Establishing a stronger foundation for credible PFAS claims
For too long, product claims concerning PFAS have depended on declarations that may reveal very little about the product that is actually being supplied.
“PFAS-free.”
“No intentionally added PFAS.”
“Compliant.”
Each statement may sound conclusive. Without a defined claim, suitable evidence and continuing control, however, none necessarily establishes what was assessed, which PFAS were considered, whether the complete finished product was examined, or whether the product being supplied today is the same as the product originally reviewed.
PFAS Free Australia’s position has remained consistent: a supplier declaration is an input, not the end of the verification process.
Our approach has long been grounded in the need for credible evidence, appropriate analytical verification and accountability throughout the supply chain.
PFAS FREE ASSURED™ formalises that position into a structured Assurance framework — connecting defined product claims, independent verification, Chain of Custody and continuing control of the evidence supporting those claims.
Why Assurance is different
A declaration records what a party says about a product.
Verification examines whether available evidence supports a particular claim at a particular point in time.
Assurance goes further. It connects the claim, the evidence, the product and the controls required to maintain confidence over time.
That connection must extend across the packaging lifecycle — from raw-material sourcing and manufacture, through chemical testing and the supporting evidence library, into commercial supply and market consumption, and ultimately to recycling, recovery or disposal.
A supporting Chain-of-Custody system provides the traceability needed to connect relevant materials, production stages, tested samples and documented evidence to the product being supplied. It should also enable the information required for responsible end-of-life decisions to be retained and made available where relevant.
Our operating principle is:
Declaration → Verification → Assurance
This progression matters because PFAS risk does not reside only in an obvious surface treatment.
Depending on the product and supply chain, relevant chemistry may involve raw materials, fibre, coatings, barriers, inks, adhesives, processing aids, recycled feedstock or substitutions made further upstream.
A single test result can provide valuable information. It cannot, on its own, explain every material input, prove continuing conformity or prevent an approved formulation from later being replaced.
Nor does the consequence of an inadequately verified chemical claim necessarily end when the packaging has served its original purpose.
Circular packaging is only circular if we know what chemistry we are circulating.
What PFAS FREE ASSURED™ represents
PFAS FREE ASSURED™ is the trade mark and identity for PFAS Free Australia’s structured approach to product and supply-chain Assurance.
It provides the framework for evaluating product claims involving PFAS and, where relevant, other chemicals of concern, through defined evidence requirements, verification, traceability and continuing control.
The framework brings together the following essential elements:
- a clearly defined claim and PFAS scope;
- product, component and intended-use definition;
- raw-material, formulation and supplier evidence;
- appropriate analytical methods and reporting limits;
- finished-article verification where required;
- documented sampling and product provenance;
- Chain of Custody across relevant supply-chain stages;
- controls for formulation, process, site and supplier changes;
- record retention, evidence review and continuing oversight; and
- independent assessment proportionate to the claim and risk.
These elements establish the architecture of the Assurance approach.
The formal operating rules, assessment procedures, governance arrangements and authorisation controls are being progressively implemented and validated. Formal Assurance status will depend on the applicable requirements being satisfied under those adopted arrangements.
The objective is not simply to place another logo or broad environmental claim on a product.
It is to establish a credible and transparent evidence system through which manufacturers, customers and other stakeholders can understand what a claim means, what supports it and how it continues to apply to the product in market.
Chain of Custody: connecting evidence to the product lifecycle
Chain of Custody is fundamental to PFAS FREE ASSURED™ because evidence has limited value if it cannot be connected to the product being manufactured, imported, sold or processed.
For packaging, that connection begins upstream.
It includes identifying relevant raw materials and suppliers, recording manufacturing and converting processes, maintaining product and sample provenance, and linking laboratory results to the materials and finished articles they are intended to represent.
The supporting evidence library must remain connected to the product as it moves through commercial supply.
Where practicable and relevant, product information should also support downstream understanding of the materials entering recycling, composting, recovery or waste-management systems.
A credible Chain-of-Custody system should identify:
- the approved product, material and supplier;
- relevant sites and production stages;
- batch, lot or other provenance records;
- where product identity or responsibility changes hands;
- which declarations, analytical results and other evidence apply to which product;
- when a material, supplier or process change requires review, retesting or reapproval;
- how exceptions and non-conformities are managed; and
- what relevant product information should remain available for downstream recovery and end-of-life decisions.
This does not imply that every individual package can be physically tracked through consumer use and disposal.
Rather, the objective is to maintain reliable product identity and evidence throughout the controlled supply chain, with relevant chemical and material information available to support downstream decisions.
But traceability alone is not Assurance.
A perfectly traceable product may still be supported by an inadequate claim or an inappropriate test method.
Assurance must therefore combine traceability with defined criteria, appropriate evidence, independent assessment and effective governance.
Testing must be connected to the claim
There is no single analytical method that answers every PFAS question for every product.
Different methods may screen for total fluorine, quantify selected individual PFAS, investigate precursors or help characterise unidentified fluorinated substances. Each method has a purpose and limitations.
Meaningful evaluation requires more than asking whether a product has “passed a PFAS test.”
It requires asking:
- What claim was the test intended to support?
- Which material or part of the product was sampled?
- Was the complete finished article represented?
- Which analytical method was used, and why?
- What were the detection and reporting limits?
- Which PFAS or fluorine measures were included — and excluded?
- Is the tested sample demonstrably connected to current commercial supply?
Testing becomes useful evidence when its scope, provenance and limitations are understood.
It becomes part of Assurance when that evidence is assessed against defined requirements and remains connected to the product through continuing supply-chain controls.
Why this matters commercially
PFAS expectations are changing across regulation, procurement, packaging design, recycling, organics processing and customer claims.
Manufacturers, importers and brand owners increasingly need to understand not only whether a supplier has provided a declaration, but whether that declaration is sufficiently specific and supported to withstand customer, regulator or market scrutiny.
Weak evidence can create practical consequences:
- product reformulation and requalification costs;
- customer claims or contractual disputes;
- obsolete or unsaleable inventory;
- inconsistent supply caused by unreported substitution;
- unsupported marketing and environmental claims;
- downstream contamination or disposal costs; and
- reputational damage where a confident claim cannot be substantiated.
The consequences may also extend beyond the original commercial transaction.
Recyclers, composters and waste-management operators can inherit materials whose chemical composition was determined much earlier in the supply chain, often without access to the evidence needed to assess their suitability for recovery.
Stronger Assurance can also create value.
Suppliers able to demonstrate transparent chemistry, controlled sourcing, reliable verification and continuing conformity can differentiate themselves from competitors relying on generic declarations.
For brand owners and retailers, stronger evidence provides a more defensible basis for procurement and product claims.
For downstream recovery operators, improved information about incoming materials can support better risk management and more responsible circularity decisions.
Independent information. Better questions. Better informed decisions.
PFAS Free Australia was established in 2018 from a foundation in innovative PFAS-free packaging solutions.
What began with the development and supply of alternative packaging products has progressively expanded into a broader examination of the chemical integrity of packaging and the evidence required to substantiate claims made about it.
Experience across product development, sourcing, analytical testing and supply-chain evaluation highlighted a recurring problem: a supplier declaration may describe an intention or specification without adequately demonstrating the chemistry of the finished product being supplied.
PFAS Free Australia’s work has consequently grown beyond product supply to address the gap between product claims and the evidence needed to rely on them.
PFAS FREE ASSURED™ formalises that accumulated experience and established position into a defined Assurance framework.
Our continuing work includes the implementation and validation of the governance, technical criteria, Chain-of-Custody controls and assessment procedures required to support formal Assurance decisions.
As those arrangements are implemented, we distinguish clearly between:
- independent information and guidance;
- product and evidence review;
- analytical verification and supporting technical assessment; and
- formal Assurance under the applicable adopted governance and authorisation requirements.
That distinction is essential to the integrity and credibility of the system.
The question is no longer simply whether someone has declared that PFAS was not added.
The question is:
What does the claim mean, what evidence supports it, and how do we know that evidence still belongs to the product being supplied?
And increasingly, there is another question:
What happens to that chemistry when the product reaches the end of its useful life?
That is why PFAS Free Australia places continuing product evidence, supply-chain accountability and chemical integrity at the centre of its Assurance approach.
From Declaration → Verification → Assurance.
