PFAS | Must Read As has always been the way in every regulatory shift, compliance is driven by the largest customers. Industry distributors selling to smaller businesses are likely to never have a problem. Distributors who deal with companies like Nestlé, General Mills and McDonald’s, etc., will have to be prepared, because those are the type of customers who are going to be unable to buy anything without conclusive proof that the goods they’re purchasing don’t contain proscribed PFAS chemicals. To be successful, these distributors need their suppliers to be prepared. “Suppliers in this industry are the ones that need to deal with this,” says Brenner. “They’re the ones that need to understand what’s in their products and whether or not PFAS is part of it. That’s going to be a matter of them contacting their testing lab, getting an education, reviewing their product categories, reviewing their products and developing a strategy, because the distributors in the industry are going to be asking, ‘Is there PFAS in it?’” Brenner adds, “It’s really challenging. I don’t think a distributor who’s trying to sell all day long, they don’t have time to be on the phone for three hours to get answers like this. They’re going to rely on the suppliers to be vetting their sources and understanding what’s in the products they’re selling. It’s going to be a big challenge for suppliers because they need to know what’s in everything they make.” Test, Test, Test The regulatory impact on the promo industry has the potential to be far reaching. PFAS’ ubiquity means it’s likely to found in a wide swath of the industry’s goods. “Take PFOA, one of the chemicals on California’s list,” says Brenner. “The question is, what’s PFOA in? Well, if you tried to test your products for every PFAS, it would be far too expensive. Different labs have different strategies, but basically the approach is to start with testing for either total fluorine or total organic fluorine under the basis that if it doesn’t have that in it, it can’t have PFAS in it because every PFAS bond is carbon and fluorine.” Pearson says, “Promo companies need to start testing and certifying their supply chains to ensure there are no intentionally added PFAS’ to their products. The companies with more robust testing and compliance programs already are doing this.” Help Is Available Promo companies aren’t alone in managing PFAS. Nana_studio / Shutterstock.com Testing companies like Bureau Veritas, QIMA, SGS and Intertek are already working with promotional products businesses on supply chain auditing, laboratory testing and product inspections. A first step for most suppliers as they deal with these chemicals will be to consult with a testing lab. “Promotional product distributors and suppliers are encouraged to work with third party testing labs like QIMA, who understand the unique challenges of bringing promotional products to market,” says Karolyn Helda, managing director of QIMA. “Companies may have small compliance departments or rely on staff to handle compliance and other responsibilities. It's hard for them to keep up with changing regulations and to fully understand their implications. Our technical experts monitor the laws and standards that impact consumer products on a global basis and can recommend options to help ensure compliance of your products based on your specific circumstances.” PPAI • APRIL 2023 • 51
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