On September 20, 2023, the U.S. Consumer Product Safety Commission (CPSC) published a request for information (RFI) on per- and polyfluoroalkyl substances (PFAS). Federal Register. The CPSC seeks information from all stakeholders, such as consumers, manufacturers, importers, government agencies, non-governmental organizations, and researchers, regarding:

(1) PFAS used in commerce or consumer products,

(2) potential exposures associated with the use of PFAS in consumer products, and

(3) potential human health effects associated with exposures to PFAS from the use of consumer products.

What are PFAS?

PFAS are a class of manmade chemicals that have been used in industry and consumer products since the 1940s because of their useful properties, including resistance to heat, fire, stains, and water. Despite their usefulness, PFAS have been linked to serious health concerns, such as cancer, and have been detected in water, soil, air, food, household, and workplace materials across the world.

Why is CPSC Concerned About PFAS?

The CPSC’s stated goal is to “protect[] the public from unreasonable risks of serious injury or death from thousands of types of consumer products under its jurisdiction, including products that pose fire, electrical, chemical, or mechanical hazard[s]”. Goal of CPSC.

In light of growing concerns with regard to PFAS, CPSC contracted with RTI International (RTI), a non-profit research group, to provide an overview of PFAS, focusing on its presence in consumer products. Federal Register. PFAS research is still ongoing, but these chemicals have already been discovered in a multitude of consumer products, including containers and packaging, apparel, furniture and décor, household products, and children’s products. PFAS Can Be Found in Many Places; RTI Report, pg. 3-1. Studies conducted by RTI show that PFAS is present in roughly 36% of all consumer products. RTI Report, pg. 4-10. Additionally, the report summarizes some of the key health concerns related to PFAS exposure: (1) decreased response to vaccines in infants; (2) low birth weight; (3) pre-eclampsia/pregnancy-induced hypertension; (4) breast cancer; (5) thyroid disease; (6) dyslipidemia; (7) liver damage; (8) kidney cancer; (9) ulcerative colitis; and (10) testicular cancer. RTI Report, pg. 4-88.

Despite the extensive research on PFAS, RTI believes that existing consumer product data is still sparse, and therefore calls for additional research on PFAS exposure routes and health risks. RTI Report, pg. 4-97, 4-98.

What Information is CPSC Requesting?

To address the data limitations noted in the RTI Report, the RFI calls for information from all stakeholders, such as consumers, manufacturers, importers, government agencies, non-governmental organizations, and researchers, on the following: (1) the use or potential use of PFAS in consumer products; (2) potential human exposures to PFAS associated with consumer products use; and (3) potential adverse human health effects informed by toxicological data. Federal Register. The following is a summary of the specific information sought by CPSC:

Use or Potential Use of PFAS in Consumer Products

  • Information on the definition of PFAS, including which chemical substances should and should not be considered PFAS, as well as which PFAS are used in commerce.
  • Identify specific PFAS potentially used and/or present in consumer products that are not included in the RTI report.
  • Information on which PFAS the CPSC should prioritize in assessments.
  • Information on which specific consumer products the CPSC should prioritize in assessing presence of PFAS.
  • For intentional uses of PFAS, provide: chemical identity; form; functional purpose; levels/concentrations of PFAS used in consumer products. For non-intentional uses of PFAS, provide: sources of contaminants; chemical identity; physical form; degradation in consumer products to PFAS; levels/concentrations of PFAS in consumer products.

Potential Human Exposures to PFAS Associated with Consumer Products Use

  • Information related to emission of PFAS from consumer products into indoor environments.
  • Information related to the migration of PFAS from consumer products into saliva, gastrointestinal fluid, or skin.
  • Information on the potential for exposure and risk from presence of PFAS in consumer products; data related to specific exposure pathways; data on measurements or estimates of PFAS intake, uptake, clearance, half-life, or occurrence in people; and data on relative source of contribution of consumer products with estimates of aggregate exposures.
  • Information about population groups that may use certain consumer products for a greater than average magnitude, frequency, or duration.

Potential Adverse Human Health Effects Informed by Toxicological Data

  • Reports and underlying data for data sources that could inform whether PFAS or subclasses/categories of PFAS have potential for adverse human health effects.
  • Information on additional sources of data and other information CPSC should consider that are not included in the RTI Report.


This request is further evidence of the federal government’s focus on PFAS exposure and associated health risks. Once focused mainly on exposure from drinking water and waste, the federal government is increasingly expanding its assessment of these chemicals to include PFAS exposure from consumer products.

The RFI is not a regulatory action, but rather is intended to inform the Commission and the public. Affected members should closely review EPA’s notice and consider the information requested. The comment period ends November 20, 2023. Instructions for submitting information in response to this RFI are available here.