Per- and polyfluoroalkyl substances (PFAS) reporting can be exceedingly complex. From Toxic Substances Control Act (TSCA) requirements to rapidly evolving US state regulations, navigating PFAS reporting is essential for ensuring compliance and minimizing litigation risk. TSCA mandates detailed disclosures for PFAS manufactured or imported since 2011, and states like Minnesota and New Mexico are introducing sweeping bans and reporting rules (see news).
Compliance is challenging because PFAS can be hidden deep in complex global supply chains and regulations differ across jurisdictions, creating a costly and resource-intensive process for companies. Gradient has proven expertise in helping companies simplify their PFAS reporting requirements.
Gradient’s Differentiators:
Extensive Knowledge – A comprehensive understanding of PFAS reporting requirements under TSCA, Canada’s CEPA, and US state regulations, including Minnesota and New Mexico.
Regulatory Tracking – Staying ahead of evolving rules, and how these rules apply to your products, with up-to-date PFAS monitoring and guidance.
Supplier Outreach & Data Management – Surveying upstream suppliers, managing data securely in a web-based platform, and ensuring data integrity. Helping companies, especially those with large portfolios, overcome resource constraints.
Regulatory Analysis – Identifying PFAS-containing products, determining applicable regulations, and clarifying definitions.
Reporting & Labeling – Preparing jurisdiction-specific reports and labeling guidance.
Automotive – Identifying PFAS reporting obligations in paints, seals, lubricants, adhesives, coatings, and electrical components.
Medical Devices – Specialized support for complex durable goods and emerging labeling requirements.
Consumer Products – A proven record navigating PFAS reporting for packaging, electronics, and everyday goods.
PFAS Reporting for Commercial Vehicle Manufacturer
Gradient assisted a leading commercial vehicle manufacturer in complying with US (TSCA) and Canadian (CEPA) PFAS reporting requirements. The project involved creating jurisdiction-specific supplier surveys for tens of thousands of products; building a secure, web-based database for data collection and analysis; and preparing regulatory submissions and audit documentation. Using advanced outreach tools and a custom supplier interface, we streamlined a complex, resource-intensive process.
TSCA Reporting for Consumer Product Manufacturer
Gradient helped a consumer product manufacturer meet PFAS reporting and recordkeeping requirements under TSCA Section 8(a)(7). We reviewed products to identify reportable items, created a supplier questionnaire to gather additional data, and built a database to organize and store information, ensuring accurate, comprehensive reporting to regulators.
PFAS Vulnerability Assessment
Gradient supported a consumer products manufacturer in assessing PFAS-related product and environmental risks. Through site visits, interviews, and operational reviews, we identified potential PFAS sources and recommended mitigation strategies and further due diligence. Additionally, we helped to design a product-testing program and update purchasing processes to eliminate PFAS in raw materials, creating a template for PFAS assessments at facilities worldwide.
PFAS Regulatory Tracking
Gradient provided PFAS regulatory guidance to consumer products and automotive companies. We summarized all relevant US state PFAS regulations, evaluating the applicability of these regulations to each company’s products and operations. Ultimately, we provided the companies with clear, actionable recommendations to ensure compliance and mitigate future risk.
Testing and Validating PFAS in Synthetic Turf
Gradient provides ongoing PFAS compliance support to a synthetic turf manufacturer. Our work includes developing sampling and analysis plans, validating test results, and interpreting findings for regulatory and risk communication. In addition, we review PFAS analytical data and “PFAS-free” claims to ensure accuracy.
