Australia Releases PFAS Use Evaluation and Signals Additional Regulatory Action

Comments are due by December 2. The evaluation provides one of the clearest pictures yet of which PFAS remain in Australian commerce and signals that Australia is moving from PFAS information-gathering toward targeted evaluation and potential risk-management measures.

The evaluation draws on a mandatory notice requiring AICIS-registered businesses to report whether they introduced any of the 522 PFAS listed on the Australian Inventory of Industrial Chemicals between September 1, 2023, and August 31, 2025, and, if so, in what volumes and for what uses. AICIS found that only 139 of the 522 listed PFAS were introduced during that period, with 91 used in industrial or consumer applications and 48 used exclusively for research and development. No domestic manufacture was reported; all introductions occurred through importation.

AICIS did not require reporting of PFAS in finished articles such as clothing and cookware, or PFAS present only as impurities, because those introductions are excluded from AICIS categorization requirements. The evaluation also does not cover non-industrial uses such as agricultural and veterinary products, therapeutic goods, and food. Volumes were reported only in bands and were self-reported, so the data may not capture all PFAS uses in Australia.

AICIS found that PFAS continue to be used across a wide range of sectors. The three most frequently reported end uses were lubricants and greases, paints and coatings, and adhesives and sealants, with other reported uses including plastics, refrigerants, cosmetics, electronics, food-contact materials, and cleaning products. The evaluation suggests that legacy long-chain PFAS have largely been phased out of commerce in Australia. Although nine potential long-chain PFAS were still reported for industrial or consumer uses, 184 of the 206 listed long-chain PFAS were not reported as being introduced during the reporting period. Fluoropolymers and fluorinated gases account for a significant share of reported PFAS commerce.

What Is Australia Seeking Comment On?

Importantly, the draft evaluation is not itself a risk assessment. Rather, it is intended to establish the factual basis for future regulatory action. AICIS proposes to use the information collected, alongside other evidence, to prioritize future PFAS evaluations, beginning with trifluoroacetic acid (TFA). AICIS describes TFA as an emerging chemical of interest because it is a common breakdown product of many other PFAS, including some PFAS introduced in high volumes. Most TFA introductions reported were for research and development. AICIS also noted that 66 of the 91 PFAS in industrial or consumer use have been assessed previously, while the remaining 25 unassessed PFAS will be prioritized for evaluation.

AICIS also proposes to vary the inventory listings of 431 PFAS that were either not reported as being introduced into Australia or were reported only for research and development purposes. Using its power under section 86 of the Industrial Chemicals Act 2019, AICIS would add or amend a “specific information requirement” for these chemicals, requiring businesses to notify AICIS before introducing any of them for a purpose other than research and development. Certain PFAS covered by the Rotterdam Convention would be excluded. Currently, these chemicals may be introduced without informing AICIS if introducers comply with the existing terms of listing. The proposal would allow regulators to identify renewed market activity and evaluate potential risks.

Comments may be submitted until December 2 through the online form on the AICIS consultation page or by uploading a file. AICIS will consider the feedback before finalizing the evaluation.

How Does This Compare to Canada?

Australia’s exercise differs significantly from Canada’s recent PFAS reporting initiative under the Canadian Environmental Protection Act, which many companies are still working through as Environment and Climate Change Canada reviews submitted data.

While Australia focused on identifying which PFAS are currently in commerce and how they are used, Canada’s program required many companies to investigate PFAS throughout their supply chains, including in mixtures, products, and manufactured articles. As a result, Canada’s reporting requirements imposed substantially greater due diligence obligations on importers, retailers, and downstream manufacturers. In practice, many companies subject to the Canadian reporting rule were required to conduct extensive supplier outreach and product reviews to determine whether PFAS were present in imported manufactured items.

In short, Australia’s effort is primarily an inventory and market-mapping exercise, while Canada’s is a broader supply-chain transparency initiative.

How Does This Compare to US State PFAS Reporting Laws?

The Australian approach is also narrower than a growing number of PFAS reporting requirements emerging in US states such as Maine and Minnesota.

Those state programs generally focus on PFAS contained in finished products sold into the state and often require product-level disclosures from manufacturers and importers. Like Canada, the US state trend increasingly emphasizes supply-chain visibility and product stewardship rather than simply understanding which PFAS chemicals are being imported or used.

For global manufacturers, the practical challenge remains the same: the need to obtain reliable PFAS information from suppliers across increasingly complex international supply chains.

Key Takeaways

• Comment deadline: December 2. Importers that may wish to introduce any of the 431 PFAS subject to the proposed prior-notification requirement, or that use TFA or PFAS that degrade to TFA, should consider submitting comments. AICIS has published a searchable table of the 522 PFAS covered by the evaluation.
• Australia is laying the groundwork for future PFAS regulation. The evaluation is intended to drive future risk assessments and regulatory priorities rather than serve as a one-time information gathering exercise.
• TFA is emerging as a global regulatory priority. Australia’s proposal to evaluate TFA reflects a broader international trend toward scrutiny of persistent PFAS degradation products.
• Australia may impose new notification obligations for hundreds of PFAS not currently reported in commerce. AICIS has proposed requiring notification before 431 PFAS that were not reported, or were reported only for research and development, are introduced for commercial purposes.
• Companies should continue building PFAS supply-chain visibility. The information needed to respond to Australia’s, Canada’s, and US state requirements increasingly overlaps, making comprehensive supplier engagement and PFAS inventory programs essential for global businesses.

Australia’s evaluation reflects a broader international trend in PFAS regulation. While jurisdictions continue to differ in the scope of their reporting obligations, regulators are increasingly using mandatory reporting programs to identify PFAS in commerce, prioritize future assessments, and support the development of targeted restrictions. For more information or to better understand how these programs impact your business, please contact an attorney in the Environmental group.