This article has been translated with machine translation.
Background
Sometimes a supplier confirms in writing that a product contains PFAS, but that same product never appears on the PFAS restriction list in your chemical inventory. This is not a bug, and it does not mean the list is wrong. It reflects how restriction lists work, and it is worth understanding so you know when to trust the list and when to look further.
How the restriction list actually works
Restriction lists match substances, not products. A product is flagged as containing PFAS when a substance with a CAS or EC number on the PFAS list also appears in Section 3 of that product's safety data sheet. If the substance is not named there with a matching identifier, there is no match, regardless of what a supplier may say elsewhere.
Where the list comes from
The PFAS list is sourced from the Swedish Chemicals Agency's PRIO database, which is itself built on the OECD's 2021 definition of PFAS, the same definition used in the EU's restriction proposal. PRIO currently covers more than 14,000 substances, up from roughly 11,000 when the agency expanded its PFAS coverage in late 2023. This is one of the broadest CAS-based PFAS sources available, and there is no wider list to switch to. The agency itself is clear that PRIO should not be treated as a complete inventory of every PFAS substance in existence, since the OECD definition is structural and covers, in practice, far more substances than any authority has yet catalogued with CAS numbers.
Why the gap happens
The gap sits on the safety data sheet side, not the list side, for several reasons.
Fluoropolymers such as PTFE, PVDF, FEP, and FKM are polymers. Under REACH they do not need to be registered or listed in Section 3 unless they are classified as hazardous, even though they count as PFAS under the OECD definition.
PFAS are often used as surfactants or processing aids in concentrations below the thresholds that trigger a declaration requirement.
Many PFAS substances have no CAS number at all, or are so-called UVCB substances. In these cases a supplier may write "fluorinated surfactant" or a trade name instead of a substance identifier.
A safety data sheet can also simply be older than the supplier's own current knowledge of the formulation.
Why a supplier's statement can still be correct
A supplier's direct statement is based on the actual recipe, not on what a declaration threshold requires. So when a supplier says a product contains PFAS and offers a PFAS-free alternative, while the same product shows no match on the list, both things can be true at once. The supplier's information is, in these cases, better data than the safety data sheet.
What you can do
If you have supplier confirmation that a product contains PFAS but it is not flagged, you can add it manually to the list by editing the product, noting the source, date, and contact person for the supplier's statement. You can also request an updated safety data sheet from the supplier with the substance name and CAS or EC number included. If the substance turns out to be a polymer or is present below the declaration threshold, you will still have a written supplier statement, which is often exactly the documentation needed for phase-out or substitution work.
The list keeps growing
The PRIO PFAS list is monitored on an ongoing basis and has grown by more than 3,000 substances over the past two years. A product that is not flagged today may be flagged in a future update as new substances are added.
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