Unpacking the PFAS Value Chain

May 22, 2024   |    9 minute read

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Called “forever chemicals” by many, poly- and perfluoroalkyl substances (PFAS) are a significant environmental concern due to their persistence in our water and soil, the challenges of destroying them, and their widespread use in various industries. 

On April 19, 2024, the U.S. Environmental Protection Agency (EPA) announced it finalized a rule that designates two widely used PFAS – perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) – as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund. 

PFOS and PFOA are fluorinated hydrocarbons used as water-, oil-, and stain-resistant coatings in fabrics, leather, and carpets; as oil-resistant coatings for paper products used for food as photographic emulsifiers; aviation hydraulic fluids; and fire-fighting foams. 

This final rule requires polluters to pay for the cost of cleaning up contamination related to PFOA and PFOS and will have a substantial reputational and financial impact on every participant in the PFAS value chain. This guide expands on the PFAS value chain, addressing the sources of PFAS pollution, the environmental and health impacts of PFAS exposure, and importantly, the technological solutions available for companies involved in PFAS remediation efforts.

Understanding PFAS

PFAS are a large group of around 12,000 manufactured chemicals known for their ability to offer oil, stain, water, and soil resistance; chemical and thermal stability; and friction reduction. This made them ideal for use in products ranging from AFFF (also known as firefighting foams) and non-stick cookware, to water-repellent fabrics and long-wearing lipsticks. Products and materials containing PFAS touch almost every aspect of our lives. 

Unfortunately, the attributes that make them so valuable in terms of staying and sticking power – their ability to persist despite numerous washings, and their thermal and chemical stability – now make them one of the most pressing environmental challenges we face. These compounds do not break down easily and their cumulative impact is leading to long-term ecological and health implications.

Current, peer-reviewed scientific studies have shown that exposure to certain levels of PFAS may lead to:

  • Reproductive effects such as decreased fertility or increased high blood pressure in pregnant women.
  • Developmental impacts or delays in children, including low birth weight, accelerated puberty, bone variations, or behavioral changes.
  • Increased risk of some cancers, including prostate, kidney, and testicular cancers.
  • Reduced ability of the body’s immune system to fight infections, including reduced vaccine response.
  • Interference with the body’s natural hormones.
  • Increased cholesterol levels and/or risk of obesity.

Due to their widespread production and use, as well as their ability to persist in the environment, surveys conducted by the Centers for Disease Control and Prevention (CDC) show that most people in the United States have been exposed to PFAS. 


Unpacking the PFAS Value Chain: A Comprehensive Guide

Explore the intricate world of PFAS with this full guide for insights on:

  • Regulatory Updates
  • Environmental Impacts
  • Technological Solutions

Legacy Landfill Leachate and the Bulk of PFAS Pollution

In use as a component of various products since the 1940s, many of which are at or are past the end of their life cycles and have entered the waste stream, a primary source of PFAS pollution is legacy landfill leachate, which seeps into groundwater and ends up in oceans, rivers and lakes, where it becomes part of the stream flowing into wells and drinking water treatment plants.

Ultimately, some landfill leachate containing PFAS ends up in wastewater treatment plants, along with or as part of inflows of domestic waste. These plants are not fully equipped to remove PFAS, and this results in two significant issues:

  1. PFAS persists in water: Treated water, still containing PFAS, is discharged back into rivers and oceans, affecting aquatic ecosystems and eventually returning to our homes as drinking water.
  2. Agricultural biosolids: For decades, a by-product of wastewater treatment known as biosolids – nitrogen-rich sludge – was a cost-effective way to fertilize agricultural crops and “recycle” residual water treatment waste. Unfortunately, this sludge also is enriched with PFAS and when spread on farmland, introduces these chemicals into the soil and potentially, the food chain.

The Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances rule designating PFOA and PFOS as CERCLA hazardous empowers the EPA to investigate and demand clean up of PFOA and PFOS contamination and ensure that leaks, spills, and other releases are reported. 

The agency also issued a separate CERCLA enforcement discretion policy that makes it clear that EPA will focus enforcement on parties who significantly contributed to the release of PFAS chemicals into the environment, including those that have manufactured PFAS or used PFAS in the manufacturing process, federal facilities, and other industrial parties. 

The action builds on the recently finalized Safe Drinking Water Act, designed to address PFAS contamination in drinking water. Both EPA actions represent the latest steps toward achieving the goals set in EPA’s PFAS Strategic Roadmap.

In line with past practice and current enforcement policy, EPA will not pursue certain parties such as farmers, municipal landfills, water utilities, municipal airports, and local fire departments for CERCLA cleanup or costs. However, landfill operators, particularly those with PFAS contamination, could be responsible for remediation efforts under CERCLA.

Nearly one-third of PFAS in our environment can be found in landfills. Experts following recent regulatory action by EPA note that landfills accepting PFOA and PFOS waste will face stricter regulations, including more rigorous monitoring, reporting, and management to prevent environmental releases. This may lead to changes in waste acceptance policies to limit or prohibit PFAS-containing waste streams.

Landfills and waste management companies could be held legally responsible for some of the cleanup costs should PFAS found in consumer goods disposed of at their facilities migrate outside their boundaries via leachate or other means. A common misconception about the management, treatment, and destruction of PFAS is that it’s not commercially viable yet or is too expensive or energy-intensive to be sustainable. That is not the case.

Enhanced leachate containment, management, and remediation technologies are possible, and will likely be necessary to prevent PFOA and PFOS from leaching into the environment and leaving landfills and waste management companies responsible for expensive cleanups.



PFAS, known as "forever chemicals" due to their persistent nature in the environment, have wide applications in various industries, contributing significantly to water, soil, and air pollution. The U.S. EPA recently classified two common PFAS—PFOA and PFOS—as hazardous substances under CERCLA (Superfund), mandating polluters to fund cleanup efforts, which impacts all stakeholders in the PFAS value chain. These substances, used in products ranging from firefighting foams to non-stick cookware, are difficult to break down and accumulate in the environment, leading to severe ecological and health issues. Landfills, a major source of PFAS pollution, will face stricter regulations and potential liabilities as these chemicals can leach into groundwater and affect the broader ecosystem. The EPA’s actions, including enhanced leachate management and cleanup policies, aim to control and mitigate PFAS contamination, setting a precedent for handling such persistent environmental pollutants.


For more information on this topic, download Unpacking the PFAS Value Chain: A Comprehensive Guide

Nature is better off without PFAS. And so is your business.

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