I Think I’ve Seen This Film Before: The Origins of Exiling PFAS

By Graham Nelson

Per- and polyfluoroalkyl substances—it’s a mouthful of chemistry jargon and not something most mainstream consumers are accustomed to pronouncing, but it’s worth knowing anyway. This group of related synthetic chemicals goes by the shorthand “PFAS,” and you have almost certainly encountered them.[1] Have you ever ordered takeout in a grease-proof wrapper? Marveled at a carpet that shrugs off red wine spills? Whether you’ve zipped up a raincoat to stay dry or been saved by a firefighter in turnout gear, you have been exposed to PFAS.[2] The Centers for Disease Control and Prevention’s analysis of national blood-sampling data found PFAS in the blood of 97% of Americans.[3] The question is not whether you have been exposed; it is what that exposure means.

In 1938, DuPont chemist Roy Plunkett opened a cylinder that should have held refrigerant gas and instead found a waxy white powder.[4] The powder was polytetrafluoroethylene (PTFE), better known by its trade name, Teflon.[5] Almost nothing would stick to it, and it did not break down.[6] By the 1950s, 3M Company was producing perfluorooctanoic acid, or PFOA, and shipping it to DuPont’s Parkersburg, West Virginia plant to make commercial Teflon. Meanwhile, 3M was building Scotchgard out of a similar compound, perfluorooctanesulfonic acid (PFOS).[7] The secret to it all was the bond between carbon and fluorine, one of the strongest in organic chemistry.[8] If you wanted to create and market a pan that food would not stick or burn onto, a fabric that would not stain, a jacket that would not soak through, or a foam that could smother a dangerous chemical fire—PFAS were the answer.[9] What made these products remarkable was their long-lasting ability to persist without breaking down. But that persistence is the problem.[10]

PFAS are not the first “miracle” chemical to age badly. The pesticide dichloro-diphenyl-trichloroethane, or DDT, was sprayed ubiquitously—over crops, in public spaces, even over children playing in pools—all to prove how harmless it was.[11] Its persistence—not breaking down in soil or water—was a selling point right up until it became the basis for public alarm.[12] DDT built up in the tissue of the fish and small animals that birds of prey eat.[13] The eggshells of bald eagles and peregrine falcons started thinning, and these birds began to vanish.[14] In 1972 the newly minted Environmental Protection Agency cancelled nearly every use of DDT.[15] This pattern has played out before—with DDT, asbestos, and polychlorinated biphenyls (PCBs).[16] A chemical arrives as an engineering wonder, its maker markets its durability as a virtue, and a generation later that same durability is the reason nobody can get rid of it. PFAS fit the pattern with one twist: DDT was sprayed into the environment on purpose, while PFAS got there as a side effect, leaking from factories, landfills, and the goods themselves into soil and water.[17]

PFAS spread far beyond their initial use because they do not break down.[18] They leach from landfills and factory outfalls into rivers, flow downstream, and accumulate in the water we drink and the fish we eat.[19] PFAS accumulate in the body over time, so their health impacts unfold across decades of low-level exposure rather than from any single dose.[20] PFAS exposure has been linked to decreased fertility and high blood pressure in pregnancy; developmental delays and low birth weight in children; increased risk of kidney, testicular, and prostate cancers; reduced immune and vaccine response; hormone disruption; and elevated cholesterol.[21]

Beginning in 2005, a court-sanctioned panel of three epidemiologists studied nearly 70,000 people who had been drinking PFOA-contaminated water around DuPont’s Parkersburg plant.[22] In 2012, the panel found a “probable link” between PFOA exposure and kidney cancer, testicular cancer, thyroid disease, ulcerative colitis, pregnancy-induced hypertension, and high cholesterol.[23] In 2023 the World Health Organization’s cancer agency went further, classifying PFOA as carcinogenic and PFOS as possibly carcinogenic.[24] The properties that made PFAS attractive to chemists and manufacturers back in 1938 are the same properties harming consumers today, whether or not consumers ever bought a PFAS-containing product.[25]

If the health effects sound like recently emerged data, they certainly aren’t.[26] They are only recently public. DuPont was aware of internal risk data on PFOA as early as 1981, including evidence that the chemical had crossed the placenta into the unborn child of a plant worker, and did not report it.[27] In 2005, DuPont agreed to pay $16.5 million to settle the EPA’s allegations that it withheld that information; at the time, this was the largest administrative penalty in EPA history.[28]

When PFOA became indefensible, DuPont phased it out and replaced it with a compound called GenX, marketed as a “sustainable substitute.”[29] It was not a solution; it was another PFAS compound.[30] In 2021, the EPA concluded that GenX was more toxic than the chemical it replaced, setting a safe daily dose nearly seven times lower.[31] The lesson from DuPont isn’t complicated. The company knew its chemicals were harmful, concealed the data for two decades, and swapped one forever chemical for another under a new brand name. That history tells you everything you need to know about whether the industry is capable of policing itself.

So what is the federal government doing about PFAS? The answer is mixed. The EPA acknowledges the harms; its own website hosts a list of health effects.[32] In April 2024, the EPA set enforceable drinking-water limits for six PFAS, including a four-parts-per-trillion ceiling for PFOA and PFOS.[33] It also designated PFOA and PFOS as hazardous substances under the Superfund law, which lets the government compel cleanup and recover costs from polluters.[34] Under the 2024 rule, every public water system must complete initial PFAS testing by April 2027.[35] But in May 2026, the EPA proposed rescinding the limits for four of the six chemicals and extending the compliance deadline for PFOA and PFOS until 2031.[36] The Superfund designation fared better: in August 2026, the D.C. Circuit rejected an industry challenge, holding that the EPA acted within its statutory authority, and left the designation fully intact.[37]

Several states have not waited for EPA action.[38] In 2025, legislators introduced nearly 350 PFAS-related bills across thirty-nine states.[39] Thirteen states successfully enacted some form of PFAS restrictions.[40] Minnesota’s is one of the most sweeping.[41] Amara’s Law, named for a young woman who grew up near 3M’s headquarters and died of liver cancer at twenty, banned intentionally added PFAS in eleven product categories—from cookware and cosmetics to ski wax and children’s products.[42] It also prohibits PFAS use in nearly everything else by 2032 unless the state finds the use currently unavoidable.[43] New Mexico, Maine, and others have followed suit with their own phase-outs.[44] Momentum is real, growing, and crossing party lines.

Internationally, the Stockholm Convention has listed several PFAS compounds as industrial persistent organic pollutants subject to global elimination or restriction.[45] The European Union is going further. In January 2023, five nations proposed EU-wide restrictions on the entire PFAS class, and in March 2026, the European Chemicals Agency’s scientific committees backed the proposed restrictions.[46] The European Commission will decide whether to act on the committee’s opinion by the end of the year.[47] Even international sporting events are banning PFAS.[48] The 2026 Milano-Cortina Winter Olympic Games were the first held under a total ban on PFAS-based ski wax.[49] Officials tested every ski, and three athletes were disqualified when spectrometers found PFAS on their gear.[50]

A reader who started this post wondering whether they had been exposed now knows the likely answer. They know the practically unavoidable and unfortunate commonality of PFAS exposure, and they know what harms it can cause. The harder question is who answers for them. The manufacturers have shown they will not volunteer to self-correct.[51] Their tactics in PFAS litigation warrant an entirely different conversation due to the numerous ways they are seeking to avoid liability. The U.S. federal government has the tools to regulate and enforce standards but shows uncertain appetite for using them. Meanwhile, several states and the rest of the world are moving forward with protecting their citizens from the forever harms of forever chemicals.

[1] Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), Nat’l Inst. of Env’t Health Scis. (last reviewed Mar. 6, 2026), https://www.niehs.nih.gov/health/topics/agents/pfc (describing the nearly 15,000 formulations of PFAS as “a large, complex group of synthetic chemicals” that have been used in consumer products since the 1950s).

[2] See Our Current Understanding of the Human Health and Environmental Risks of PFAS, U.S. Env’t Prot. Agency (July 14, 2026), https://www.epa.gov/pfas/our-current-understanding-human-health-and-environmental-risks-pfas (listing common products and occupations with elevated exposure); Daniel Kampf, Forever Chemicals Face Sweeping Bans as States Pass PFAS Laws in 2025, MultiState (Jan. 22, 2026), https://www.multistate.us/insider/2026/1/22/forever-chemicals-face-sweeping-bans-as-states-pass-pfas-laws-in-2025 (noting that PFAS are found in firefighter personal protective equipment).

[3] Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), supra note 1 (reporting CDC analysis of National Health and Nutrition Examination Survey data found PFAS in the blood of 97% of Americans).

[4] Roy J. Plunkett, Sci. Hist. Inst., https://www.sciencehistory.org/education/scientific-biographies/roy-j-plunkett/ (recounting the accidental discovery of PTFE while researching chlorofluorocarbon (CFC) refrigerants).

[5] Id.; see also Evelyn Jiang, Revisiting PFAS: What Happened to the “Brilliant Future” of Forever Chemicals?, Yale Sci. Mag. (Feb. 11, 2024), https://www.yalescientific.org/2024/02/revisiting-pfas-what-happened-to-the-brilliant-future-of-forever-chemicals/ (identifying DuPont’s Teflon as “one of the most notorious PFAS”).

[6] Roy J. Plunkett, supra note 4 (describing PTFE as “heat resistant and chemically inert” and that “most other substances would not adhere to it”); Jiang, supra note 5 (explaining the stable and unreactive nature of PFAS).

[7] Jiang, supra note 5 (noting that by 1951 3M had begun producing PFOA and was sending it to DuPont’s Parkersburg plant for the manufacture of commercial Teflon products, and that 3M began producing Scotchgard with PFOS around the same time).

[8] Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), supra note 1 (explaining that PFAS “do not degrade easily in the environment” because of the chemical bond strength).

[9] See Our Current Understanding, supra note 2.

[10] See Jiang, supra note 5 (observing that “the same unique characteristics that led to PFAS being dubbed ‘forever chemicals’ are intertwined with their potential health and environmental risks”).

[11] See Chemical Sprays: 57 Years Since Rachel Carson’s Silent Spring, and What Have We Learned?, Land Between (Aug. 20, 2019), https://www.thelandbetween.ca/2019/08/environmentally-friendly-and-non-toxic-bug-repellents/ (noting that films “from the late 1940s show DDT being sprayed on children in a swimming pool to showcase how ‘safe’ it was,” and that DDT was used on crops, gardens, and inside homes).

[12] U.S. Env’t Prot. Agency, EPA-540/1-75-022, DDT: A Review of Scientific and Economic Aspects of the Decision To Ban Its Use as a Pesticide 251 (1975) (“Certain characteristics of DDT which contributed to the early popularity of the chemical, particularly its persistence, later became the basis for public concern over possible hazards involved in the pesticide’s use.”).

[13] See Eagles, Other Birds Thrive After EPA’s 1972 DDT Ban, EPA J. (July 1983), reprinted by EPA Archive, https://www.epa.gov/archive/epa/aboutepa/eagles-other-birds-thrive-after-epas-1972-ddt-ban.html); DDT – A Brief History and Status, U.S. Env’t Prot. Agency, (Aug. 24, 2026), https://www.epa.gov/ingredients-used-pesticide-products/ddt-brief-history-and-status.

[14] Eagles, Other Birds Thrive After EPA’s 1972 DDT Ban, supra note 13 (attributing eggshell thinning that “caused sharp population declines” in certain birds to DDT use).

[15] DDT – A Brief History and Status, U.S. Env’t Prot. Agency, (Aug. 24, 2026), https://www.epa.gov/ingredients-used-pesticide-products/ddt-brief-history-and-status.

[16] See U.S. Env’t Prot. Agency, supra note 12 (observing the persistence that “contributed to the early popularity of the chemical . . . later became the basis for public concern”); Sam Kean, How Asbestos Fell from Grace, The Disappearing Spoon (Sci. Hist. Inst. May 6, 2025), https://www.sciencehistory.org/stories/disappearing-pod/how-asbestos-fell-from-grace/ (transcript)(recounting that asbestos, once “a wonder material,” was used in “pretty much every building erected between 1900 and 1980,” that it “flipped from wonder material to deadly poison” as its lung-disease toll emerged); Gerald Markowitz, From Industrial Toxins to Worldwide Pollutants: A Brief History of Polychlorinated Biphenyls, 133 Pub. Health Reps. 721, 722, 724 (2018) (explaining that PCBs “were designed to be chemically stable and fire resistant,” that Monsanto marketed their “durability,” that “[b]ecause of their chemical stability, they remained in the environment for long periods,” and that Congress banned their manufacture in the 1976 Toxic Substances Control Act).

[17] See Jiang, supra note 5 (explaining that water-soluble PFAS “can follow natural solubility pathways” to infiltrate groundwater); Our Current Understanding, supra note 2 (listing “[s]oil and water at or near waste sites” such as landfills among places PFAS can be found).

[18] See Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS), supra note 1 (explaining that “[b]ecause PFAS break down slowly, if at all, people and animals are repeatedly exposed to them”).

[19] See Our Current Understanding, supra note 2 (identifying drinking water, soil, waterways near landfills, and fish in contaminated streams as exposure pathways); Nadia Barbo et al., Locally Caught Freshwater Fish Across the United States Are Likely a Significant Source of Exposure to PFOS and Other Perfluorinated Compounds, 220 Env’t Rsch., 1, 1, 3, 5–6 (2023)(finding that a single serving of locally caught freshwater fish at the median PFOS level is equivalent to a month of drinking water contaminated at 48 parts per trillion).

[20] See Our Current Understanding, supra note 2 (“One common characteristic of concern of PFAS is that many break down very slowly and can build up in people, animals, and the environment over time.”).

[21] Id.

[22] C8 Probable Link Reports, C8 Sci. Panel, http://www.c8sciencepanel.org/prob_link.html; see also Catie Boston et al., The Evolution of PFAS Epidemiology: New Scientific Developments Call into Question Alleged “Probable Links” Between PFOA and Kidney Cancer and Thyroid Disease, 13 Frontiers Pub. Health, 1, 1-2 (2025) (describing the panel’s creation under a class-action settlement, its study of residents exposed to PFOA, enrollment of 69,030 participants, and the 2012 probable-link findings for six conditions).

[23] C8 Probable Link Reports, supra note 23 (collecting the panel’s probable-link findings).

[24] See Press Release, Int’l Agency for Rsch. on Cancer, IARC Monographs Evaluate the Carcinogenicity of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) (Dec. 1, 2023), https://www.iarc.who.int/news-events/iarc-monographs-evaluate-the-carcinogenicity-of-perfluorooctanoic-acid-pfoa-and-perfluorooctanesulfonic-acid-pfos.

[25] See Jiang, supra note 5 (describing the “unique combination of properties” for PFAS);

[26] See Yale Experts Explain PFAS ‘Forever Chemicals’, Yale Sustainability (May 20, 2025), https://sustainability.yale.edu/explainers/yale-experts-explain-pfas-forever-chemicals (quoting attorney Robert Bilott that “[c]ompanies like 3M and DuPont set internal safety guidelienes for their employees decades ago, but this information was withheld from government agencies and scientists until much later”).

[27] Cheryl Hogue, DuPont, EPA Settle, Chem. & Eng’g News (Dec. 19, 2005), https://cen.acs.org/articles/83/i51/DuPont-EPA-Settle.html (quoting EPA’s enforcement chief that the most serious allegation was DuPont’s failure to report, for more than twenty years, that PFOA had been found in the umbilical cord of a baby born to a Parkersburg plant worker); Press Release, U.S. Env’t Prot. Agency, EPA Settles PFOA Case Against DuPont for Largest Environmental Administrative Penalty in Agency History (Dec. 14, 2005), https://www.epa.gov/archive/epapages/newsroom_archive/newsreleases/fdcb2f665cac66bb852570d7005d6665.html

[28] Press Release, U.S. Env’t Prot. Agency, supra note 28 (announcing a $10.25 million civil penalty plus $6.25 million in supplemental environmental projects to resolve eight counts under the Toxic Substances Control Act and the Resource Conservation and Recovery Act).

[29] Cheryl Hogue, US EPA Deems Two GenX PFAS Chemicals More Toxic than PFOA, Chem. & Eng’g News (Oct. 29, 2021), https://cen.acs.org/environment/persistent-pollutants/US-EPA-deems-two-GenX-PFAS-chemicals-more-toxic-than-PFOA/99/i40 (reporting DuPont began manufacturing GenX in 2009, later followed by its Chemours spin-off, and that it was marketed as a “sustainable substitute” for PFOA).

[30] Id. (explaining that GenX is a PFAS synthetic forever chemical).

[31] Id. (reporting EPA’s final toxicity assessment setting a safe daily dose of 3 nanograms per kilogram of body weight for GenX, compared to 20 nanograms per kilogram for PFOA).

[32] Our Current Understanding, supra note 2.

[33] PFAS National Primary Drinking Water Regulation, 89 Fed. Reg. 32,532 (Apr. 26, 2024).

[34] Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances, 89 Fed. Reg. 39,124, 39,125 (May 8, 2024) (explaining that designation opens CERCLA actions and cost-recovery authorities and ensures that polluters are financially responsible); see also 42 U.S.C. § 9607(a) (imposing liability following a release of a hazardous substance).

[35] Extending the Compliance Deadline for the PFOA and PFOS Maximum Contaminant Levels, 91 Fed. Reg. 29,425, 29,427 (proposed May 20, 2026) (noting that under the 2024 rule all systems must complete initial monitoring by April 2027, and comply with the MCLs by April 2029).

[36] See Proposed PFAS Rescission Rule, U.S. Env’t Prot. Agency, (last updated July 23, 2026) https://www.epa.gov/sdwa/proposed-pfas-rescission-rule (describing the proposal to rescind the regulatory determinations and maximum contaminant levels for four PFAS formulations); Extending the Compliance Deadline, supra note 36 (proposing a federal exemption for PFOA and PFOS compliance dates to April 2031 for water systems that request an extension).

[37] See Chamber of Com. of the U.S. v. EPA, 187 F.4th 636, 649 (D.C. Cir. 2026) (holding that CERCLA’s plain language allows the EPA to designate chemicals “repeatedly” linked to adverse health effects).

[38] See Kampf, supra note 2 (reporting that PFAS legislation has been “a priority for states across the country” and that states are expected to keep advancing PFAS laws “as federal regulations shift”).

[39] Id.

[40] Id.

[41] Minnesota’s New Ban on PFAS Compounds and the Impact on Products Sold and Distributed in Minnesota, Fafinski Mark & Johnson, P.A., https://www.fmjlaw.com/minnesotas-new-ban-on-pfas-compounds-and-the-impact-on-products-sold-and-distributed-in-minnesota/ (noting that some of Minnesota’s PFAS laws “are the first of their kind” and are “among the broadest in the country”).

[42] Minn. Stat. § 116.943(5)(a) (2025) (prohibiting the sale of listed products containing intentionally added PFAS); PFAS Use Prohibitions and Reporting, Minn. Pollution Control Agency, https://www.pca.state.mn.us/air-water-land-climate/pfas-use-prohibitions-and-reporting. On the law’s namesake, see Fafinski Mark & Johnson, P.A., supra note 43.

[43] Minn. Stat. § 116.943, (5)(d) (2025) (prohibiting, beginning 2032, the sale of any product containing intentionally added PFAS unless the commissioner of the Pollution Control Agency has determined the use is currently unavoidable).

[44] Kampf, supra note 2 (summarizing New Mexico’s phased bans beginning in 2027, and describing similar product bans enacted in Vermont and New Hampshire); see also N.M. Stat. Ann. §§ 74-15-1, 74-15-3(E) (2025); Me. Rev. Stat. Ann. tit. 38, § 1614(5)(D) (2025).

[45] Per- and Polyfluoroalkyl Substances (PFASs), U.N. Env’t Programme, (last updated June 10, 2026), https://www.unep.org/topics/chemicals-and-pollution-action/pollution-and-health/persistent-organic-pollutants-pops/and

[46] Mason Wakley, European Chemicals Agency Backs EU-Wide PFAS Ban, Chemistry World (Mar. 27, 2026), https://www.chemistryworld.com/news/european-chemicals-agency-backs-eu-wide-pfas-ban/4023196.article (reporting that ECHA’s Risk Assessment Committee and Socio-Economic Analysis Committee support an EU-wide restriction on PFAS, following a January 2023 proposal from Denmark, Germany, the Netherlands, Sweden, and Norway).

[47] Marta Pacheco, EU Chemicals Agency Backs ‘Forever Chemicals’ Ban, with Final Decision to the Commission, Euronews (Mar. 26, 2026), https://euronews.com/my-europe/2026/03/26/eu-chemicals-agency-backs-forever-chemicals-ban-with-final-decision-to-the-commission.

[48] See Monica Amarelo, These Olympics Are First to Feature a Ban on ‘Forever Chemicals’ in Ski and Snowboard Wax, Env’t Working Grp. (Feb. 12, 2026), https://www.ewg.org/news-insights/news/2026/02/these-olympics-are-first-feature-ban-forever-chemicals-ski-and-snowboard (noting the International Ski and Snowboard Federation banned PFAS-based fluorinated waxes during the 2023–24 season, the Milano Games would ban PFAS-based waxes, and the World Cup and World Championship events conduct mandatory PFAS testing).

[49] Id. (noting that every pair of skis competing at the 2026 Games would be tested).

[50] Rebecca Trager, PFAS Waxes Found on Skis and Snowboards Lead to Three Olympic Disqualifications, Chemistry World (Feb. 18, 2026), https://www.chemistryworld.com/news/pfas-waxes-found-on-skis-and-snowboards-lead-to-three-olympic-disqualifications/4022977.article

[51] See Hogue, DuPont, EPA Settle, supra note 28; Yale Experts Explain PFAS ‘Forever Chemicals’, supra note 27 (quoting Bilott that federal action “took decades, with companies pushing back and fighting regulation in courts”)