In less than three months, the California 50 ppm PFAS limit takes effect. On January 1, 2027, the total organic fluorine (TOF) threshold for textiles under AB 1817 drops from 100 ppm to 50 ppm. Products that passed in 2025 and 2026 could fail in 2027.
Here's a focused checklist for the next ten weeks.
Key takeaways
- Threshold halves: 100 ppm → 50 ppm TOF on January 1, 2027.
- Intentionally added PFAS remain banned at any level.
- Reports saying "below 100 ppm" don't prove compliance at 50 ppm.
- Check high-risk components first: membranes, coated fabrics, repellent finishes, zipper tapes.
Recap: how AB 1817 works
A textile article sold in California may not contain regulated PFAS. Regulated PFAS means intentionally added PFAS or PFAS at or above the TOF threshold. The threshold was 100 ppm from January 1, 2025, and becomes 50 ppm from January 1, 2027. Full details in our AB 1817 guide.
The change matters most for products without intentionally added PFAS, where contamination or residue gives a TOF reading between 50 and 100 ppm.
Who's most at risk
- Brands that switched to PFAS-free DWR recently. Mills may have residue from old fluorinated finishes on shared equipment.
- Products with recycled synthetics. Recycled feedstock can carry legacy fluorine.
- Laminates and coated fabrics. Adhesives and coatings can add fluorine.
- Anyone with "below 100 ppm" test reports. That number no longer proves anything.
The 10-week checklist
1. Pull your California textile list
Every textile article you sell in California: apparel, bags, bedding, towels, upholstery fabric, accessories.
2. Review every TOF report
Sort them into three buckets:
- Below 50 ppm (with a reporting limit under 50): ready.
- Between 50 and 100 ppm, or "below 100" only: needs action.
- No test: decide if one is needed based on risk.
3. Re-ask suppliers
For the "needs action" group, ask suppliers for a current TOF result at a reporting limit under 50 ppm. Many mills test regularly. See getting suppliers to respond.
4. Test the gaps
Order TOF tests for high-risk materials with no current data. Lab turnaround can take a couple of weeks, longer in December. Order now. See PFAS testing cost.
5. Decide on non-compliant stock
If a material tests between 50 and 100 ppm:
- Can you sell through before January 1, 2027?
- Can you hold it from California channels?
- Can you switch to a cleaner material for new production?
Get advice on how the law treats inventory already in the channel.
6. Update your declarations
Make sure supplier declarations reference the 50 ppm standard going forward, not just 100 ppm.
7. Brief your buyers
Retailers will ask. A short note per product saying "AB 1817 compliant at 50 ppm, evidence on file" saves time.
Reading a TOF report correctly
Check three things:
- Material. Does it match the exact fabric, color and finish you buy?
- Reporting limit. If the lab's limit is 50 ppm or higher, "not detected" doesn't prove below 50.
- Date. Recent tests on current lots are stronger evidence.
What about severe-wet outdoor apparel?
Outdoor apparel for severe wet conditions has until January 1, 2028, with a "Made with PFAS chemicals" disclosure. The 2027 change doesn't move that date. See the disclosure label.
Example triage of a 60-fabric library
A home textiles brand reviewed every TOF report in October 2026:
| Bucket | Fabrics | Action |
|---|---|---|
| Below 50 ppm, current, low reporting limit | 31 | No action |
| Below 50 ppm, but report older than 18 months | 9 | Ask suppliers for current results |
| "Below 100 ppm" only | 7 | Retest at a lower reporting limit |
| 50–100 ppm | 3 | Ask mills about the finish; switch or hold from California |
| No test, low risk (untreated cotton) | 10 | Declaration only |
Ten fabrics needed real work. Knowing that in October, not December, made it manageable.
Why fabrics land between 50 and 100 ppm
When no one intentionally added PFAS, readings in this range usually come from:
- Residue on shared finishing equipment at mills that also run fluorinated finishes
- Recycled synthetic feedstock carrying legacy fluorine
- Coatings or adhesives in laminates
- Contaminated process water
- Test method differences between labs
Ask the mill which applies. Some can clean lines, change sub-suppliers or run dedicated equipment.
Other California dates to keep in mind
- January 1, 2027: SB 54 PRO-join deadline cited by CalRecycle. See SB 54 guide.
- January 1, 2028: Severe-wet outdoor apparel exception ends.
- By July 1, 2030: AB 347 enforcement by DTSC. See AB 347.
Questions teams ask
"Do we need to relabel anything for 50 ppm?" No new label is created by the 50 ppm change. It's a content limit.
"Will retailers ask?" Most already do. Expect their PFAS questionnaires to reference 50 ppm.
"What about products we only sell online?" Online sales into California count.
50 ppm checklist
- California textile SKUs listed
- TOF reports sorted into ready, needs action and untested
- Suppliers asked for current results with low reporting limits
- New tests ordered for high-risk gaps
- Plan for any material between 50 and 100 ppm
- Declarations updated to reference 50 ppm
- Buyer note prepared per product
What to do this week
- Pull every TOF report on file and sort it into the three buckets above.
- Email suppliers in the "needs action" bucket asking for a current result with a reporting limit well below 50 ppm.
- Get two lab quotes for any tests you'll need, and ask about December turnaround.
- Brief your wholesale team so they can answer buyer questions about 50 ppm with confidence.
Key terms
- Threshold: The TOF level at or above which PFAS count as regulated: 100 ppm until December 31, 2026, 50 ppm from January 1, 2027.
- Reporting limit: The lowest level a lab reports; it must sit well below 50 ppm.
- Legacy fluorine: Fluorine left over from older fluorinated finishes, often found in recycled fibers or shared equipment.
- Dye lot: A batch of fabric dyed together; finishes can vary between lots.
- Sell-through: Selling existing stock before a deadline.
Mistakes to avoid
- Treating a "below 100 ppm" result as proof for 2027.
- Testing only the main fabric and skipping membranes and zipper tapes.
- Waiting until December, when lab turnaround slows.
The bottom line
The 50 ppm limit catches products that were fine under 100 ppm. Sort your TOF reports now, chase current data from suppliers, test the gaps before lab queues fill up, and have a plan for anything in between before January 1, 2027.
How Secuabase helps
We review every TOF report you hold, flag the ones that won't hold up at 50 ppm, re-ask suppliers for current data, and show you which products are ready for January 1, 2027.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
What changes on January 1, 2027?
The TOF threshold drops from 100 ppm to 50 ppm.
Does it apply to inventory?
Plan as if anything sold after January 1, 2027 must meet 50 ppm; confirm with counsel.
Do I need to retest?
Yes, if prior results were between 50 and 100 ppm or only said "below 100."
General information, not legal advice. Facts checked October 2026.
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