Chemical Forensics: Addressing Allegations of PFAS in Consumer Products

While there are currently no accredited methods for testing PFAS in consumer products, the US EPA has approved standard methods for measuring PFAS in a variety of environmental matrices. With proper guidance, those methods can be adapted for use in consumer product testing.

That guidance has recently been finalized with author Rock Vitale, CEAC, Co-Chairing the American Society for Testing and Materials (ASTM) F18.81 Subcommittee that published “Standard Guide to Evaluate PFAS in Consumer and Related Products” in February of 2025. ^[1] The Guide is structured to support decisions for choosing sampling and testing methods, procedures, and techniques to evaluate PFAS in a wide variety of consumer and related products. In short, it is a roadmap to provide certainty that investigations into the source of PFAS in consumer products will be reliable and defensible under scrutiny.

The steps in the ASTM roadmap are as follows: First, testing a finished product may not be possible. Rather than testing the product itself, like a whole frying pan or a water-repellant jacket, the product’s raw materials and/or components should likely be tested separately. Once we determine what needs to be tested, the Guide outlines the six next steps in the process.

The Six Steps Used to Evaluate PFAS in Consumer Products 

1. Measure total fluorine. All PFAS contain the element fluorine. If there’s no fluorine in the product, there can be no PFAS. It sounds simple, but there is a catch. A testing method can’t tell you there is zero of something. It can only say whether it can be detected and the level or limit at which something may be present but not detectable. Several methods are available for testing total fluorine, and the method selected will need to have a low enough reporting limit that any PFAS present would be too low to be of concern.
2. Perform organofluorine testing. Fluorine can be present in two forms: organic or inorganic. Inorganic forms include salts such as sodium fluoride, which is sometimes put into drinking water to prevent dental cavities. In the case of PFAS, it is the organic form of fluorine where all the fluorine is tightly bound to carbon. The recently approved US EPA Method 1621 describes how this testing is done for environmental samples. As for total fluorine testing, it is important to confirm that the reporting limit of the test used is low enough. The catch with this test is that while all PFAS are organofluorine compounds, not all organofluorine compounds are PFAS.
3. Perform speciated PFAS testing. When an organofluorine test has suggested PFAS are likely present, the next step is to conduct testing to measure for specific individual PFAS compounds. The complication here is that there are several thousand individual PFAS known to be used in a wide range of consumer products^[2], and the US EPA-approved method for speciated (specific) PFAS testing (Method 1633) can only report a few dozen of these at most. However, the specific types of PFAS used in most industries are known. We can verify in advance that the laboratory providing speciated PFAS testing is able to measure PFAS specific to the industry that the product in question comes from, in addition to a broad suite of common PFAS. If that testing returns a negative result, the product sample itself may not contain PFAS in any significant amount, but there are still a few more stones to be turned.
4. Look at the packaging. If PFAS are present in a finished product, but testing of the raw materials and components comes back negative, the next step should be to examine the packaging in which the product was sold. The same three testing steps—total fluorine, organofluorine, and speciated PFAS—can be followed.
5. Look at where the product was assembled/packaged. If the testing still comes back with negatives, but there remains evidence that the product being sold has PFAS in it, the next step should be to investigate the facility where the product went through final assembly or packaging. The manufacturer may knowingly or unknowingly use products containing PFAS in its operations. PFAS are all around us and often turn up in unexpected places so that few facilities can be entirely PFAS-free. However, with proper guidance, steps can be taken to ensure PFAS are not transferred to a product during packaging.
6.       Understand the limitations. The final step in the detective journey should be to examine all the steps taken and understand their strengths and limitations. Were the reporting limits low enough? Were there limitations in the testing methods that may have skewed the results? A good understanding of each stage’s strengths and potential weaknesses in the investigative journey is an important but sometimes overlooked step in ensuring the final conclusions stand up to scrutiny.

Ultimately, when faced with PFAS allegations, it’s critical to follow a structured, methodical approach and collaborate with experts to ensure the results are both accurate and legally defensible. If you find yourself grappling with a case involving PFAS in consumer or related products, our team of PFAS detectives is ready to guide you through the investigation and help you obtain reliable, defensible, and tailored answers.