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Used at top MBA programs including
Feb 14 2025
19 min read
1. The fight against “forever chemicals” reaches consumers
- The fight against “forever chemicals” – known as PFAS (per- and polyfluoroalkyl substances) – is gaining traction among policymakers and consumers. The first day of 2025 kicked off bans on clothing with PFAS in New York and California (where the ban also applies to other textiles). Minnesota became the first state to ban the sale of nonstick cookware with PFAS (as well as dental products, ski wax, and other items). The same month, the FDA revoked its prior allowances on PFAS-containing substances used in food packaging.
- Recent months have also seen a wave of new PFAS-related consumer lawsuits against DuPont spinoff Chemours, 3M (which just settled a $10B+ PFAS lawsuit in 2023), Gore-Tex, Johnson & Johnson, Samsung, and Apple (for its Apple Watch band), among others. (Company disclosures of PFAS ahead of a coming Jan 2026 EPA reporting deadline are driving some of this litigation.) One 2024 study found that consumers – who have become increasingly aware of PFAS – would be willing to pay $157 annually to protect themselves from PFAS.
- PFAS (per- and polyfluoroalkyl substances) – a family of thousands of fluorinated chemicals – are commonly applied to textiles, paper and other goods to make them stain-resistant (e.g. Scotchgard), water-repellent (e.g. Gore-Tex), grease-resistant (e.g. food packaging), heat-resistant and nonstick (e.g. nonstick pans). PFAS are often referred to as “forever chemicals” because they break down very slowly under typical environmental conditions. As a result, PFAS are widely found in drinking water, food crops, air, and soil.
- PFAS have been used in industrial and consumer products for 70+ years and are ubiquitous. They are found in a broad range of products across 200+ categories – such as period underwear, toilet paper, bedding, raincoats, ski wax, pizza boxes, carpets, floor finishes, anti-fog sprays, tubing/wiring, plant-based straws, freshwater fish, and firefighting foam. A 2022 study found that 72% of products labeled as stain- or water-resistant sold at 10 major retailers (e.g. Amazon, Walmart, REI, Costco, and Target) tested positive for PFAS. Notably, PFAS are widely used in the production of critical equipment such as chips, batteries, aircraft, cars, and medical equipment.
- PFAS are made up of chains of carbon and fluorine. The reason why they break down so slowly is because of the strength of the carbon-fluorine bond, which has been called the strongest single bond in organic chemistry. There are 4,700+ PFAS chemicals known to exist, and 14,000+ PFAS structures have been identified. 600+ are still being used in commerce in the US.
- Each chemical has its own distinct set of properties, and the half-life of a PFAS in the human body varies widely based on the chemical. Some subgroups of PFAS are even fully degradable. Fluoropolymers like PTFE (branded Teflon) have generally not been considered bioavailable (and are not always included in the PFAS designation), though their production and disposal can raise their own concerns. (At one point, Teflon was produced using PFOA purchased from 3M as a surfactant and emulsifier.) Notably, PTFE can break down into PFAS byproducts under high heat above 500 degrees Fahrenheit, and generate noxious gases under even lower heat (e.g. Teflon flu). (High heat cooking on the stove generally runs around 425-450°, although wok cooking can be as high as 750°+).
- “Forever chemicals” aren’t exactly around forever – they just degrade slowly. In water, PFAS have a half-life of 41 to 92 years. In humans, long-chain PFAS (more than 6-7 carbons) have longer elimination half-lives than short-chain PFAS in blood serum tests – e.g. 2-8 years for long-chain PFAS vs. a month to 1.5 years (and as little as a few days) for short-chain PFAS. Short-chain PFAS are thought to excrete through urine more efficiently, and as a result, are considered somewhat less bioaccumulative. Neither long-chain nor short-chain PFAS degrade easily, however, and both are bioaccumulative. (It should also be noted that precursors can degrade into long-chain PFAS, and long-chain PFAS can break down into short-chain PFAS.)
- Industry has been moving away from long-chain “legacy PFAS” since the early 2000s. The best-studied of these – PFOS (perfluorooctanesulfonic acid) and PFOA (perfluorooctanoic acid) – are no longer manufactured intentionally in the US. Since 1999-2000, the concentrations of PFOS and PFOA in blood levels have declined by 70-85%. In environmental samples, however, PFOS still represents the vast majority of PFAS found.
- By and large, the industry has moved towards short-chain PFAS, which were thought to be less toxic. However, many of these alternatives such as GenX are not well-studied and not well-understood. Recent studies also suggest that certain short-chain PFAS such as GenX and 6:2 FTOH may have higher toxicity levels than previously thought. The industry also continues to invent new variants.
- The widespread exposure of populations and the persistence of PFAS in the environment are not under debate. 200M+ Americans are exposed to PFAS in their drinking water. In studies, PFAS were found in the blood of 97% of Americans, 100% of breast milk samples, and 100% of umbilical cord samples. (The majority of Americans do not have detectable levels of PFAS in their urine, possibly because the short-chain PFAS now prevalent eliminate efficiently in urine.)
- What has been controversial is the scale of the health impact. While most PFAS are chemically inert, many have reactive sites that make them bioaccessible. Some are readily absorbed in the gastrointestinal tract. Others accumulate in the liver. The kidneys are the main elimination pathway for PFAS – and the site of one of the diseases (kidney cancer) for which there is the strongest evidence of a linkage.
- Most PFAS studies are observational, meaning their conclusions could be correlation rather than causation or subject to confounding factors. One of the largest PFAS studies is the C8 Health Project, a 2005-2006 study funded as part of a DuPont settlement that examined 69K people exposed to PFOA from a DuPlant plant over a span of 50+ years.
- The project found probable linkages between PFOA specifically and high LDL cholesterol (but not coronary artery disease); pregnancy-induced hypertension (but not other kinds of hypertension); kidney cancer (but not kidney disease) and testicular cancer (but not other kinds of cancer); thyroid disease; and ulcerative colitis (but not other autoimmune disease). A follow-up review in 2020 found that the evidence for a linkage with kidney cancer and high cholesterol had strengthened, while the evidence of an association with thyroid disease and ulcerative colitis had gotten weaker. That said, even with exposure increasing the incidence of kidney cancer by 50-60%, the actual percentage who had kidney cancer stayed relatively small at 0.3-0.4% of the cohort.
- Regulators in the US have historically been more inclined to take a substance-by-substance approach focused on intentionally-added PFAS rather than a blanket ban. Combating PFAS was a priority under the Biden administration, which earmarked $10B in Bipartisan Infrastructure Law (2021) funding towards addressing contaminants such as PFAS, and created the Interagency Policy Committee on PFAS. Since then, multiple agencies (e.g. CDC, DoD, EPA, FDA, NIST, NOAA, USDA, VA) have developed policies, designed tools, and expanded programs to monitor and regulate levels of PFAS.
- Last year, the US EPA (Environmental Protection Agency) finalized a rule designating PFOA and PFOS as hazardous, and issued the first national, legally enforceable drinking water standards for PFAS. The EPA will require public water systems to monitor for 6 specific PFAS – the legacy PFOA and PFOS as well as PFHxS, PFNA, GenX (HFPO-DA), and PFBS. The proposal sets an enforceable standard of a maximum of 4 parts per trillion of PFOA and PFOS (separately) – a dramatically lower standard than the prior 70 parts per trillion. PFHxS, PFNA, and GenX maximums are set at 10 parts per trillion each, with a combined PFAS maximum level also established. The EPA also proposed last year that 9 PFAS chemicals – PFOA, PFOS, PFBS, GenX (HFPO-DA), PFNA, PFHxS, PFDA, PFHxA, and PFBA – be listed as hazardous constituents under the Resource Conservation and Recovery Act (RCRA).
- In Europe, the European Chemicals Agency (ECHA) is actively considering a blanket ban on PFAS. The proposal provided for two options – either a full ban with an 18-month transition, or a ban with some use-specific derogations (exemptions/relaxations) for a 5- or 12-year period (or even time-unlimited for very narrow use cases). Derogations would be determined based on the “availability and applicability” of PFAS alternatives. The EU has already restricted PFOS (2009), PFOA (2020), PFHxS (2020), C9-C14 PFCA (2023), and PFHxA, a breakdown product of other PFAS chemicals (starting in 2026).
- On the US state level, 40 states have already enacted 366 different policies regarding PFAS. 28 states are considering 230 new policies related to PFAS, including 5 states that have never enacted a PFAS-related policy before. In addition to California, New York, and Minnesota, there’s also Maine, Colorado, and Vermont that have similar bans set to take effect in 2026, followed by Rhode Island in 2027 and Connecticut in 2028. Washington is also rolling out use-specific PFAS restrictions on a regular cycle, following legislation passed in 2022.
- Growth in PFAS bans has the potential to be hugely disruptive to companies and industries. The US market for nonstick cookware alone is $2B-$3B. In some cases, entire manufacturing lines will need to be reengineered to accommodate new materials and processes.
- Many companies are already seeking to reduce PFAS in their products. 3M – whose Scotchgard launched in the 1950s helped bring PFAS into the mainstream – announced it will stop making and using PFAS in its product portfolio by end of 2025. (It stopped using PFOA and PFOS in 2000.) Gore Fabrics will transition the “vast majority of its consumer portfolio” away from PFAS “of environmental concern” (which excludes PTFE) by end of 2025.
- REI began phasing out PFAS in clothing and cookware sold by its brand partners in the fall of 2024. LL Bean and Columbia Sportswear have both transitioned to PFAS-free products as of late 2024. Patagonia will begin making all its new styles without added PFAS in spring 2025 (the company claims 78% of its goods already meet that standard). VF Corp (owner of The North Face, Vans, JanSport, Smartwool and others) plans to phase out PFAS by Mar 2026. Canada Goose, Cotopaxi, Lululemon, Eddie Bauer, Abercrombie, American Eagle, Calvin Klein and Tommy Hilfiger have all made commitments to phase out PFAS as well.
- Among dining chains, McDonald's is phasing out PFAS from its food packaging by 2025, and Burger King and Chick-fil-A have committed to doing the same. Panera and Chipotle are aiming to avoid packaging with intentionally added PFAS.
- Trying to regulate an entire class of chemicals will inevitably result in unintended consequences. Policymakers are trying to avoid “regrettable substitution” – a common response to narrow bans, in which companies switch to lesser-known and poorly studied alternatives that may have similar or worse effects.
- Growing bans on PFAS will likely result in fewer options and less functional products across many industries – and perhaps less competitive industries. For instance, alternatives have not yet been created that repel water and oil as well as PFAS does. We can expect a rising market for PFAS alternatives such as ceramic coatings for nonstick pans. The transition to PFAS alternatives will also likely drive up the prices of goods – which is already being seen in the outdoor industry.
- We’ll also see momentum behind solutions to address PFAS in groundwater and the environment (e.g. PFAS-adsorbing materials, hydrogen-polarized UV treatment, nanofiltration, sequestration, and other treatment technologies). Unfortunately for individuals, PFAS can be avoided in their diet and environment to some extent but the options for reducing the levels of PFAS already in their bodies are limited (e.g. donating blood and plasma, pumping breast milk, prescription regimens that promote excretion).
- For some industries, a PFAS ban could have severe consequences. Chipmakers are warning that there are no viable alternatives to PFAS in semiconductor manufacturing. (They launched the lobbying group Sustainable PFAS Action Network last year.) After seeing the ramifications of the past chip shortages, policymakers are unlikely to want to face another global supply disruption like that – especially in a macro economy that’s already unsteady. PFAS are already in short supply in chip manufacturing – the price for one PFAS derivative, for instance, has risen 70-80% over the past 2 years.
- The new Trump administration has not taken a strong stance on PFAS, although it did withdraw Biden-era limits on industrial discharge in wastewater by PFAS manufacturers the day after Trump took office. The withdrawal was part of a general freeze on any rules that had not yet been published in the Federal Register. If consumer concerns and state/local-level policymaker action continue their momentum, however, federal regulation may become somewhat moot.
Related Content:
- Mar 31 2023 (3 Shifts): "Forever chemicals" are facing a regulatory crackdown
- Jul 15 2022 (3 Shifts): Businesses are using more recycled content – and pushing up recycled-PET prices
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Disclosure: Contributors have financial interests in Meta, Microsoft, Alphabet, OpenAI, and Perplexity. Amazon, Google, and OpenAI are vendors of 6Pages.
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