3 PFAS SDS Mistakes That Cost You Money, Time, and Sleep
What they are. Why they happen. How to fix them before regulators, customers, or customs do.
Per- and polyfluoroalkyl substances (PFAS) are the regulatory equivalent of glitter: once they are in your product story, they get everywhere. New bans and hazard updates are landing across multiple regions, buyers are adding PFAS clauses to contracts, and enforcement teams are getting sharper. If your Safety Data Sheet is not keeping pace, you are carrying hidden commercial risk.
Below is a deep dive into the three PFAS-related SDS mistakes we see most often, with practical fixes you can apply today. Use it as a reality check for your portfolio, your suppliers, and your authoring process.
Mistake 1: Not disclosing PFAS in Section 3 when you should
How it happens
PFAS slip in as surfactants, processing aids, performance additives, or residuals in raw materials. Suppliers sometimes declare them vaguely as “fluorinated additives” or treat them as impurities. Authoring teams then miss the thresholds or special rules that would require listing in Section 3 or mentioning restrictions in Section 15.
Why it hurts
You risk non-compliance if a PFAS drives the mixture classification or sits above a generic or specific concentration limit.
Buyers increasingly demand written PFAS statements. If your SDS is silent, they assume the worst.
Some PFAS are restricted in certain uses. If you do not flag this in Section 15, distributors can and do walk away.
Every actor in the supply chain, from importers to formulators, distributors, and downstream users, now has the obligation and option to remove the annulled titanium dioxide classification and associated hazard statements. This means:
SDS and labels across the supply chain can be updated to reflect the judgment.
Suppliers at all levels should communicate changes to their customers to ensure consistency.
The update is not limited to importers; all suppliers of TiO₂-containing products in the EU market are affected.
“This is more than a legal technicality,” notes Yordas' Regulatory Consultant Fiona Moir. “It changes hazard communication obligations for a major industrial pigment used in paints, coatings, plastics, and many other products. Businesses that act quickly can reduce labelling complexity and demonstrate proactive compliance to customers.”
Mistake 2: Letting hazard information go stale
How it happens
PFAS hazard profiles evolve. Harmonised classifications get updated, new categories appear in some regions, and authoritative opinions shift based on fresh data. SDS templates and authoring rules sit still. Before you know it, your Section 2 and Section 11 are out of date and your exposure controls in Section 8 are not strong enough.
Why it hurts:
Classification changes affect labels, transport, worker protection, and customer risk assessments.
You are legally expected to update the SDS when new information affects risk management. “We review every three years” is not a defence if something material has changed next month.
Outdated controls are a red flag to auditors and customers.
Mistake 3: Ignoring regional PFAS bans and use-specific restrictions
How it happens
Teams author a single “global” SDS, then market the product everywhere. PFAS rules, however, are not one size fits all. Some jurisdictions target firefighting foams, others food contact, textiles, cosmetics, children’s products, or broad use categories. Importers discover the problem at the border.
Why it hurts
You can lose entire markets overnight if your SDS does not surface applicable restrictions or if your product simply cannot be sold in certain uses.
Distributors will return stock if they cannot legally place it on the market.
E-commerce platforms increasingly screen listings for PFAS keywords.
Bonus pitfalls that trip up good teams
Treating PFAS as confidential without justification: confidentiality claims must be defensible. Authorities can and do request full composition.
UVCBs and polymer naming: broad family names hide risk. Where feasible, indicate the function and any known residual monomers or processing aids that are PFAS.
Copy-paste creep: one product’s well-maintained SDS becomes the accidental template for another with a different PFAS profile. Lock your templates and use controlled composition data.
What “good” looks like for a PFAS-aware SDS
Section 2 clearly reflects current classification and signal word, with relevant hazard statements and precautionary measures that match PFAS concerns.
Section 3 lists PFAS contributors with recognised names and identifiers, typical ranges, and notes on specific limits or M-factors where relevant.
Section 8 provides exposure controls that are realistic for your customers’ processes, including suitable filters, gloves, and capture methods.
Section 11 and 12 speak to persistence and mobility, where relevant and avoid vague, unhelpful phrases like “no data available” when data obviously exists.
Section 15 highlights applicable restrictions or prohibitions in the markets you sell into and signposts any reporting or notification duties.
Change control is visible: revision date, reason for update, and a version history.
How we can help
If you want a quick, no-obligation SDS Health Check, send us one representative SDS and tell us where you sell it. We will pinpoint your top exposures and the fastest path to fix them.
Or if you have a question about PFAs or Safety Data Sheets, get in touch.
PFAS compliance is moving fast. Your SDS should move faster. For the latest information on PFAs, you can subscribe to our Monthly PFAs Newsletter.
