PFAS Requirements in 2025: What Electronics Manufacturers Must Know

PFAS regulations are evolving worldwide practically by the day. For electronics manufacturers and supply chain leaders, 2025 brings a clear mandate: Know what’s in your products, and prove it with confidence.

PFAS (polyfluoroalkyl substances), also called “forever chemicals,” have been essential to electronics manufacturing for decades. Their stability, heat resistance, and insulating properties make them valuable in everything from circuit board coatings to wire insulation and chemical etching.

Mounting evidence of PFAS toxicity and longevity has prompted global regulatory action. Beginning in 2025, a wave of new requirements — particularly from the U.S. EPA — is forcing electronics companies to re-evaluate materials, scrutinize suppliers, and adopt more rigorous documentation practices.

Here’s what electronics manufacturers and purchasers need to know about PFAS requirements to stay compliant — and competitive — in 2025 and beyond.

Why PFAS Use in Electronics Is Under Fire

PFAS are a broad class of synthetic chemicals prized in electronics for their thermal stability, chemical resistance, and dielectric strength.  Common applications include:

• Wire and cable insulation
• Printed circuit board coatings and laminates
• Etchants and cleaning agents in semiconductor processing
• Thermal interface materials and lubricants
• Dielectric coatings for capacitors and sensors

However, these substances are also extremely resistant to degradation in nature and the human body. PFAS accumulate over time in water, soil, and food sources, earning them the “forever chemicals” label.

Exposure has been linked to: 

• Cancer 
• Liver damage 
• Immune dysfunction

Global regulators now treat PFAS like asbestos or lead — hazardous substances to be phased out, not tolerated.

PFAS Requirements & Compliance Landscape in 2025

This year marks a turning point for PFAS regulation. Here’s what electronics purchasers and compliance teams need to watch:

U.S. Federal Regulations

Federal oversight of PFAS in the United States is intensifying. Electronics manufacturers must comply with several new and updated rules from the EPA that mandate comprehensive tracking and reporting of PFAS usage. 

Here’s what’s coming at the national level:

• 

  EPA’s Toxic Substances Control Act (TSCA) Section 8(a)(7) Rule: Beginning in 2025, manufacturers and importers must report PFAS usage dating back to 2011. The EPA currently lists over 1,400 PFAS substances under TSCA, with growing attention to over 10,000 structurally similar compounds. Reporting includes: 
  • Chemical identity 
  • Production volumes 
  • Functional applications (e.g., coatings, insulators, additives)
  • Worker exposure and risk data
  • End-use products and disposal methods
• Toxics Release Inventory (TRI) Reporting Changes: PFAS are now classified as “chemicals of special concern.” Companies must report all listed PFAS chemicals without exemption for low concentration. Even minor use in solder masks or conformal coatings must be reported. The 2025 reporting year adds nine more substances, totaling 205 reportable PFAS.
• Significant New Use Rule (SNUR): Reintroducing inactive PFAS requires EPA review. Electronics firms exploring legacy formulas or importing parts with legacy chemicals must proceed with caution.
• New Chemicals Review Reform: Low-volume and low-exposure PFAS — once exempt — now undergo full risk assessments. This includes PFAS used in prototypes or R&D.
  
  

U.S. State-Level Actions

States are going further, enacting bans on products containing intentionally added PFAS:

• California’s AB-1817: Bans PFAS in textiles — relevant for wearable electronics and protective casings.
• Colorado: Requires PFAS labeling for cookware and other consumer-facing goods.
• Minnesota: Prohibits PFAS in specific product categories.
  
  

Global Trends

PFAS regulation isn’t limited to the U.S. — it’s a growing international priority. From Europe to Canada and beyond, regulatory bodies are rolling out new measures that electronics companies must monitor and comply with to maintain global market access.

• European Union: Under REACH, a broad restriction proposal aims to eliminate all non-essential PFAS uses — including electronics parts, coatings, and cables.
• Canada: Under CEPA, PFAS reporting was required in 2024 for 2023 activities, with a Jan. 29, 2025, deadline. Electronics components and goods are included. Future restrictions may target specific industry applications.

Lead Your Industry in Meeting Electronics Compliance Standards Understanding PFAS requirements is just the beginning. Discover how electronics manufacturers can meet today’s toughest compliance expectations — from material traceability to environmental reporting. Learn more about electronics compliance standards:

Key Responsibilities for Purchasers in 2025

For B2B electronics procurement professionals, PFAS compliance is not just a supplier issue — it’s also a strategic business risk. Whether you’re sourcing enclosures, harnesses, PCBs, or finished electronic assemblies, you must proactively verify compliance across the supply chain.

What you need to collect:

• Full Material Declarations (FMDs): Identify regulated PFAS at the part number level
• Updated Safety Data Sheets (SDS): Ensure accurate PFAS disclosures
• Supplier Compliance Certifications: Confirm PFAS-free or regulation-compliant status
• Documentation for TSCA/TRI Submissions: Maintain internal records of PFAS usage, exposure, and disposal

Key PFAS Questions to Ask Electronics Suppliers

Your supply chain partners are your first line of defense against PFAS compliance issues. Don’t wait for them to come to you — initiate the conversation now. Establishing clear supplier accountability is a cornerstone of effective PFAS compliance.

Use these targeted questions to evaluate supplier readiness and uncover potential risks in your sourcing network:

1. Are any of your products or components manufactured using PFAS-based materials or coatings?
2. Can you certify compliance with TSCA Section 8(a)(7) and TRI reporting requirements?
3. How are you tracking updated PFAS regulatory lists, including EPA, REACH, and CEPA?
4. Do you offer alternative materials for PFAS-free applications?
5. Are you using third-party compliance platforms to manage PFAS data?
   
   

Best Tools to Manage PFAS Data and Supplier Compliance

Keeping up with evolving PFAS regulations and supplier responses requires robust systems. The tools below can help you manage incoming data, centralize documentation, and ensure audit readiness:

• Source Intelligence
• Assent Compliance
• IMDS (for automotive electronics)
• SiliconExpert
• Internal supplier management platforms with compliance modules

Digital systems can automate supplier outreach, track declarations, flag high-risk materials, and generate compliance reports for audits and customer documentation.

Internal Actions to Stay Ahead of PFAS Regulations

PFAS compliance is an exercise in internal coordination to futureproof your operations. To build a resilient compliance program, electronics manufacturers should take these internal steps:

• Form a cross-functional PFAS compliance team: Include the procurement, engineering, regulatory affairs, and quality control departments
• Assess your PFAS risk: Identify all PFAS uses in production and finished goods
• Prioritize PFAS-free material selection: Seek out viable alternatives whenever feasible
• Set up strong rules for managing your suppliers: Add PFAS compliance to vendor contracts, scorecards, and onboarding
• Revise design specifications: Engineer out PFAS where possible
• Invest in testing and analysis: Verify PFAS levels in raw materials and final products
• Develop a reporting system: Align with TSCA and TRI reporting formats and submission timelines
• Plan for long-term transition: Assume future regulations will be even tighter – prepare now
  
  

Business Risks for Noncompliant Electronics Companies

Failing to meet PFAS compliance obligations doesn’t just mean regulatory penalties. It could also impact your business in more profound ways:

• Lost contracts: Many OEMs and defense contractors are now requiring verified PFAS declarations for all Tier 1 and 2 suppliers.
• Market exclusion: EU and California laws will disqualify companies from selling noncompliant products.
• Increased costs: Delays from noncompliance can increase rework and sourcing expenses.
• Reputation damage: B2B buyers and partners are paying close attention to Environmental, Social, and Governance (ESG) credentials.

These risks aren’t theoretical — they’re already affecting sourcing decisions, customer contracts, and go-to-market timelines. Proactive PFAS compliance is a competitive advantage.

Embracing a PFAS-Free Future in Electronics

For companies that make electronics and the businesses that buy from them, the rules around PFAS chemicals are going to change a lot in 2025. This means they'll need to be much more open about the materials they use, carefully pick what goes into their products, and work closely with their suppliers.

Failure to adapt to these evolving PFAS requirements can lead to disrupted supply chains, compromised product integrity, loss of market access, and potential legal liabilities.

Collecting the right data, engaging suppliers, and planning ensure electronics companies stay compliant and lead the shift to safer, more sustainable solutions.

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