Chapter 8PFAS in consumer goods
Introduction
8.1PFAS are widely found in consumer goods. Since the 1940s, thousands of PFAS chemicals have been used worldwide in commercial products and applications, including consumer goods sold and imported into Australia.
8.2PFAS chemicals have a range of properties that are useful in a commercial context, such as fire-retardance, temperature and stain-resistance, and oil and water-repellence.
8.3PFAS are present in a range of common household items, personal care products, cleaning products, outdoor wear, cookware, grease-resistant food packaging, stain-resistant furniture, plastics and paint.
8.4While the presence of PFAS in some products is well-known (for example, firefighting foam and non-stick cookware), the extent of PFAS in other consumer products—such as compostable packaging, lipstick and dental floss—is less understood.
8.5As the use of PFAS predates frameworks of organised chemical management and regulation, it is unknown how many PFAS are now in global circulation. The most recent estimate by the Organisation for Economic Cooperation and Development (OECD) in 2018 suggests that approximately 4730 PFAS have been used commercially.
8.6This chapter will highlight some of the most common uses of PFAS in consumer goods, and the various pathways between human exposure to the PFAS in consumer goods. It will also consider some of the issues associated with PFAS in the context of a circular economy model—as this relates to both food packaging and imported goods.
Exposure pathways for PFAS
8.7The mechanism for exposure to PFAS is explained in Figure 8.1, below.
Figure 8.1Summary of human PFAS exposure pathways
Source: Society of Environmental Toxicology and Chemistry, Selection of academic journal articles on the environmental and human health impacts of PFAS (received 21 October 2024). Figure adapted from European Environment Agency–Emerging chemical risks in Europe–'PFAS' (2019).
Note: Human exposure to PFAS may occur through multiple pathways including food, consumer products, food packaging, cleaning products, personal care products, household dust, and contact with a variety of other contaminated media. While dietary intake resulting from the ingestion of contaminated drinking water and/or foods grown in contaminated groundwater rank among the key exposure routes for the general population, emerging evidence indicates that plastic containers, such as those used for storage of food, drinks, personal care products, pharmaceuticals, and cleaning and industrial products, may represent a major new PFAS exposure source.
Exposure pathways for PFAS from consumer goods
8.8The Department of Health, Disability and Ageing (Department of Health) argued that ingestion of PFAS through food and drinking water is thought to be the primary source of exposure. By contrast, the 'inhalation of dust contaminated with PFAS and dermal (skin) contact with PFAS' are considered 'minor exposure pathways'.
8.9Nevertheless, Australians may be exposed to PFAS through a variety of consumer goods and everyday items. PFAS exposure from consumer goods is generally thought to occur through three pathways: skin absorption, inhalation, and ingestion. These exposure pathways are explored in the following sections.
Skin absorption of PFAS
8.10There are multiple ways that PFAS can be absorbed through the skin (dermal absorption). CSIRO noted that contact with PFAS-containing personal care (for instance, sunscreen, shampoo, period products and dental floss) or cleaning products may lead to absorption of PFAS through the skin.
8.11Several submitters, including Ms Louise Keats, Toxics Free Australia, and Dr Mariann Lloyd-Smith, cited research conducted at the School of Geography, Earth & Environmental Sciences at the University of Birmingham, completed in May 2024. The study analysed 17 different PFAS compounds in order to investigate the rate of dermal uptake of the chemicals. The results suggest that 'human skin took in "substantial" amounts of 15 PFAS, including 13.5 per cent of PFOA, one of the most toxic PFAS. With a longer application, skin absorbed a further 38 per cent of the PFOA dose'.
8.12The issue of skin absorption through clothing was highlighted by the Circular Textile Working Group Australia (CTWG WA)—a network representing over 80 members from Western Australia's textile industry. PFAS is commonly used in textiles for its water-repellent, stain-resistant and crease-proof properties. In fact, CTWG WA highlighted that, 'the textile sector is estimated to be the biggest contributor to PFAS pollution in Europe'. The CTWG WA therefore stated that clothing and textiles should be part of the conversation about PFAS in consumer goods
8.13While 'knowledge on human dermal uptake' of PFAS is still developing, some submitters stressed the importance of addressing the presence of PFAS in consumer products, specifically in personal care and children's products.
8.14The Department of Health submitted that three out of the nine studies funded under the Australian Government's PFAS Targeted Call for Research Scheme 'include consideration and investigation of exposure pathways including dermal exposure, which can include exposure from consumer products'. Results of these studies are expected by the end of 2025 and 'will be considered when developing and revising relevant health advice'.
Inhalation of PFAS
8.15Inhalation of dust contaminated with PFAS and dermal contact with PFAS—including showering and bathing in contaminated recreational water—are considered minor exposure pathways.
8.16CSIRO noted that PFAS-containing dust can be inhaled from carpets, fabrics, upholstery cleaning products, plastics and paints. Environmental consultants, Dr Matthew Askeland and Mr Andrew Mitchell, drew the committee's attention to the issue of airborne PFAS:
PFAS exposure through dust, aerosols, and volatilised forms is often overlooked. PFAS can bind to dust particles, travel through the air, or volatilise under certain conditions. This contributes to direct human exposure and broader environmental spread. For example, PFAS-contaminated dust settling on roof catchments can impact rainwater collection systems.
8.17Dr Askeland and Mr Mitchell argued that addressing these risks will require 'baseline data on PFAS in indoor and outdoor air, a better understanding of volatilisation and aerosolization conditions and assessments of health risks from inhalation or dermal contact'. They suggested that '[i]dentifying and controlling these airborne pathways would broaden our capacity to reduce PFAS exposure'.
Ingestion of PFAS
8.18PFAS ingestion can occur through the application of cosmetic products such as lipstick,as well as through food packaging, which is explored in more detail below.
8.19The use of PFAS in make-up was highlighted by Professor Bradley Clarke, Associate Professor of Analytical Chemistry and Environmental Science, University of Melbourne. Professor Clarke noted that PFAS is used in make-up for its oil- and water-repellent properties. As most cosmetic products come in relatively small volumes, PFAS can be a significant proportion of the product. Professor Clarke also pointed to other countries, such as New Zealand, that have banned the use of PFAS in make-up, due to the high possibility of ingestion or absorption.
8.20The Department of Health noted that the import and use of PFAS chemicals is subject to a ban in Australia from 1 July 2025—including its use in articles (products). The department noted that some product types, including cosmetics, are already subject to laws requiring labelling of ingredients such as PFAS.
PFAS in food packaging
8.21PFAS chemicals are found in much food packaging. As Australian states and territories have begun to phase out non-compostable, single-use food packaging, fibre-based packaging has been seen as a more environmentally friendly alternative. However, compostable fibre-based packaging often contains intentionally added PFAS, as the chemicals serve as a barrier to heat, grease and water.
8.22Common examples include 'paper/board/fibre-based straws, cups, bowls and food packaging—including for "fast" highly processed foods (for example, pizza boxes, microwave popcorn bags, burger wrapping paper)'.
8.23Studies on PFAS migration from packaging to food have shown that PFAS can leach into food from contact packaging, specifically paper and cardboard food packaging.
8.24However, Mr Stephen Bouwhuis from the Department of Health, noted that Food Standards Australia and New Zealand has considered the leaching of PFAS into food from contact packaging and formed the view that 'the level within the packaging and the food wasn't significant enough to cause a health concern'. Specifically, 2016 testing of PFAS in 'a range of foods in the Australian diet' found:
There were no detections for PFOA and only two detections for PFOS out of 50 foods tested. The concentrations of PFOS were at very low levels (≤1 part per billion) and similar to those reported internationally for the same foods.
8.25Another issue with PFAS in food contact packaging emerges when such materials are recycled. The joint submission from the World Wide Fund for Nature–Australia (WWF-Australia) and the Australian Marine Conservation Society (AMCS) highlighted that in a circular economy, when packaging is routinely recycled, PFAS added to fibre-based recyclable or compostable packaging has the potential to contaminate recovery systems, and migrate into products made from recycled materials and contaminate home-grown or other food products, some of which might even be labelled as organic. They argued that this only increases the presence of PFAS in Australian consumer goods and makes human exposure more likely.
Australian Packaging Covenant Organisation action plan
8.26In 2021, a joint study by Planet Ark and the Australian Packaging Covenant Organisation (APCO) found that a significant proportion of fibre-based, food contact packaging samples in Australia contained PFAS. The 2021 study found 45.9 per cent of samples had 'fluorine concentrations above 100 ppm'. The threshold of 100 ppm was considered 'a reliable indicator that PFAS had been intentionally added to the packaging material' and was 'consistent with levels set in overseas programs'.
8.27As a result of this study, APCO worked with members to create an action plan to phase out all PFAS in food contact packaging by 2023. The plan outlined a 'voluntary, industry-led approach to phase out per- and polyfluoroalkyl substances (PFAS) in fibre-based food contact packaging in Australia'.[28]
8.28The action plan, implemented by all APCO members, led to a reduction in packaging products exceeding the threshold of 100 ppm of fluorine from 45.9 per cent in 2021 to around 9.6 per cent in 2024.
8.29While APCO's findings indicated that PFAS-free food packaging options are available and could be adopted by industry, some submitters criticised the lack of transparency surrounding the results. For instance, Dr Mariann Lloyd-Smith said the APCO action plan is a 'voluntary approach with little oversight and does not represent an appropriate response to a serious pathway to PFAS exposure'.
Regulation of PFAS in food packaging
8.30In September 2024, the Department of Climate Change, Energy, the Environment and Water (Department of Environment) released a consultation paper on packaging regulation. The consultation paper 'identified PFAS as a chemical of concern targeted for elimination from packaging'.[31]
8.31The consultation built upon the APCO action plan. The consultation outcomes were released in February 2025. Acting Division Head, Circular Economy Division at the Department of Environment, Ms Rachel Burgess explained that 'the department is now considering the information provided through that public consultation' and is working with industry to determine methods for identifying PFAS in packaging items.
8.32WWF—Australia and the ACMS submitted that the Commonwealth should consider implementing a ban on any PFAS that is intentionally added to food packaging materials and goods. They also recommended that 'all products designed for organic disposal be certified as PFAS free'.
8.33APCO and the Minderoo Foundation echoed this call, arguing for a phasing out of PFAS in all food contact applications. This would not only reduce human exposure to PFAS but also aid organic waste processors. Currently, consumers might place alternative food packaging that contains PFAS into green bins, or into organic waste collectors such as FOGO (Food Organics and Garden Organics) bin collections. Banning PFAS in all food contact packaging ensures that the chemicals are not ending up in landfill and leaching PFAS into the environment.
8.34Ms Burgess noted that while the responsibility for the 'use and disposal' of packaging 'largely falls to states and territories', regulating the importation of packaging is a Commonwealth responsibility. The department also acknowledged that Australia imports most of its packaging.
Imported goods
8.35The presence of PFAS in imported goods presents a complex challenge for Australian regulators. Many importers, suppliers and retailers are not aware of the presence of PFAS in the goods they import. Being able to accurately identify goods containing PFAS and then trace them through the economy is also complicated, as current technologies only allow for the identification of a small number of PFAS variants.
8.36Further, jurisdictions such as the European Union and the United States have enacted stricter regulations regarding the levels of PFAS permissible in consumer goods. As such, the Australian Bedding Stewardship Council was concerned that Australia risks becoming a 'dumping ground' for products containing PFAS chemicals, as foreign manufacturers try to offload goods that may be non-compliant in other countries, posing clear environmental and health risks.
8.37This issue was also raised in the context of the textiles industry, where the presence of PFAS is magnified by 'the dominance of low-cost, direct-to-consumer fast fashion platforms such as Shein, Temu and AliExpress', many of which are known to sell products containing PFAS. As many consumers purchase these products online, CTWG WA argued there is a need for 'strong regulatory oversight of direct-to-consumer e-commerce imports'.
8.38CTWG WA noted the importance of transitioning to a 'circular textiles economy' to improve Australia's environmental sustainability, while noting that the presence of PFAS in fast fashion 'can introduce harmful chemicals into recycling streams'. CTWG WA was concerned that Australia 'lacks clear national protocols to identify, separate, and manage PFAS treated textiles at end of life' and recommended:
1. National Protocols for Identification and Segregation: Develop and implement clear guidelines for identifying, labelling, and separating PFAS treated textiles at collection and recycling points.
2. Investment in PFAS-Safe Recycling and Destruction Infrastructure: Support the establishment of advanced treatment facilities in Western Australia and other jurisdictions to manage PFAS-contaminated textiles, including thermal destruction and emerging technologies.
3. Product Stewardship Requirements: Embed PFAS detection, separation, and disposal requirements into all national clothing stewardship schemes, including Seamless and relevant state programs.
4. Consumer Education and Transparency: Fund education initiatives for consumers, local councils, and recycling operators to improve understanding of PFAS-related risks in textiles and enable informed disposal decisions.
5. Support for Bioleaching Innovation: Allocate dedicated funding to accelerate research, pilot trials, and commercial readiness of bioleaching and other advanced biological treatment technologies for PFAS contaminated textiles.
Views of state and local governments on imported goods
8.39Many local and state government bodies including Brisbane City Council, the Local Government of New South Wales (NSW), the Northern Territory Department of Lands, Planning and Environment, and the Local Government Association of Queensland expressed concerns about inadequate national regulation of PFAS in imported goods placing an unfair burden on regional bodies who have to deal with the downstream effects of PFAS in consumer goods.
8.40These submitters argued that a lack of Commonwealth oversight of PFAS in consumer goods leaves state and local governments to manage the environmental and health consequences of having these goods in circulation—a challenge for which they argued they are not properly resourced.
8.41The Local Government Association of Queensland submitted:
Local governments remain concerned that products containing PFAS continue to be imported into Australia and that greater compliance expectations imposed on councils are not being balanced by appropriate action from the State and Federal government, despite strong commitments to stop contamination at the source.
8.42This was echoed by the Northern Territory Department of Lands, Planning and Environment who stressed that smaller jurisdictions, such as the Northern Territory, have limited resources and depend on 'national frameworks' to support their regulation of PFAS.
8.43This is compounded by a lack of mandatory product labelling and import documentation, which makes it difficult for state regulators to trace or isolate the source of contamination once it has already entered the supply chain.
Regulation
8.44Inquiry participants made a number of recommendations aimed at increasing the regulation and management of PFAS in consumer goods. Numerous community members and organisations argued for a complete phase out or ban on non-essential uses of PFAS in Australia and products imported to Australia, focussing on personal care items, as well as products for children and babies.
8.45Submitters also recommended that Australia aligns with international jurisdictions, such as the European Union, in taking a firmer stance to reduce the levels of PFAS in consumer goods.
8.46Inquiry participants noted that it is currently impossible to quantify the extent of PFAS in consumer products. Submitters argued there is a need to better understand the extent of PFAS in consumer products, to consider import and export restrictions, and for Australia to advocate for stronger international product regulation when it comes to PFAS. Submitters were concerned about the lack of information as to what goods contain PFAS, and at what levels—most notably, imported goods.
8.47Considering many consumer products end up in waste streams, some submitters argued that it would be easier and cheaper to reduce the number of PFAS-containing products circulating in the Australian economy rather than deal with the PFAS once it has reached the waste stream. This evidence is discussed in Chapter 9 of this report.
8.48The committee heard arguments in support of compulsory labelling of PFAS in consumer products. Submitters suggested that public health warning labels be mandated for products and packaging that contain PFAS, especially those products with a higher risk of chemical leaching. Some submitters also recommended that mandatory labelling be supplemented by 'public awareness initiatives on the presence and risks of PFAS in household and [information and communications technology] goods', as this would help individuals to make informed choices about the goods they purchase.
8.49Questions about the mandatory labelling of PFAS in consumer products were asked of the Department of Health as well as the Australian Competition and Consumer Commission (ACCC). The department submitted that:
Existing products on the market that may have contained PFAS would also be subject to laws requiring labelling where PFAS is included as an ingredient. For example, the labelling of cosmetic products is regulated under the Consumer Goods (Cosmetics) Information Standard 2020, administered by the Australian Competition and Consumer Commission.
… Additionally, businesses can not provide false or misleading information under Australian Consumer Law. This applies to all products, including cookware and any claims about being 'non-toxic', 'PFAS-free', or 'eco-friendly' as well as any omissions of fact that could mislead consumers. In addition, if a product contains chemicals that could pose a health risk, failing to disclose this information may be considered deceptive conduct.
8.50The ACCC clarified that it:
… does not have powers to restrict the importation of consumer goods into Australia. However, the importation of some goods to which a permanent ban applies is prohibited under customs regulations that are enforced by Australian Border Force (ABF).
8.51Further, the ACCC stated that it does not currently undertake any testing and surveillance for PFAS or other chemicals. However, if there was a mandatory standard or product ban in place, the ACCC 'may commission testing of certain products if we were investigating compliance with the standard or ban'.
8.52Asked if it would have a role in enforcing an importation ban on consumer goods containing PFAS, the ACCC said it would not. It also stated that it is not in a position to assess the practical implications of an import ban, and that it has 'not considered whether an information standard for goods containing PFAS should be made'.
8.53Chapter 10 of this report includes further evidence on phasing out non-essential uses of PFAS, and the role of the national regulation.
Funding for research and development
8.54The CTWG WA noted that while many alternatives to fabrics that use PFAS exist, such alternatives do not exist for certain kinds of safety gear, for example, fire-fighter uniforms. Thus, the CTWG WA recommends that more funding be provided for research and development into non-PFAS solutions for certified safety gear and uniforms.
8.55The CTWG WA also called for increased funding into the Seamless Clothing Stewardship Scheme, whose research focuses on creating designs standards and frameworks that are environmentally friendly, as this will also help Australian producers create garments that are PFAS-free.
8.56The CTWG WA submitted that currently there are no national protocols to guide the safe and effective recycling of garments containing PFAS. CTWG WA recommended that more funding be provided for research into emerging treatment technologies for textile waste, such as bioleaching (the use of organic microorganisms to break down toxic compounds). Bioleaching has been successfully operationalised by other industries, but is still in its infancy in textiles, and so more research is needed to establish whether it is an effective solution to the issue of PFAS in textile waste.
8.57Submitters also noted a lack of robust evidence surrounding certain human exposure pathways for PFAS and recommended that more studies be done on the mechanisms by which humans can be exposed to PFAS through everyday goods. While evidence on the exact nature of these exposure pathways—and the potential health impacts—are limited, preliminary studies and evidence from academics suggest that the presence of PFAS in household goods and clothing can lead to increased human exposure to PFAS in the home.
8.58The committee's views and recommendations are outlined in Chapters 11 and 12 of this report.