PFAS & BPA
Plain-English explanations, our policy, the testing behind it, and how to talk about it.
What it is — plain English
PFAS stands for Per- and Polyfluoroalkyl Substances — a large family of man-made chemicals widely used in textiles, packaging, and industrial processes for their water and stain-repellent properties. They are sometimes called "forever chemicals" because they break down very slowly in the environment and can accumulate in living organisms over time.
In recycled polyester, PFAS are not intentionally added. However, because Tex2Tex® processes post-industrial textile waste, trace levels of PFAS can occasionally be present in the incoming feedstock as legacy contamination from previous treatments applied to those textiles before they became waste.
This is why Tex2Tex® tests for PFAS — not because they are used, but because responsible recycling requires verifying that they are not carried through the recycling loop into new products.
No-intentional-use policy
Tex2Tex® applies a strict No Intentional Use policy for PFAS, with particular emphasis on long-chain PFAS (C6+ chemistry).
This means:
- No PFAS compounds are deliberately added at any stage of the Tex2Tex® recycling or fiber production process
- PFAS are not used as process aids, finishing agents, or functional additives within the TMR™ thermo-mechanical system
- Any trace presence detected in testing is assessed as potential legacy contamination from recycled feedstock, not as a result of intentional use
- Where trace detection occurs at extremely low levels, results are interpreted against REACH, AFIRM, and applicable EU restrictions to confirm compliance within globally accepted thresholds
This policy is documented in the Tex2Tex® Chemical Compliance Guideline V3.0 (March 2026) and applies to all Tex2Tex® recycled polyester placed on the market.
Testing methods
EN 17681-1 and Total Fluorine
EN 17681-1 — what it tests
EN 17681-1:2025 is the primary European standard method for targeted PFAS analysis in textiles and synthetic coated fabrics. It uses alkaline hydrolysis to break down PFAS compounds, followed by liquid chromatography-mass spectrometry (LC-MS) to identify and quantify specific targeted PFAS substances.
What it covers:
- PFOS and its salts (limit: 25 ppb total)
- PFOA and its salts (limit: 25 ppb total)
- PFHxS and its salts (limit: 25 ppb total)
- C9–C14 Perfluorocarboxylic acids (PFCAs) and their salts (limit: 25 ppb total)
- PFHxA and its salts (limit: 25 ppb total)
- A range of PFAS-related substances at corresponding limits
Important limitation: EN 17681-1 quantifies targeted PFAS analytes only. Certain PFAS substances — including some precursor compounds and fluorotelomer-based substances — may not be fully detectable using this method alone. Some substances listed in EU regulations are hydrolysed during testing and will never be directly detected; instead, they are reported as their converted related substances. This is why Tex2Tex® applies a complementary Total Fluorine screening method alongside EN 17681-1.
Total Fluorine — what it tests
Total Fluorine (TF) analysis is a complementary screening method that measures the total fluorine content in a material, regardless of which specific PFAS compounds may be present. It acts as a broad-spectrum net — capturing both known and unknown PFAS, as well as any fluorinated compounds that targeted methods may miss.
Tex2Tex® applies Total Fluorine testing using EN 14582:2016 or ASTM D7359, with an internal limit of 100 mg/kg.
Why this matters: many suppliers only test for named, targeted PFAS compounds. A material could pass targeted testing while still containing unidentified PFAS if only EN 17681-1 is used. Total Fluorine screening closes this gap — if Total Fluorine results are low, it confirms that the overall fluorine burden in the material is minimal, regardless of compound identity. This dual approach reflects best practice and provides a more robust, defensible position for brand compliance teams.
Standards alignment
REACH / AFIRM / ZDHC / OEKO-TEX®
| Standard | PFAS Requirement | Tex2Tex® Alignment |
|---|---|---|
| REACH | Restrictions on PFOS, PFOA, PFHxS, C9–C14 PFCAs and related substances under Annex XVII and Persistent Organic Pollutants Regulation | Tested and aligned; limits adopted as per most restrictive applicable threshold |
| AFIRM RSL 2026 | PFAS phase-out guidance; targeted limits for key PFAS families in finished textile articles | Aligned; AFIRM limits incorporated into Tex2Tex® RSL Table 1 |
| ZDHC MRSL v3.1 | Input chemistry control — no intentional PFAS use in manufacturing processes | Aligned; No Intentional Use policy in place for all Tex2Tex® production processes |
| Oeko-Tex® Standard 100 | RSL-level compliance for PFAS in consumer textile articles | Tex2Tex® meets or exceeds Oeko-Tex® RSL alignment through Intertek testing; formal certification available upon customer request |
| France 2026 PFAS Decree | Bans specific PFAS in consumer textile articles from 2026; exemptions exist for secondhand and recycled goods and some specialised products | Tex2Tex® testing already aligned with upcoming requirements; monitoring in place |
| California Proposition 65 | Exposure-based limits where applicable to fluorinated substances | Monitored where relevant |
Note on analytical limitations: certain PFAS substances within EU regulations cannot be directly measured using EN 17681-1:2025 alkaline hydrolysis. These compounds require supply chain verification rather than product-level testing. Tex2Tex® addresses this through feedstock control and the Total Fluorine screening approach documented in the Chemical Compliance Guideline V3.0 PFAS Appendix.
Sales scripts
Suggested responses for PFAS questions
Q: "Recycled polyester is risky — how do you control PFAS contamination?"
You're right that recycled materials can carry legacy substances. The key difference is how they're managed. Tex2Tex® controls this through feedstock selection, process control, and validated analytical testing aligned with global RSL frameworks. We treat recycled input as a higher-risk starting point — so our controls are stricter, not looser.
Q: "Do you guarantee PFAS-free?"
We apply a strict no intentional use policy for PFAS and validate this through both targeted PFAS testing using EN 17681-1:2025 and total fluorine screening. Like all recycled systems, trace detection can occur at extremely low levels from legacy contamination in feedstock — but we ensure compliance with REACH, AFIRM, and upcoming EU restrictions. Batch testing is available on request.
Q: "We've seen PFAS contamination in recycled materials — why are you different?"
That's exactly why we use a dual testing approach — targeted PFAS analysis plus total fluorine screening. Many suppliers only test for known compounds, which can miss unknown PFAS. It's not about claiming zero — it's about detecting, controlling, and staying compliant.
Q: "Are you compliant with the French 2026 PFAS ban?"
Yes. Tex2Tex® has been tested using methods already aligned with the upcoming French 2026 PFAS requirements. Our testing covers the relevant PFAS families under the Decree, and our No Intentional Use policy means no C6+ PFAS chemistry enters our process. Note also that the French Decree includes exemptions for recycled goods — we monitor this closely and can share full details on request.
Q: "What about PFAS compounds that can't be detected by standard testing?"
This is an important and often overlooked point. EN 17681-1 is the industry-standard method but has known limitations for certain precursor compounds. That's why we complement it with Total Fluorine screening — which captures total fluorine burden regardless of compound identity. For specific substances that cannot be detected at the product level at all, we manage risk through feedstock supplier controls and supply chain verification, as documented in our PFAS Appendix.
Q: "How often do you test for PFAS?"
We follow a risk-based testing approach aligned with AFIRM, ZDHC, REACH, and Oeko-Tex®. This includes regular validation at six-month intervals as part of our RSL schedule, with priority monitoring for PFAS as a higher-risk chemical family within polyester recycling. Batch-level testing is also available on request.