One of the most common questions we hear: "Our pan uses PTFE, and our jacket uses an ePTFE membrane. Are those PFAS?" The answer to fluoropolymer PFAS rules depends on the state, the product and sometimes the test.
This guide explains how the main laws treat fluoropolymers and what that means for your proof.
Key takeaways
- Fluoropolymers like PTFE are PFAS under the broad definitions used by Minnesota and Maine.
- New Mexico is the first state to expressly exempt some fluoropolymers.
- California's textile law catches fluoropolymers through intent and total fluorine limits.
- EU food-contact packaging limits include polymeric PFAS in the 50 ppm total limit.
What fluoropolymers are
Fluoropolymers are large, plastic-like molecules made with carbon-fluorine bonds. Common examples:
- PTFE (polytetrafluoroethylene): nonstick coatings, seals, some coatings on cords and tapes
- ePTFE (expanded PTFE): breathable waterproof membranes in jackets, boots and gloves
- FEP, PFA, PVDF: wire coatings, tubing, some industrial parts
Industry groups argue fluoropolymers are stable and low-risk in use. Regulators counter that making and disposing of them can release smaller PFAS. That debate is why state laws differ.
How each jurisdiction treats fluoropolymers
| Jurisdiction | Fluoropolymers covered? | Notes |
|---|---|---|
| Minnesota | Yes | Broad definition: any substance with at least one fully fluorinated carbon atom |
| Maine | Yes | Similar broad definition |
| New Mexico | Partly exempt | First state with an express exemption for products containing certain fluoropolymers |
| California AB 1817 | Yes, in textiles | Intentionally added PFAS banned; total organic fluorine limits also apply |
| EU PPWR (food packaging) | Yes, in total limit | 50 ppm total PFAS limit includes polymeric PFAS |
Minnesota and Maine
Both laws define PFAS broadly, as substances with at least one fully fluorinated carbon atom. PTFE meets that test. So a PTFE nonstick coating on a pan counts as intentionally added PFAS. Cookware has been banned with intentionally added PFAS in Minnesota since January 1, 2025, and in Maine since January 1, 2026. Maine has granted some currently unavoidable use determinations for certain cookware, so check the current list.
New Mexico
New Mexico's PFAS Protection Act is the first state law to expressly exempt certain products that contain fluoropolymers from both its sales ban and reporting. Read the exemption's exact wording before relying on it. See New Mexico's PFAS Protection Act.
California
California's textile law bans regulated PFAS, defined by intentional use or a total organic fluorine threshold. An ePTFE membrane is intentionally added and would be caught, unless the product qualifies as outdoor apparel for severe wet conditions, which has until January 1, 2028 with a disclosure label. See AB 1817.
California's broader cookware ban (SB 682) was vetoed in 2025, so PTFE cookware is not banned there today, though disclosure rules apply. See California cookware disclosure.
Testing for fluoropolymers
This is a common trap. Targeted PFAS tests usually miss fluoropolymers, because they look for specific small molecules. A PTFE membrane can "pass" a targeted panel and still be intentionally added PFAS under state law.
Total fluorine methods usually detect fluoropolymers, because they measure all carbon-bound fluorine. If your goal is to confirm no fluoropolymer is present, choose a total fluorine method. See TOF testing explained.
What brands should do
- Ask suppliers specifically about fluoropolymers. "Does this material contain PTFE, ePTFE, FEP, PFA, PVDF or any other fluoropolymer?" Many suppliers don't think of polymers as PFAS.
- Check membranes and laminates. In outdoor gear, the membrane is often the only PFAS left after a switch to PFAS-free DWR.
- Check small parts. Zipper coatings, cord coatings, gaskets and some threads can contain fluoropolymers.
- Map by state. A product legal in New Mexico may be banned in Minnesota.
- Plan alternatives. Polyurethane and polyester membranes are common non-fluorinated options in apparel. Ceramic and stainless are common in cookware.
A note on reporting
In Minnesota, a product with an intentionally added fluoropolymer is reportable even if it isn't in a banned category. The report includes the PFAS, amount or range, and its purpose. See Minnesota PFAS reporting.
Where fluoropolymers hide in consumer products
Most brands know about nonstick pans and ePTFE jackets. These are easier to miss:
| Product | Possible fluoropolymer component |
|---|---|
| Rain jackets, gloves, boots | ePTFE membrane or laminate |
| Tents and shelters | PTFE-coated threads or seam tapes in some designs |
| Small kitchen appliances | PTFE-coated plates, baskets, seals |
| Water bottles and drinkware | Fluoropolymer seals or gaskets in some lids |
| Backpacks | Coated zippers, cords or webbing |
| Furniture | Some performance fabric finishes |
| Electronics accessories | Wire insulation (FEP, PFA) |
When you send supplier requests, list these by name. A supplier who would answer "no PFAS" may answer "yes, PTFE" when asked directly.
Example: one jacket, three states
A rain shell uses a PFAS-free DWR and an ePTFE membrane.
- Minnesota: Not in a 2025 banned category (general apparel), but reportable because the membrane is intentionally added PFAS. Banned from 2032 unless a CUU applies.
- California: The membrane is intentionally added PFAS, so the jacket fails AB 1817 unless it truly qualifies as outdoor apparel for severe wet conditions, in which case it needs a "Made with PFAS chemicals" disclosure until January 1, 2028.
- New Mexico: Textiles are banned with intentionally added PFAS from January 1, 2028. Check whether the fluoropolymer exemption could apply to the membrane before assuming either way.
Same product, three different answers. That's why per-state mapping matters.
Common questions from product teams
"Isn't PTFE inert?" Industry argues it's stable in use. That doesn't change how most state laws define PFAS today.
"Our supplier says the membrane is 'PFC-free.'" Ask whether it's PU, polyester or ePTFE. "PFC-free" sometimes refers only to the DWR.
Fluoropolymer checklist
- Supplier requests name PTFE, ePTFE, FEP, PFA and PVDF explicitly
- Every membrane identified by type (ePTFE, PU, polyester)
- Small parts checked: zippers, cords, seals, gaskets, threads
- Total fluorine method used where polymers are possible
- Per-state map: Minnesota and Maine (covered), New Mexico (check exemption), California (intent + TOF)
- Minnesota report includes fluoropolymer uses where present
Key terms
- Fluoropolymer: A large fluorinated polymer such as PTFE, FEP, PFA or PVDF.
- PTFE: Polytetrafluoroethylene, the classic nonstick coating.
- ePTFE: Expanded PTFE, used in waterproof-breathable membranes.
- Polymeric PFAS: PFAS in polymer form; included in the EU's 50 ppm total PFAS limit for food packaging.
- Fluoropolymer exemption: New Mexico's express exemption for certain products containing fluoropolymers.
The bottom line
Treat fluoropolymers as PFAS unless a specific state law says otherwise. Ask suppliers about them by name, test with total fluorine methods where polymers are possible, and map each product state by state, because New Mexico's exemption doesn't travel to Minnesota or Maine.
How Secuabase helps
Our supplier requests ask about fluoropolymers by name, so they don't slip through. We flag membranes, coatings and small parts that need a closer look, and we show which states treat each one differently.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
Is PTFE a PFAS?
Under most state definitions, yes. New Mexico is an exception that exempts some fluoropolymers.
Are ePTFE membranes allowed in outdoor apparel?
It depends on the state and category. In textile-ban states, an ePTFE membrane counts as intentionally added PFAS unless an exemption applies.
Do PFAS tests detect PTFE?
Targeted tests usually don't. Total fluorine methods usually do.
General information, not legal advice. Facts checked October 2026.
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