A PFAS-free claim sells. Shoppers want it, retailers ask for it, and many outdoor and cookware brands have made public pledges. But the claim is only as good as the proof behind it. Brands have faced lawsuits and retailer pushback when tests found PFAS in products marketed as free of them.
This guide covers what proof you need, which words are safer, and how to keep your claim true over time.
Key takeaways
- A PFAS-free claim needs component-level proof, not a supplier's website statement.
- "Made without intentionally added PFAS" is more defensible than "PFAS-free."
- Test the riskiest materials. Keep every test with its declaration.
- Re-check at least once a year and whenever a supplier or material changes.
Why PFAS-free claims are risky
Three things make the claim hard to defend:
- PFAS are everywhere in trace amounts. Water, air and shared machines can leave traces. A sensitive lab test may find something even when nothing was added.
- Supply chains change. A mill switches finish suppliers. A trim vendor changes zipper tape. Your claim was true last year and isn't now.
- Tests disagree. A targeted test might find nothing while a total fluorine test reads high, or the other way around. See TOF testing explained.
Plaintiffs' lawyers know this. Independent testing of popular products has led to class actions over PFAS claims in several product categories.
Choose your words carefully
| Wording | Risk | Notes |
|---|---|---|
| "PFAS-free" | Highest | Implies zero PFAS of any kind at any level |
| "100% PFAS-free" / "Zero PFAS" | Very high | Hard to prove; avoid |
| "Free of intentionally added PFAS" | Lower | Matches how most state laws define PFAS |
| "Made without PFAS chemicals in the finish" | Lower, but narrow | Only true if it's just about the finish; be clear |
| "PFC-free DWR" / "C0 DWR" | Low if accurate | Refers only to the water-repellent finish |
The safest claims match the scope of your proof. If you only checked the DWR, say the DWR. If you checked every component, you can speak about the whole product.
The proof file behind a claim
For each product carrying a claim, keep:
1. A complete component list
Shell, lining, membrane, insulation, trims, zippers, thread, labels, adhesives, coatings and packaging. See bill of materials mapping.
2. A signed declaration for each component
Each should name the material, the supplier, and state that no PFAS was intentionally added or used in its manufacture. Dated and signed by a named person. Use a standard form like our supplier PFAS declaration template.
3. Test reports for high-risk parts
Coated, laminated, water-repellent or stain-resistant materials should have a recent test. Total organic fluorine is a common screen.
4. A written conclusion
One short paragraph: what you checked, what you found, and why the claim is supported. Date it and name who reviewed it.
5. A review schedule
Set a date to re-check. At least yearly, plus any time a supplier, mill or finish changes.
Watch out for these red flags
- Supplier says "we comply with all laws." That's not a PFAS statement. Ask again.
- Declaration covers a supplier, not a material. "Our company does not use PFAS" doesn't tell you about the specific fabric you buy.
- Old test reports. A test from three years ago on a different lot proves little.
- Test on the wrong component. A shell fabric test doesn't cover the membrane.
- Only the finish is checked. Membranes, laminates and some trims can carry PFAS too.
PFAS-free claims and state law
State laws don't regulate the phrase "PFAS-free" itself, but they do interact with it:
- In California, textiles above the total organic fluorine limit are banned regardless of what you claim. The limit drops to 50 ppm on January 1, 2027. See California's 50 ppm limit.
- In Minnesota, products with intentionally added PFAS must be reported. A public PFAS-free claim that conflicts with your report would be hard to explain.
- Outdoor apparel for severe wet conditions sold in California with PFAS must carry a "Made with PFAS chemicals" disclosure until 2028. See the disclosure label.
Federal unfair-advertising rules also apply to environmental claims generally. A claim needs a reasonable basis at the time you make it.
A quick self-check before you publish a claim
Ask your team these five questions:
- Do we have a declaration for every component of this product?
- Do the declarations name the material, not just the supplier?
- Have we tested the coated or treated parts in the last 12 months?
- Does our wording match the scope of our proof?
- Do we have a date to re-check?
If any answer is no, fix that before the claim goes live.
Example: turning a weak claim into a strong one
Before: A brand's product page says "100% PFAS-free jacket." The file behind it holds one email from the fabric mill saying "our DWR is PFC-free."
What's missing: nothing about the membrane, zipper, seam tape, thread or labels. No test. No date. No signature.
After: The brand collects signed declarations for all eight components, runs a TOF test on the shell, membrane and zipper tape (all under 15 ppm), writes a one-page conclusion, and changes the wording to "Made without intentionally added PFAS." The claim is narrower but defensible, and the file can be handed to a retailer or lawyer the same day.
Keeping claims true over time
A claim that's true today can become false next season. Build these habits:
- Change triggers. Any new supplier, mill, finish, color or construction means a re-check before production.
- Supplier notice clause. Require suppliers to tell you before changing chemistry. See our supplier declaration template.
- Annual refresh. Re-collect declarations for high-risk materials every year.
- Spot tests. Test a rotating sample of materials each year, even when nothing has changed.
- One owner. Someone signs off on every claim before it goes on a hangtag or website.
Key terms
- PFAS-free claim: Any marketing statement saying a product has no PFAS. Needs proof that matches its scope.
- C0 DWR: A water-repellent finish made without fluorinated chemistry. Covers the finish only.
- Substantiation: The evidence you hold, at the time of the claim, showing it's true.
- Scope of claim: Which part of the product the claim covers: finish, fabric or whole product.
The bottom line
PFAS-free claims are valuable, but only as strong as the file behind them. Collect a declaration for every component, test the treated parts, choose words that match your proof, and re-check every year. A narrower claim you can defend beats a bold claim you can't.
How Secuabase helps
We collect a declaration for every component, check each one against the material, flag what needs testing, and give you a product file that shows exactly what your claim rests on. When a supplier changes, we re-ask.
For our first partners we run it free on one product line. Book a quick chat.
FAQ
Can I say my product is PFAS-free?
Only if you can prove it with declarations for every component and tests for the riskiest materials. Many brands use narrower wording.
What is the safest wording?
"Made without intentionally added PFAS" is more accurate than "PFAS-free," because trace contamination is hard to rule out.
Do PFAS-free claims lead to lawsuits?
Yes. Brands in several categories have faced class actions over PFAS claims. Strong proof is the best defense.
General information, not legal advice. Have counsel review marketing claims. Facts checked October 2026.
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