That ‘PFAS‑Free’ Jacket Label Might Mean Almost Nothing in 2026: The 3 Legal Loopholes Brands Use (and which states just shut them)
In 2026, “PFAS‑free” often means “not intentionally added,” not “zero PFAS.” Here’s how three loopholes work—and how California, New York, and Vermont are narrowing them.
By TheMurrow Editorial
April 6, 2026
Key Points
- 1Learn the core loophole: many laws regulate intentionally added PFAS, letting “PFAS‑free” mean compliant—not necessarily analytically absent.
- 2Track the carve-outs: “severe wet conditions” exemptions can keep PFAS in flagship rain gear while brands market other lines as “PFAS‑free.”
- 3Follow the state clampdown: CA uses TOF thresholds (100 ppm in 2025; 50 ppm in 2027) while NY and VT set major dates.
A few years ago, “PFAS‑free” sounded like a promise. In 2026, it often reads like a riddle.
Outdoor brands plaster the phrase on hangtags and homepages, and consumers—tired of chemical alphabet soup—reach for the simplest signal available. The trouble is that “PFAS‑free” sits at the intersection of complex chemistry, shifting state laws, and performance marketing. The result is a claim that can be technically true, meaningfully misleading, or both at once.
Why the label carries so much heat
One reason the label carries so much heat is scale. PFAS—short for per‑ and polyfluoroalkyl substances—are a large class of chemicals prized for water and oil repellency, and they’ve been widely used in performance textiles, especially durable water repellent (DWR) finishes and some membrane systems used in waterproof/breathable gear. Outdoor Life explains that the same properties that make PFAS useful in rain shells also make the chemicals persistent and difficult to manage once released. And exposure is not a niche concern: one commonly cited estimate based on NHANES 2011–2012 analysis suggests about 97% of Americans have PFAS in their bloodstream. (Outdoor Life)
That difference—between “absent” and “not intentionally added”—is where the marketing minefield begins.
That difference—between “absent” and “not intentionally added”—is where the marketing minefield begins.
~97%
A commonly cited estimate from NHANES 2011–2012 analysis suggests about 97% of Americans have PFAS in their blood. (Outdoor Life)
In 2026, ‘PFAS‑free’ often doesn’t mean ‘PFAS‑absent.’ It means ‘PFAS‑not‑intentionally‑added.’
— — TheMurrow
Why “PFAS‑Free” Became a Consumer Flashpoint
PFAS matter to shoppers because the conversation has moved from obscure regulatory talk to everyday life. The chemicals show up in headlines, lawsuits, and statehouse debates. Consumers see the same three themes repeated: PFAS are widespread, persistent, and hard to avoid. When nearly everyone is presumed exposed, people start looking for levers they can pull—like the jacket they buy.
Performance apparel sits at the center of the fight because PFAS have been a workhorse ingredient for decades. Outdoor Life notes that PFAS have been used for water/oil repellency and durability in performance textiles—especially DWR finishes and some membrane systems in waterproof/breathable gear. Those are precisely the garments where consumers care most about performance claims: shells, parkas, waders, and workwear.
The other reason “PFAS‑free” became combustible is structural. Many laws focus on “intentionally added” PFAS—a legal concept that matters for enforcement but doesn’t map neatly onto what shoppers imagine when they hear “free.” A product can comply with an “intentionally added” ban while still containing trace PFAS from contamination, recycled inputs, chemical auxiliaries, or upstream processing. California’s legislative approach and other states’ statutes show how governments are trying to define the boundary between intentional formulation and incidental presence, but the consumer label rarely carries that nuance.
Performance apparel sits at the center of the fight because PFAS have been a workhorse ingredient for decades. Outdoor Life notes that PFAS have been used for water/oil repellency and durability in performance textiles—especially DWR finishes and some membrane systems in waterproof/breathable gear. Those are precisely the garments where consumers care most about performance claims: shells, parkas, waders, and workwear.
The other reason “PFAS‑free” became combustible is structural. Many laws focus on “intentionally added” PFAS—a legal concept that matters for enforcement but doesn’t map neatly onto what shoppers imagine when they hear “free.” A product can comply with an “intentionally added” ban while still containing trace PFAS from contamination, recycled inputs, chemical auxiliaries, or upstream processing. California’s legislative approach and other states’ statutes show how governments are trying to define the boundary between intentional formulation and incidental presence, but the consumer label rarely carries that nuance.
What shoppers think they’re buying vs. what the law often regulates
When most people read “PFAS‑free,” they picture zero PFAS. Many state rules, however, target whether PFAS were deliberately used—not whether a lab could detect any fluorinated signal in the material. That mismatch is not a small semantic gap. It determines whether a brand’s claim is a strong health-and-environment commitment—or a compliance statement dressed as a moral one.
The law often asks, ‘Did you add PFAS on purpose?’ Shoppers ask, ‘Is it in there?’ Those are different questions.
— — TheMurrow
PFAS in Outdoor Gear: Why the Chemistry Is Hard to Quit
Brands didn’t choose PFAS because it sounded good on a spec sheet. They chose it because it works.
Outdoor Life’s overview links PFAS use to repellency and durability—two properties that define technical apparel. A DWR treatment that shrugs off rain for a season changes how a jacket feels, how heavy it gets when wet, and whether it keeps insulating layers dry. Some waterproof/breathable constructions also relied on fluorinated chemistry to deliver a certain balance of waterproofness, breathability, and longevity.
That performance history creates a real tension in the market. Consumers want fewer persistent chemicals in their lives. Many also want the same stormproof shell they’ve always depended on. The moment a brand claims “PFAS‑free,” buyers reasonably ask: does it still perform? And if a brand avoids the phrase, buyers may assume the worst.
Outdoor Life’s overview links PFAS use to repellency and durability—two properties that define technical apparel. A DWR treatment that shrugs off rain for a season changes how a jacket feels, how heavy it gets when wet, and whether it keeps insulating layers dry. Some waterproof/breathable constructions also relied on fluorinated chemistry to deliver a certain balance of waterproofness, breathability, and longevity.
That performance history creates a real tension in the market. Consumers want fewer persistent chemicals in their lives. Many also want the same stormproof shell they’ve always depended on. The moment a brand claims “PFAS‑free,” buyers reasonably ask: does it still perform? And if a brand avoids the phrase, buyers may assume the worst.
The performance trap: “PFAS‑free” as a proxy for “less protective”
Not every shopper will accept a tradeoff. Some will; many won’t. That’s why exemptions exist in state laws (more on that below), and it’s why marketing departments sometimes reach for phrasing that sounds absolute while remaining legally defensible.
The more honest framing—rarely used on hangtags—is that the industry is moving along a spectrum:
- Removing intentionally added PFAS from many categories
- Managing trace contamination through supply-chain controls
- Reserving PFAS use (sometimes legally) for edge cases where performance demands are extreme
The more honest framing—rarely used on hangtags—is that the industry is moving along a spectrum:
- Removing intentionally added PFAS from many categories
- Managing trace contamination through supply-chain controls
- Reserving PFAS use (sometimes legally) for edge cases where performance demands are extreme
A key statistic with context
- ~97%: A commonly cited estimate from NHANES 2011–2012 analysis suggests about 97% of Americans have PFAS in their blood. (Outdoor Life)
This statistic doesn’t tell you where any one person’s exposure came from. It does explain why “PFAS‑free” became a potent consumer signal: people feel surrounded, so small choices feel consequential.
This statistic doesn’t tell you where any one person’s exposure came from. It does explain why “PFAS‑free” became a potent consumer signal: people feel surrounded, so small choices feel consequential.
Loophole #1: “PFAS‑Free” Means “No Intentionally Added PFAS”
The most widespread loophole isn’t a shady tactic. It’s the logical consequence of how many states drafted their rules.
Several laws prohibit intentionally added PFAS, which allows a brand to say a product meets the rule without guaranteeing it is analytically PFAS‑free in an absolute sense. That’s not hypothetical. Vermont’s statute is explicit: it prohibits textiles and textile articles to which “regulated PFAS have been intentionally added in any amount” starting January 1, 2026. (Vermont Legislature)
New York’s structure shows the same split, with an added twist. A legal analysis from Morgan Lewis notes that New York’s ban on new apparel with intentionally added PFAS takes effect January 1, 2025, while the state’s Department of Environmental Conservation is directed to set a numeric threshold for PFAS in apparel by January 1, 2027. (Morgan Lewis)
Several laws prohibit intentionally added PFAS, which allows a brand to say a product meets the rule without guaranteeing it is analytically PFAS‑free in an absolute sense. That’s not hypothetical. Vermont’s statute is explicit: it prohibits textiles and textile articles to which “regulated PFAS have been intentionally added in any amount” starting January 1, 2026. (Vermont Legislature)
New York’s structure shows the same split, with an added twist. A legal analysis from Morgan Lewis notes that New York’s ban on new apparel with intentionally added PFAS takes effect January 1, 2025, while the state’s Department of Environmental Conservation is directed to set a numeric threshold for PFAS in apparel by January 1, 2027. (Morgan Lewis)
Why brands like the phrase “no intentionally added PFAS”
Because it’s defensible. A brand can redesign a DWR finish, certify its formulation choices, and still be vulnerable to trace PFAS coming from upstream processes. If the brand promises “PFAS‑free” without clarifying what it means, it has created a claim that chemistry and supply chains may not be able to guarantee.
Expert perspective (legal framing)
California’s AB 1817 and related state frameworks illustrate why the term “intentionally added” shows up so often: it’s enforceable. Legislatures can ask manufacturers what they deliberately used. Proving “zero” across a global supply chain is far harder.
A jacket can be ‘PFAS‑free’ in the intentional-use sense while still carrying trace PFAS—and the brand may not be lying, depending on the wording.
— — TheMurrow
Key dates and statistics
- January 1, 2026: Vermont ban begins for textiles with intentionally added regulated PFAS “in any amount.” (Vermont Legislature)
- January 1, 2025: New York ban begins for new apparel with intentionally added PFAS. (Morgan Lewis)
- January 1, 2027: Deadline for New York DEC to set a numeric threshold for PFAS in apparel. (Morgan Lewis)
- January 1, 2025: New York ban begins for new apparel with intentionally added PFAS. (Morgan Lewis)
- January 1, 2027: Deadline for New York DEC to set a numeric threshold for PFAS in apparel. (Morgan Lewis)
Jan 1, 2026
Vermont ban begins for textiles with intentionally added regulated PFAS “in any amount.” (Vermont Legislature)
Jan 1, 2025
New York ban begins for new apparel with intentionally added PFAS. (Morgan Lewis)
Jan 1, 2027
Deadline for New York DEC to set a numeric threshold for PFAS in apparel. (Morgan Lewis)
How California Tightened the Claim: Total Organic Fluorine Thresholds
Some states have tried to reduce the wiggle room by adding measurement-based thresholds. California is the clearest example in the provided research.
A Taft Law summary explains that California’s framework uses total organic fluorine (TOF) thresholds—100 ppm starting January 1, 2025, and 50 ppm starting January 1, 2027—for covered textile articles. (Taft Law)
That matters because TOF is not simply a declaration of intent. It’s a screening concept that looks at fluorine content as a proxy for PFAS-like chemistry. The approach doesn’t identify every compound. It doesn’t provide a perfect inventory. Taft’s analysis emphasizes the nuance: TOF “reduces the wiggle room” compared to intention-only regimes, but doesn’t eliminate ambiguity because it’s a screening metric, not compound-by-compound identification.
A Taft Law summary explains that California’s framework uses total organic fluorine (TOF) thresholds—100 ppm starting January 1, 2025, and 50 ppm starting January 1, 2027—for covered textile articles. (Taft Law)
That matters because TOF is not simply a declaration of intent. It’s a screening concept that looks at fluorine content as a proxy for PFAS-like chemistry. The approach doesn’t identify every compound. It doesn’t provide a perfect inventory. Taft’s analysis emphasizes the nuance: TOF “reduces the wiggle room” compared to intention-only regimes, but doesn’t eliminate ambiguity because it’s a screening metric, not compound-by-compound identification.
Why TOF changes marketing behavior
A brand can still say “no intentionally added PFAS,” but California’s thresholds pressure manufacturers to manage fluorinated content more comprehensively. If a product needs to meet a 50 ppm TOF bar by 2027, “we didn’t add it” becomes less protective as a shield. Supply chains must work harder to keep fluorinated residues low.
Key statistics with context
- 100 ppm TOF (Jan 1, 2025) and 50 ppm TOF (Jan 1, 2027): California’s thresholds for covered textile articles. (Taft Law)
These numbers are not “health safe” thresholds; they’re compliance thresholds used to narrow loopholes in textile regulation.
These numbers are not “health safe” thresholds; they’re compliance thresholds used to narrow loopholes in textile regulation.
100 ppm → 50 ppm
California’s TOF thresholds for covered textile articles: 100 ppm (Jan 1, 2025), then 50 ppm (Jan 1, 2027). (Taft Law)
Loophole #2: The “Severe Wet Conditions” Exemption
The most controversial carve-out is also the most understandable—at least on paper.
Several laws exempt or delay restrictions for “outdoor apparel for severe wet conditions” (or similar), generally framed as extreme and extended use items intended for “outdoor sports experts,” and not marketed for general consumer use. A Great Lakes PFAS policy compilation hosted by the National Sea Grant Law Center describes how such exemptions are written and how they can be interpreted strategically. (NSGLC/olemiss.edu)
This is the performance carve‑out in action: lawmakers accept that some technical gear still relies on PFAS chemistry, so they create a narrow exception. The trouble is that “severe,” “extended,” and “expert” can become elastic words.
Several laws exempt or delay restrictions for “outdoor apparel for severe wet conditions” (or similar), generally framed as extreme and extended use items intended for “outdoor sports experts,” and not marketed for general consumer use. A Great Lakes PFAS policy compilation hosted by the National Sea Grant Law Center describes how such exemptions are written and how they can be interpreted strategically. (NSGLC/olemiss.edu)
This is the performance carve‑out in action: lawmakers accept that some technical gear still relies on PFAS chemistry, so they create a narrow exception. The trouble is that “severe,” “extended,” and “expert” can become elastic words.
Where the exemption can blur
Consider how outdoor marketing works. Brands often want the credibility of “expedition-grade” performance while selling to a broad audience. When a statute hinges on whether an item is “not marketed for general consumer use,” the incentive is obvious: keep the product’s aura of extreme utility while positioning the marketing language carefully.
Nothing in the exemption automatically implies bad faith. The real point is that the exemption can preserve PFAS in flagship categories—rain shells, waders, and technical layers—while brands still advertise “PFAS‑free collections” elsewhere. Consumers see the headline and assume the closet is clean.
Nothing in the exemption automatically implies bad faith. The real point is that the exemption can preserve PFAS in flagship categories—rain shells, waders, and technical layers—while brands still advertise “PFAS‑free collections” elsewhere. Consumers see the headline and assume the closet is clean.
Practical takeaway for readers
When a brand says “PFAS‑free,” ask where the claim applies:
- Is it company-wide or only to selected lines?
- Does it exclude severe-wet or “pro” gear?
- Does the brand clarify “no intentionally added PFAS” or provide test-based thresholds?
- Is it company-wide or only to selected lines?
- Does it exclude severe-wet or “pro” gear?
- Does the brand clarify “no intentionally added PFAS” or provide test-based thresholds?
“PFAS‑Free” Isn’t One Claim: How to Read Labels Without Getting Played
Consumers deserve better than a scavenger hunt through footnotes, but 2026 is where we are. The most useful mental model is to treat “PFAS‑free” as a family of claims, not a single standard.
Three tiers of meaning you’ll see in 2026
1. Marketing shorthand: “PFAS‑free” with no definition
2. Compliance meaning: “No intentionally added PFAS” (aligned with many state bans)
3. Measurement-aligned meaning: A claim tethered to thresholds or testing frameworks (closer to California’s TOF approach)
State laws show why brands gravitate toward Tier 2. Vermont’s ban on intentionally added regulated PFAS in textiles begins January 1, 2026. (Vermont Legislature) New York’s ban begins January 1, 2025, and a threshold is coming by January 1, 2027. (Morgan Lewis) Those rules encourage brands to speak in “intentional use” terms, because that’s how compliance is judged.
2. Compliance meaning: “No intentionally added PFAS” (aligned with many state bans)
3. Measurement-aligned meaning: A claim tethered to thresholds or testing frameworks (closer to California’s TOF approach)
State laws show why brands gravitate toward Tier 2. Vermont’s ban on intentionally added regulated PFAS in textiles begins January 1, 2026. (Vermont Legislature) New York’s ban begins January 1, 2025, and a threshold is coming by January 1, 2027. (Morgan Lewis) Those rules encourage brands to speak in “intentional use” terms, because that’s how compliance is judged.
Real-world scenario: The compliant jacket that still isn’t “zero PFAS”
A company reformulates its DWR so it contains no intentionally added PFAS. The jacket now qualifies for sale under an intention-based regime. Upstream textile processing, recycled yarn content, or chemical auxiliaries introduce trace PFAS anyway. The brand prints “PFAS‑free” because, internally, the team means “no intentionally added PFAS.”
That jacket may represent real progress. The label may still mislead a shopper who heard “free” as “none.”
That jacket may represent real progress. The label may still mislead a shopper who heard “free” as “none.”
Key Insight
Treat “PFAS‑free” as a family of claims—marketing shorthand, compliance language, or measurement-aligned thresholds—not a single universal standard.
The Other Side of the Debate: Why Brands and Regulators Struggle to Speak Plainly
It’s tempting to treat this as corporate doublespeak versus consumer rights. Reality is messier.
Brands face a hard problem: performance expectations are high, supply chains are global, and the legal environment is patchwork. Regulators face another: they need rules that can be verified, enforced, and updated as science and manufacturing shift.
Brands face a hard problem: performance expectations are high, supply chains are global, and the legal environment is patchwork. Regulators face another: they need rules that can be verified, enforced, and updated as science and manufacturing shift.
Expert perspective (legal analysis)
Morgan Lewis’s summary of the New York and California timelines captures the transitional nature of the policy moment: bans on intentionally added PFAS can arrive before agencies define the numeric thresholds that better approximate what consumers imagine “PFAS‑free” means. (Morgan Lewis) That sequencing can produce a period where brands comply, market compliance as purity, and consumers assume more than the law requires.
What good faith looks like in 2026
A responsible “PFAS‑free” message does at least one of the following:
- Defines the claim as “no intentionally added PFAS” in plain language
- Discloses exceptions (such as severe wet conditions products) clearly
- Aligns claims with measurable standards where applicable (e.g., acknowledging California’s TOF thresholds if selling into that market)
None of that is radical. It’s simply respecting the reader.
- Defines the claim as “no intentionally added PFAS” in plain language
- Discloses exceptions (such as severe wet conditions products) clearly
- Aligns claims with measurable standards where applicable (e.g., acknowledging California’s TOF thresholds if selling into that market)
None of that is radical. It’s simply respecting the reader.
Editor's Note
A “PFAS‑free” claim that doesn’t define its terms is the core problem: consumers hear “none,” laws often regulate “intent,” and supply chains can still carry trace contamination.
What Readers Can Do: A Practical Checklist for Smarter Purchases
You shouldn’t need a law degree to buy a rain jacket. Until labeling catches up, a few targeted questions can separate real progress from convenient ambiguity.
The PFAS‑free checklist (use it in-store or online)
- ✓Ask what “PFAS‑free” means: Does the brand specify “no intentionally added PFAS”?
- ✓Look for scope: Is the claim for one fabric, one line, or all products?
- ✓Check for carve-outs: Does the brand exclude “severe wet conditions” or pro-level gear?
- ✓Watch the timeline language: Is the claim tied to compliance dates like Jan 1, 2025 (NY) or Jan 1, 2026 (VT)?
- ✓If shopping in California: Be aware the state uses TOF thresholds—100 ppm (2025) and 50 ppm (2027) for covered textile articles. (Taft Law)
A grounded way to think about impact
Replacing intentionally added PFAS in common apparel categories is not trivial. It changes what factories order, what chemical formulators supply, and what becomes “normal” in the market. The honest posture is to reward transparency and measurable progress, not absolutes that no one defines.
A consumer can demand clean language without demanding perfection.
A consumer can demand clean language without demanding perfection.
The Murrow Take: The Phrase We Need Is “PFAS‑Accountable,” Not “PFAS‑Free”
“PFAS‑free” will remain popular because it’s short and emotionally satisfying. That’s exactly why it needs to be handled with care. When a label can mean “zero,” “not intentionally added,” or “below a screening threshold,” it stops being a promise and becomes a test of how much you trust a brand to define its own virtue.
State law is beginning to narrow the ambiguity. Vermont draws a bright line around intentional addition starting January 1, 2026. (Vermont Legislature) New York bans intentionally added PFAS in new apparel starting January 1, 2025 and is on the path toward numeric thresholds by January 1, 2027. (Morgan Lewis) California goes further by imposing TOF thresholds—100 ppm in 2025 and 50 ppm in 2027—that pressure companies to manage fluorinated content, not just intent. (Taft Law)
Those are meaningful shifts. None of them make the words on a hangtag self-explanatory.
So treat “PFAS‑free” as the beginning of a conversation, not the end. Ask what it means, where it applies, and which legal standard it tracks. Companies that have done the work can answer without flinching.
State law is beginning to narrow the ambiguity. Vermont draws a bright line around intentional addition starting January 1, 2026. (Vermont Legislature) New York bans intentionally added PFAS in new apparel starting January 1, 2025 and is on the path toward numeric thresholds by January 1, 2027. (Morgan Lewis) California goes further by imposing TOF thresholds—100 ppm in 2025 and 50 ppm in 2027—that pressure companies to manage fluorinated content, not just intent. (Taft Law)
Those are meaningful shifts. None of them make the words on a hangtag self-explanatory.
So treat “PFAS‑free” as the beginning of a conversation, not the end. Ask what it means, where it applies, and which legal standard it tracks. Companies that have done the work can answer without flinching.
1) Does “PFAS‑free” legally mean zero PFAS?
Not usually. Many state laws focus on “intentionally added” PFAS, which means PFAS weren’t deliberately used in the product’s formulation. Trace PFAS can still appear from contamination or upstream processing. California’s approach, which uses total organic fluorine (TOF) thresholds, narrows the gap but still doesn’t equal “zero PFAS.” (Taft Law)
2) Why were PFAS used in outdoor clothing in the first place?
PFAS have been used because they deliver water and oil repellency and durability in performance textiles. Outdoor Life points to PFAS use in DWR finishes and some waterproof/breathable systems, where consumers expect high performance in rain and wet conditions. Removing PFAS can require material and chemical changes that affect feel, longevity, or repellency. (Outdoor Life)
3) What’s the difference between “no intentionally added PFAS” and “PFAS‑free”?
“No intentionally added PFAS” is a narrower, compliance-oriented claim: the manufacturer didn’t deliberately add regulated PFAS. “PFAS‑free” sounds absolute to most consumers, suggesting none are present at all. The difference matters because many laws regulate intent, not analytical absence—so a brand can be compliant while a lab still detects trace PFAS. (Vermont Legislature; Morgan Lewis)
4) What’s happening in New York, and why does 2027 matter?
New York’s ban on new apparel with intentionally added PFAS takes effect January 1, 2025. Morgan Lewis notes that New York also requires its Department of Environmental Conservation to set a numeric threshold for PFAS in apparel by January 1, 2027. That second step is significant because numeric thresholds can better align policy with consumers’ expectations. (Morgan Lewis)
5) How does California’s TOF threshold change what “PFAS‑free”
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About the Author
TheMurrow Editorial is a writer for TheMurrow covering style & fashion.
Frequently Asked Questions
Does “PFAS‑free” legally mean zero PFAS?
Not usually. Many state laws focus on “intentionally added” PFAS, meaning PFAS weren’t deliberately used. Trace PFAS can still appear from contamination or upstream processing. California’s total organic fluorine (TOF) thresholds narrow the gap but still don’t equal “zero PFAS.” (Taft Law)
Why were PFAS used in outdoor clothing in the first place?
PFAS have been used because they deliver water and oil repellency and durability in performance textiles—especially DWR finishes and some waterproof/breathable systems—where consumers expect high performance in wet conditions. (Outdoor Life)
What’s the difference between “no intentionally added PFAS” and “PFAS‑free”?
“No intentionally added PFAS” is a compliance-oriented claim: the manufacturer didn’t deliberately add regulated PFAS. “PFAS‑free” sounds absolute to most consumers, suggesting none are present, even though laws often regulate intent rather than analytical absence. (Vermont Legislature; Morgan Lewis)
What’s happening in New York, and why does 2027 matter?
New York’s ban on new apparel with intentionally added PFAS takes effect January 1, 2025. The state must also set a numeric threshold for PFAS in apparel by January 1, 2027, which could better align policy with consumer expectations. (Morgan Lewis)
How does California’s TOF threshold change what “PFAS‑free” means?
California adds measurement-based limits using total organic fluorine (TOF): 100 ppm starting Jan 1, 2025, and 50 ppm starting Jan 1, 2027 for covered textile articles. This reduces wiggle room versus intent-only rules, but it remains a screening approach rather than compound-by-compound “zero PFAS.” (Taft Law)
