Caraway Home sells nonstick cookware that is made with a non-toxic ceramic coating and without "forever chemicals" (i.e., per- and polyfluoroalkyl substances (PFAS)). The company advertised that "most traditional cookware is made with forever chemicals and when they are overheated, they can release those same toxins into your food and home." Cookware Sustainability Alliance challenged this and various other claims before NAD saying that the claims conveyed the unsupported messages that Caraway nonstick cookware is healthier and safer than competitor nonstick cookware and competitor nonstick cookware exposes consumers to a harmful form of PFAS.
Caraway argued that its claims were supported because polytetrafluroethylene (PTFE)—the PFAS compound used in traditional nonstick cookware—is known to be "toxic." The company's expert pointed to several studies showing that when PTFE-coated cookware is exposed to high enough temperatures, the material can decompose and release potentially dangerous fumes that consumers can inhale. PFAS is a broad category encompassing thousands of chemicals, and the Cookware Sustainability Alliance argued that not all PFAS behave the same or pose the same risks.
NAD found the studies to be a poor fit for the claims. NAD acknowledged that PTFE can release potentially harmful fumes—but only under extreme and uncommon cooking conditions (e.g., exposure to temperatures above 680°F for 4–6 hours). Caraway's error wasn't in citing PTFE's theoretical risks—it was in failing to demonstrate that consumers would actually encounter these risks during typical cooking. NAD has consistently required that health-related claims be backed by consumer-relevant evidence, not just lab studies or speculative expert opinions. Scientific facts should be tied to how consumers actually use a product.
NAD also pointed out that the Food and Drug Administration allows the use of PTFE in cookware and reaffirmed its position as recently as 2023. The Consumer Product Safety Commission also declined to require warning labels on nonstick cookware. While NAD acknowledged that regulatory approval isn't dispositive, it found that regulatory tolerance of PTFE under normal use further undercuts Caraway's broad comparative health claims.
NAD did not give weight to the numerous states that have banned PFAS in cookware and a variety of other products, including California, Colorado, Maine, Minnesota, Vermont, Connecticut and Rhode Island, with more planning to follow suit as part of a broader effort to reduce consumer exposure. A footnote in the Decision states that "NAD did not find the decisions of a handful of states (some of which the Challenger argued were in the process of revoking their restrictions) and government entities outside of the United States to be persuasive as to either party's position." PFAS are a category of chemicals, broadly defined in most state laws as having at least one fluorinated carbon atom, which exhibit a high degree of persistence (resistance to breaking down in the environment) and bioaccumulative potential (tendency to remain in the human body for long periods of time). While the scientific and regulatory communities have not settled on a single generally accepted definition, the competing options range in coverage from roughly 1,500 unique chemical formulations to over 15,000. The debate is heavily centered on whether to include fluoropolymers, such as PTFE, within the regulatory scope of "PFAS."
One lesson from this case is that when structuring tests or reviewing evidence to support a claim, it's important to ensure that products are tested under typical use conditions. It doesn't matter that a product performs a certain way under specific conditions if consumers will typically not use it under those conditions. Click here for another decision that applies this principle in a different industry.
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