Chapter 2About PFAS
2.1This chapter describes what are PFAS (per and polyfluoroalkyl substances), including the different types of PFAS and which ones are regulated in Australia. It then covers:
PFAS as environmental contaminants;
human exposure pathways; and
regulation of PFAS in Australia.
What are PFAS
2.2PFAS are a group of manufactured chemicals that have been used since the 1950s to make products 'that resist heat, stains, grease and water'. PFAS have been used in a range of industrial and consumer products, including:
stain resistant fabrics and carpets
non-stick cookware
food packaging
cosmetics
pharmaceuticals
waterproof clothing
dental products, and
firefighting foams.
2.3PFAS are chemicals of concern as they 'do not break down readily in the environment, can travel long distances through soil and water and can get into groundwater'. Evidence indicates that PFAS levels 'build up in animals and humans and remain for many years in the human body'.
2.4A key source of PFAS contamination in Australia, is the historic use of PFAS-containing aqueous film forming foams (AFFF), a type of water based firefighting foam. AFFF were used in Australia since the 1970s due to their effectiveness in fighting liquid fuel fires.
2.5While the use of PFAS-containing firefighting foams has dramatically decreased since the Australian Government began reducing the use of certain PFAS in firefighting foams in 2002, PFAS-containing firefighting foams are still being used in operational and training scenarios in some jurisdictions across Australia.
2.6The historic use of PFAS in firefighting foams has led to increased levels being detected at 'airports, Defence bases, and other sites where fire-fighting training has been conducted, or where fire suppression systems are installed for extinguishing liquid-fuel fires'. Increased levels of PFAS may also be found in industrial areas, effluent outfalls and landfill sites.
Types of PFAS
2.7There are thousands of different PFAS, some of which have been more widely used and studied than others. The most prevalent PFAS found in the Australian environment and population to date have been perfluorooctane sulfonate (PFOS), perfluorooctanoic acid (PFOA), and perfluorohexane sulfonate (PFHxS).
2.8PFOS, PFOA and PFHxS are also examples of 'long chain' PFAS. Long chain PFAS have been considered more harmful to the environment and human health compared to 'short chain' PFAS. As long-chain PFAS are becoming increasingly regulated, short-chain PFAS are being used as alternatives. However, while short-chain PFAS are assumed to have a lower bioaccumulation potential compared to long-chain PFAS, research has shown short-chain PFAS to have many of the same properties of concern. Like long-chain PFAS, short-chain PFAS are highly mobile in soil and water and can remain persistent in the environment. Recent studies have also shown the shorter-chain PFAS compounds to be more readily absorbed through the skin than longer-chain PFAS compounds.
2.9Considering the logistical difficulties of monitoring thousands of different chemicals in the environment, PFOS, PFOA, and PFHxS have been used as 'primary indicators' of the presence of other PFAS compounds including other short and long chain perfluoroalkyl acids and precursors.
2.10PFAS have never been manufactured in Australia and the use and import of products containing PFOA, PFOS and PFHxS has reduced significantly in the last 20 years. Today, the importation of PFOA, PFOS and PFHxS has been almost entirely phased-out. As of 1 July 2025, the importation of PFOA, PFOS and PFHxS to Australia will be prohibited, with limited exceptions, such as for research or laboratory purposes. The ban will not apply if the chemicals are unintentionally present in products at low levels.
2.11There is concern that as PFOA, PFOS and PFHxS are phased out, equally or even more dangerous chemicals may replace them. The Minderoo Foundation submitted that chemical company, 3M, which first invented PFAS compounds:
… initiated a voluntary phase out of PFOA in 2000. However, … immediately replaced PFOA with the PFAS known as 'GenX', which was also later shown to be toxic.
2.12The Department of Climate Change, Energy, the Environment and Water (Environment Department) raised similar concerns in its submission, stating:
We do not yet fully understand the alternative chemicals that may replace the large numbers of PFAS. There is a risk of regrettable substitution, which occurs when a chemical of unknown or unforeseen (potentially greater) risk to the environment is used to replace a banned substance.
PFAS as environmental contaminants
2.13PFAS have many chemical characteristics which make them difficult environmental contaminants to manage and remediate. PFAS are soluble in water and highly bioavailable to aquatic organisms and plants. This allows PFAS to move long distances from the point of contamination in creeks, rivers and streams.
2.14PFAS are very stable chemicals which resist physical, chemical and biological degradation. This allows PFAS to degrade very slowly and persist for a long time in the environment and bioaccumulate in plants and animals.
Figure 2.1Conceptual diagram showing the major mechanisms of the fate, transport, and exposure pathways of PFAS
Source: United States Geological Survey, December 2021, www.usgs.gov/media/images/conceptual-diagram-showing-major-mechanisms-fate-transport-and-exposure-pathways-pfas(accessed 13 February 2025).
2.15The Environment Department notes that PFAS in the environment is 'an emerging concern globally'. PFAS are 'highly persistent, bioaccumulate, can move long distances in the environment, and are linked to adverse impacts on some plants and animals'. PFAS accumulate in animals, including 'dolphins, whales, seals, sea birds, and polar bears', passing on higher concentrations to animals further up the food chain. Investigations indicate that PFAS from sites with high contamination 'have moved over time from the contaminated soil, and contaminated surface and ground water, and migrated into adjoining environments' and laboratory studies have identified negative effects on the reproductive, developmental and other systems of animals exposed to PFAS.
Human exposure pathways
2.16Due to the widespread historic use of PFAS and its persistence in the environment, it is likely that most people have detectable levels of PFAS in their blood. Population studies completed in the United States have shown 98 per cent of participants have detectable levels of PFAS in their blood. No equivalent studies have been undertaken in Australia.
2.17PFAS can enter the blood stream through food, water, air or through contact with the skin. Eating and drinking contaminated food and water is expected to be the primary source of exposure for most people. Inhalation of contaminated dust, and skin contact with PFAS, including bathing in contaminated recreational water, are considered lower exposure pathways. Once in the human body, the time for the level of PFAS to reduce by half can take from two to eight years.
Firefighting foam
2.18For most people living in Australia the level of exposure is likely to be relatively small. However, in locations where PFAS have been used as an active ingredient in firefighting foams, PFAS contamination in the environment and in the population are much higher. Research has found that firefighters who have administered these foams and communities living in these locations can have elevated blood concentrations above the general population.
Drinking water
2.19Contaminated drinking water is another source of exposure. Most tap water in Australia has PFAS levels well below both Australian and international standards. However, localised contamination can lead to a community's drinking water exceeding safe levels. Exposure to PFAS through drinking water can be heightened in areas where people are unknowingly drinking from contaminated bores.
2.20The Australian Drinking Water Guidelines guideline values for PFAS assume that '10 per cent of an individual's daily intake of PFAS comes from the drinking water supply'.
2.21Chapter 4 covers PFAS in drinking water in more detail, including more information on the current and proposed Australian Drinking Water Guidelines and the status of PFAS testing and treatment.
Food
2.22Current evidence suggests PFAS levels in the general Australian food supply are low. Food Standards Australia New Zealand (FSANZ)'s 27th Australian Total Diet Study investigated the presence of 30 PFAS in 112 food types. Out of the 30 PFAS tested, PFOS was the only chemical detected. PFOS was found in less than two per cent of all the samples. The PFAS levels found in these samples were consistently lower than reported concentrations in overseas studies conducted in Europe, the United States, the United Kingdom and China. The study concluded that there are 'no public health and safety concerns for the general Australian population'.
2.23However, there are areas of localised contamination where PFAS can be present at higher quantities. If they are aware of the contamination, local authorities may distribute advice. In its submission, the Department of Health and Aged Care (Health Department) described what this advice can include:
This local advice takes into consideration the Australian guidance values and specific local circumstances and may include encouraging people to consume produce from multiple sources, and in some cases, limiting consumption of home-grown produce, home-produced livestock, and locally harvested food such as fish, and PFAS contaminated water to reduce exposure.
Regulation of PFAS in Australia
2.24Chemicals are regulated under both state and territory, and Commonwealth laws, in Australia. At the national level, chemicals are regulated according to their use, through four regulatory authorities:
AICIS [Australian Industrial Chemicals Introduction Scheme] regulates individual industrial chemicals in products such as paints, adhesives, inks, glues, solvents, soaps, cosmetics and cleaning products.
Australian Pesticides and Veterinary Medicines Authority regulates agricultural and veterinary chemical products, such as pesticides, animal medicines, insect repellents, garden sprays and some pool chemicals
Therapeutic Goods Administration regulates medicines, complementary medicines, medical devices, and biologicals such as vitamins, minerals, herbal material, aromatherapy and homeopathic preparations and blood products.
Food Standards Australia and New Zealand regulates ingredients in food and food additives for human consumption, such as processing aids, colourings, vitamins and minerals and food packaging materials.
2.25PFAS are also governed by two Commonwealth Acts, the Industrial Chemicals Act 2019 and the Industrial Chemicals Environmental Management (Register) Act 2021. These Acts regulate the importation and manufacture of industrial chemicals in Australia.
Industrial Chemicals Act 2019
2.26The Industrial Chemicals Act 2019 (Cth) is the legal framework that regulates the importation and manufacture of industrial chemicals in Australia. It also establishes the AICIS and its Executive Director. All importers and manufacturers of industrial chemicals listed under this Act are required to register their business and the categories of their chemical importations or manufacture with AICIS before they introduce industrial chemicals into Australia.
2.27AICIS enforces import and export controls on PFOS and specified PFOS precursors listed under an international agreement called the Rotterdam Convention.Importers and manufacturers of PFAS must comply with legal obligations under the Actand are prohibited from importing or exporting PFAS without approval from AICIS. However, the regulation of the 'use, release and disposal of PFAS in Australia is primarily a state and territory responsibility'.
2.28AICIS has recommended that industry should 'actively seek alternatives to and phase out PFAS and PFAS-related substances of concern'.
Industrial Chemicals Environmental Management (Register) Act 2021
2.29The Industrial Chemicals Environmental Management (Register) Act 2021 established the Industrial Chemicals Environmental Management Standard (IChEMS) Register. The IChEMS is a national approach to managing the import, use and disposal of industrial chemicals. Under the register chemicals can be classified under one of seven schedules, with Schedule 1 being of low concern, while Schedule 6 and 7 chemicals are considered 'likely to cause serious or irreversible harm to the environment':
Figure 2.2IChEMS scheduling
Source: Department of Climate Change, Energy, the Environment and Water, Setting standards under IChEMS, December 2024, (accessed 13 February 2025).
2.30In December 2023, PFOS, PFOA and PFHxS were registered as Schedule 7 chemicals, which means the import, manufacture and export of these chemicals will be prohibited, with limited exceptions. The listing is due to come into effect on 1 July 2025. The delay enables states and territories to update their own regulatory regimes. Commonwealth legislation to implement the IChEMS 'at the border and on Commonwealth sites, is under development'.
Status of IChEMS implementation in state and territory jurisdictions
2.31The state and territory governments have committed to several actions to implement IChEMS in their jurisdictions, including by adopting the IChEMS Register into their existing regulatory frameworks. The status of implementation in each jurisdiction at the time of writing is as follows:
Queensland and NSW both passed legislation to implement the IChEMS Register requirements.
Victoria indicated that its existing legislation is likely already consistent with IChEMS but also stated that it is 'conducting a case-by-case analysis of each chemical listed in the IChEMS register to determine whether further controls are required to manage their risks'.
Western Australia released and consulted (between Dec2023 and Feb2024) on draft Regulations to implement IChEMS; however, the proposed Regulations do not appear to have been introduced into state law as yet.[36]
the Tasmanian EPA states that the Department of Natural Resources and Environment (NRE) is developing state legislation to implement IChEMS; however, the NRE's webpage provides no information on the progress of this legislation.
the South Australian EPA gave notice in December2023 that it intended to prepare a draft Industrial Chemicals Environment Protection Policy to implement IChEMS (p.4179); however, the draft policy does not appear to have been released as yet.
both the Northern Territory and the Australian Capital Territory (ACT) Governments do not appear to have indicated how they intend to implement IChEMS in their jurisdictions.
The Intergovernmental Agreement on a National Framework for Responding to PFAS Contamination
2.32Management and regulation of chemicals and contamination is primarily the responsibility of state, territory and local governments. The Intergovernmental Agreement on a National Framework for Responding to PFAS Contamination (the Intergovernmental Agreement) is an agreement between the Commonwealth and the states and territories to respond consistently to PFAS contamination.
2.33The Intergovernmental Agreement came into effect in 2018. In 2019, the Intergovernmental Agreement was reviewed and updated. As part of the review, the National PFAS Position Statement was added to the Intergovernmental Agreement. The Position Statement lists nationally agreed objectives for phasing-out certain PFAS in Australia, including 'a goal to transition away from the use of short-chain PFASs where practical', but does not specify regulatory measures or timeframes for phasing out PFAS.
2.34The Intergovernmental Agreement articulates the commitment of Australian governments to implement a range of national guidance documents, including:
the PFAS National Environmental Management Plan;
Health Based Guidance Values for PFAS
Environmental Health Standing Committee Guidance Statements on PFAS;
a number of fact sheets and other guidance materials.
2.35According to the Environment Department, since the release of the National PFAS Position Statement in May 2020, 'multiple industries are working with the Environment Department to phase out PFAS use', and national reforms to environmental management regulation are 'well progressed'. In addition, all Australian governments 'are sharing information on PFAS contamination with the aim of managing the potential impacts to environment and human health'.
PFAS National Environmental Management Plan (PFAS NEMP)
2.36The PFAS NEMP sets nationally agreed guidance and standards on the investigation, assessment and management of PFAS wastes and contamination. The PFAS NEMP was developed by the Heads of Environmental Protection Agencies in Australia and New Zealand (HEPA). The first iteration of the PFAS NEMP was developed in 2018. The PFAS NEMP is designed to be an iterative document, regularly updated to reflect emerging knowledge. The current version is Version 2.0, published in January 2020. PFAS NEMP 3.0 has been drafted, and a consultation process has been undertaken by the Nation Chemical Working Group, with NEMP 3.0 expected to be finalised in early 2025.
Stockholm Convention
2.37PFOS, PFOA and PFHxS are listed on the Stockholm Convention on Persistent Organic Pollutants. The Stockholm Convention is a global treaty to protect human health and the environment against persistent organic pollutants, such as PFAS. The Stockholm Convention entered into force on 17 May 2004. Australia ratified the Convention on 20 May 2004 but chose to be an 'opt-in' party. This means Australia undertakes a domestic treaty making process to determine whether to ratify any amendments to the Convention, including any new chemical listings. Australia is yet to ratify the listing of PFOS, PFOA or PFHxS under the Convention.
2.38In its most recent report on compliance with the Stockholm Convention, Australia reported that, while it has not ratified the listing of PFOS in Annex B of the Convention, AICIS:
… issued a series of alerts in 2002, 2003, 2004, 2007 and 2008. These alerts were reviewed and updated in 2013. The alerts recommend that PFOS be restricted to only essential uses, for which no suitable and less hazardous alternatives are available.
2.39The Environment Department shared that Australia 'strongly supports' the listing of PFAS and is working towards ratification:
… to ratify listings of chemicals on the Stockholm Convention Australia must be able to meet the specific obligations for managing those chemicals. This means ensuring there is an appropriate regulatory framework in place.
Once implemented, the IChEMS will provide the necessary regulatory framework to prohibit or severely restrict uses of PFOS, PFOA and PFHxS in Australia and enable Australia's ratification of their listings under the Stockholm Convention.
Packaging regulation
2.40A potential source of PFAS exposure is food packaging. Since 1999, Australia has had national arrangements setting out that governments and businesses across Australia 'share the responsibility for managing the environmental impacts of packaging'. Under this arrangement, businesses with an annual turnover of $5 million or more which produce or sell packaging and/or packaged products in Australia must become a signatory to the Australian Packaging Covenant. The Covenant is a voluntary, industry-led packaging product stewardship scheme administered by the Australian Packaging Covenant Organisation (APCO).
2.41In 2022, APCO released an industry Action Plan to phase out PFAS in fibre-based food contact packaging by 31 December 2023. Packaging companies can report their compliance with the Action Plan. However, the plan remains voluntary.
2.42In September 2024, the Environment Department released a consultation paper on packaging regulation. The consultation paper 'identified PFAS as a chemical of concern targeted for elimination from packaging'.[49] The consultation outcomes are expected to be released in early 2025.[50]
2.43Australia's environment ministers have stated that 'removing PFAS in packaging is an urgent priority for all jurisdictions'.