ILAG testing and measurement recommendations for PFAS-related findings

PFAS-related findings should not be based solely on a single measurement. To ensure a reliable assessment, ILAG recommends a multi-step approach consisting of documentation, targeted analysis, and expert evaluation.

Why a multi-step testing approach makes sense

PFAS is a broad group of substances. Results may vary depending on the test material, test scope, and measurement method. Furthermore, the presence of fluorine does not automatically equate to PFAS. For this reason, ILAG recommends a phased testing approach rather than an isolated, single assessment.

Definitional framework

PFAS
Per- and polyfluorinated alkyl substances as defined by the OECD in 2021.

Low-molecular-weight PFAS
These substances are particularly relevant when it comes to PFAS that are capable of migration and can be specifically detected through analysis.

Fluoropolymers
Fluoropolymers such as PTFE, PFA, or FEP belong to the PFAS group of substances according to the OECD definition.

Inorganic fluorine sources
Certain raw materials, such as mineral-based or pigment-related fluorine sources, can influence analytical fluorine results without automatically indicating the presence of organic PFAS.

Recommended testing approach

Manufacturer confirmation
A documented statement from the coating manufacturer confirming that no PFAS were intentionally used in the development and formulation of the coating.
Targeted PFAS analysis
Analytical testing of relevant PFAS—particularly with regard to low-molecular-weight, migratable compounds—using a testing spectrum appropriate for the material and market.
Supplementary fluorine screenings
A test for total fluorine or organically bound fluorine may be useful as a supplementary screening component. However, such values must be interpreted by experts, as not every detection of fluorine automatically indicates the presence of PFAS.
Assessment of possible non-PFAS sources of fluorine
If fluorine levels are elevated, it should be determined whether non-organic or material-specific sources of fluorine—such as pigments or mineral components—could explain the findings.
Market-specific claim evaluation
Even a good test result does not replace the question of how a statement will be understood in the respective market. Measurements, wording, and graphical presentation should therefore be evaluated together.

Note on guideline values

If guideline values are used, they should always be presented as ILAG recommendations and not as legally binding EU limit values.

Important note on communication

A testing concept can provide technical support for a claim. However, it does not replace either the precise definition of the claim’s subject matter or the careful formulation of the claim itself.

We explain how technical results, market understanding, and regulatory requirements interact on our claim strategy page.

from easurement to a robust claim