With increasing scrutiny on the presence of PFAS in consumer products, states have been rolling rolling out new legislation aimed at limiting or eliminating intentionally added PFAS, beginning with menstrual products where there is a perceived gap in regulation.
California's legislation seeks to regulate both intentionally and unintentionally added PFAS. Questions are already swirling as to how to regulate the unintentional addition of chemicals that are ubiquitous in the environment and the additional requirements for manufacturers to monitor all aspects of the supply chain where unintentional exposure may occur.
For manufacturers of menstrual products, and other consumer care products that may ultimately be subject to the same scrutiny, industry experts suggest starting with a thorough review of the supply chain.
Manufacturers' first step should be to conduct a desktop analysis to see whether PFAS compounds are currently identifiable throughout the supply chain, Baroni said. Manufacturers should also look at which compounds come up repeatedly in the intentionally added category, versus which compounds are more obscure and not intentionally added, she said.
This article is presented for informational purposes only and is not intended to constitute legal advice.
