A pfos free plastic programme starts from one fact: PFOS - perfluorooctane sulfonic acid - was used for decades as a surfactant and processing aid, and it is now among the most tightly restricted substances in trade. For plastics the risk is rarely the base resin; it is what was added along the way - fluoropolymer processing aids in film lines, mould-release agents, and additives whose chemistry nobody declared. This guide explains where fluorine hides in plastic supply chains, which limits apply, and how buyers verify them.
Where fluorine hides in plastic products
- Processing aids: fluorinated polymer processing aids (PPA) are added in small amounts to film extrusion lines to remove die lines and melt fracture - they leave traces in the finished film.
- Mould release and slip agents: some legacy release chemistries contain short-chain fluorinated compounds.
- Fluoropolymer materials: PTFE, PVDF, FEP and PFA parts are themselves fluorinated, and regulators are still deciding how the universal PFAS proposal treats them.
- Coatings, seals and gaskets: fluoroelastomer and treated components inside assemblies that buyers often treat as hardware.
The pfos restriction buyers must meet
PFOS is a Stockholm Convention POP. In the EU it sits in the POPs Regulation (EU) 2019/1021, amended by (EU) 2025/718 with effect from 3 December 2025: PFOS and its salts are limited to 0.025 mg/kg (25 ppb) in substances, mixtures and articles, and the sum of PFOS-related compounds must stay below 1 mg/kg (1,000 ppb). The old REACH Annex XVII entry for PFOS has been folded into the POPs framework. Sister substances follow the same pattern - PFOA and PFHxS carry the same 25 ppb and 1,000 ppb thresholds, and REACH Annex XVII entry 68 limits C9-C14 perfluorocarboxylic acids to 25 ppb with a 260 ppb sum for related compounds. On top of that, the five-country universal PFAS restriction proposal moved through ECHA committees through 2026, with adoption expected around 2027-2028 and phased transition periods; a pfas free plastic specification is becoming the default expectation rather than a premium.
| Instrument | Scope | Limit |
|---|---|---|
| POPs Reg. (EU) 2019/1021 as amended by 2025/718 | PFOS and salts; related compounds | 25 ppb; 1,000 ppb sum of related compounds |
| POPs Reg. Annex I | PFOA and PFHxS | 25 ppb; 1,000 ppb sum of related compounds |
| REACH Annex XVII entry 68 | C9-C14 PFCAs and related compounds | 25 ppb; 260 ppb sum |
| Universal PFAS proposal | All per- and polyfluoroalkyl substances | Under evaluation; adoption expected 2027-2028 |
How pfos free plastic is tested
Screening starts with total fluorine (TF) or total organic fluorine (TOF) by combustion and ion chromatography - a fast pass or fail for fluorine presence that European food-contact guidance has accepted as compliance evidence, with per-member-state lists still applying. Confirmation moves to targeted analysis: extraction followed by LC-MS/MS for individual substances such as PFOS, PFOA and PFHxS, down to the 25 ppb range. Buyers should ask which method produced the number, because a TOF result says fluorine is present but not which compound, and an LC-MS/MS panel proves the regulated substances specifically.
What to verify in an RFQ
- Full material declaration: every resin, masterbatch and additive in the part, including processing aids used on the line.
- Test evidence: TOF or TF screening plus LC-MS/MS confirmation where limits are tight - request reports per batch or per grade.
- Declarations: a REACH SVHC statement in the format of our REACH SVHC declaration guide, covering fluorinated SVHCs.
- Destination rules: California Prop 65 warnings apply to listed PFAS - see the Prop 65 warning guide - and export files are summarised in our export documentation guide.
Certification and compliance topics are indexed under certification guides, where buyers can compare the restricted-substance schemes side by side.
Related product categories
The materials and part types discussed above are grouped in our sourcing directory:
