given without rigorous analytical validation. New formulations or materials must be analyzed to verify the absence of regulated PFAS, as well as the absence of precursors that could later transform into persistent PFAS.
Laboratory analyses thus help to secure substitution processes by providing objective evidence of compliance. They also play a key role in post-substitution monitoring, ensuring that PFAS levels remain controlled over time and under different product usage conditions.
Integrate PFAS into monitoring and self-monitoring programs
For many stakeholders, particularly industrial plant operators, PFAS compliance involves integrating these substances into self-monitoring programs. This is especially relevant for wastewater discharges, effluents, and waste, which can be sources of environmental contamination.
Integrating PFAS into these systems requires defining appropriate sampling protocols, validated analytical methods, and relevant monitoring thresholds. The results obtained allow for the rapid identification of any potential deviations and the implementation of corrective actions before regulatory non-compliance is detected by the authorities.
Anticipate controls and ensure long-term compliance
As 2026 approaches, administrative and health controls related to PFAS are expected to increase. Anticipating these controls requires having complete and up-to-date documentation, including analysis results, control plans, evidence of substitutions, and exchanges with suppliers.
Beyond immediate compliance, this proactive approach is part of a sustainable PFAS risk management strategy. By relying on regular analyses and active regulatory monitoring, manufacturers can secure their operations in an evolving regulatory environment and demonstrate their commitment to protecting public health and the environment.
