Achievements and Challenges of PFAS Regulation

by Kanako Kinoshita | 23 February 2026 | Environment, GNV News, World

GNV News, February 23, 2026

In the latest study published on January 26, 2026, researchers found that in the livers of whales in the North Atlantic, the concentration of extractable organofluorine compounds—an indicator of the total amount of “forever chemicals” PFAS (※1)—decreased by more than 60% between 2011 and 2023.

Because PFAS have strong carbon–fluorine bonds within their molecules, they are extremely resistant to degradation and are feared as “forever chemicals.” They repel water and oil and are highly resistant to heat and chemicals, so they are used in frying-pan coatings, food packaging, textiles, cosmetics, medical devices, and electronic-device coatings, among others. However, serious health risks have been pointed out, including cancer, impacts on the immune system, and developmental disorders. Because they are persistent, they tend to remain and accumulate in the human body, and at the ecosystem level, once released into the natural environment, they bioaccumulate and build up in organisms at the top of the food chain (such as whales in the oceans). The decrease in PFAS concentrations in whale bodies seen in this study indicates that PFAS released into the oceans has declined, and a major factor cited is the discontinuation of production of legacy PFAS (※2) at the international level in the early 2000s. There is a gap of about 10 years between the end of production and the observed decrease in concentrations, which is thought to be mainly due to the time required for transport through the oceans.

Although the total amount of PFAS released into the ocean is believed to be decreasing, some types of PFAS are actually increasing. One of these is C4 FASA (perfluorobutanesulfonamide), a substitute for legacy PFAS. From 2001 to 2023, its concentration in whale bodies increased at an average annual rate of about 7%. It has been suggested that this substance may have toxicity comparable to that of legacy PFAS, and the “regrettable substitution” of using new PFAS similar to legacy ones is becoming a major problem. In addition, in human blood data, total organofluorine levels remain high, raising the possibility that new PFAS are accumulating not in the oceans but in terrestrial and coastal regions.

As this shows, it is impossible in practice to study each of the more than ten thousand types of PFAS, including new ones that may turn out to be toxic, one by one. In terms of regulation as well, in some U.S. states, the European Union, Canada, and elsewhere, there is a growing trend away from regulating individual PFAS and toward comprehensive regulation by chemical “class.”

In the United States, state-level PFAS regulations were implemented on January 1, 2025. However, the scope of PFAS covered, the products targeted, and the allowable thresholds differ from state to state, creating complexity that is a challenge for companies. At the same time, a reporting rule has been established requiring all companies that export products containing PFAS to report on roughly the past 10 years of PFAS use. In the European Union, PFAS regulation accelerated dramatically in 2025, aiming for a phased phase-out leading to an almost complete ban on PFAS. In France, starting in 2026, the use of PFAS in cosmetics, textile products and footwear, and ski wax will be banned; the manufacture, import, export, and sale of a wide range of products containing PFAS will also be prohibited, and a “polluter pays” tax has been introduced. Japan, Australia, and Taiwan are also moving forward with setting standards, regulations, and assessments for a wider variety of PFAS than in the past.