What are Long – chain PFAAs, why are they still in Consumer Supply Chains, and should we be worried?

An initiative of ALGA’s Emerging Contaminants of Concern Specialist Interest group.

Written by Dr Karl Bowles, Dr Matthew Askeland and Dr Attila Tottszer. 

PFAS (per- and polyfluoroalkyl substances) are an extremely large and varied group of chemicals. Over the past decade, several governments worldwide have taken steps to phase out production and use of only a small number of these. Such efforts commonly are centred on long-chain perfluoroalkyl acids (PFAAs), a subset of PFAS that includes PFOS, PFOA and PFHxS, as many view these as the most hazardous PFAS, based on limited available toxicity data.

Production, use, and disposal of PFOS, PFOA, PFHxS, long chain perfluorinated carboxylic acids (and related substances) have been heavily restricted under the Stockholm Convention for Persistent Organic Pollutants, to which New Zealand and Australia are signatories. Australia has not yet ratified the PFAS Stockholm Convention listings, but has effectively banned the use or importation of PFOS, PFHxS and PFOA and related substances under recently implemented Industrial Chemicals Environmental Management Standard (IChEMS) legislation. Some Australian states have also implemented restrictions or bans on PFAS, or at least long chain PFAAs in firefighting foams.

Importantly, the Stockholm and IChEMS restrictions apply not just to the long chain PFAA (e.g. PFOS or PFOA) but also to their related substances. These are often called precursor PFAS (or incorrectly PFAS precursors) and are chemicals that contain a PFAA as part of their structure and can degrade in the environment, sewage treatment plants, etc. to form those PFAAs.

Following regulatory pressures such as listing of some PFAS on the Stockholm Convention and pressures exerted by the US EPA, production of long chain PFAAs is believed to have been phased out in Western nations earlier this century.

Despite these efforts, recent scientific publications have revealed that long chain PFAAs are still common in products and articles globally, including Australia (and presumably New Zealand). Dewapriya et al. (2023) conducted a review of studies reporting PFAS in consumer products globally. The review included quite diverse product categories, including household chemicals, cosmetics, textile finishing products, food contact materials, waxes and polishes, electronics, firefighting foams and building materials. They compiled over 5900 data points (each data point being a concentration for a specific PFAS in a consumer product or article), excluding data for firefighting foams and building materials. Nearly 600 data points (10.1%) were at or above 1 ppm PFAS. The highest concentration was 29,000 PPM for PFDA, a long chain PFAA. Importantly, many of the highest concentrations were for long chain PFAS that are assumed to have been phased out by Western manufacturers.

Other recent reports support the findings from Dewapriya et al. For example, a 2025 Greenpeace investigation into fast-fashion textiles found extremely high concentrations of fluorotelomer alcohols (FTOHs), including the long chain 8:2 FTOH and 10:2 FTOH in the hundreds of mg/kg range across shoes, jackets, shirts and children’s apparel (see pages 38–48 of the analytical report at this link: https://www.greenpeace.de/publikationen/Laborbericht_0.pdf). FTOHs also featured among the highest concentrations in the review by Dewapriya et al. (2023).

Ideally, these FTOHs should be managed in Australia and New Zealand, in particular 8:2 FTOH which would be captured under Stockholm Convention and IChEMS as related substances to PFOA. The ongoing findings of concentrations of long chain PFAAs and related substances in a diverse range of domestic and commercial products is commonly assumed to be an indication of importation of products and articles from Asia. China, in particular, is a major centre of PFAS production. Some production also occurs in India but less is known about PFAS produced and production volumes (Kookana et al. 2025).

Of the approximately 6400 data points (now including data for firefighting foams and building materials) identified by Dewapriya et al. (2023), about 2,400 (37.5%) were at or above 0.025 parts per million (PPM). This is the level below which can be considered unintentional trace contamination according to the definition used by IChEMS for PFOS, PFOA and PFHxS. In other words, these substances are not merely incidental residues, they are intentionally added to achieve desired physical and chemical properties.

The widespread presence of long chain PFAAs and their precursors in low-cost, readily available clothing (Greenpeace 2025) highlights the difficulties in managing PFAS in a global economy. The failure is not as much by intent of existing regulation, but rather reflects the difficulties of testing for a highly diverse range of chemicals at the speed and scale required if imports were to be effectively controlled.

Also important is that these PFAS are in items that involve direct human exposures such as clothing and household textiles. FTOHs volatilise to the air, and both FTOHs and their PFAA transformation products can be released in dust, resulting in exposure via breathing and incidental ingestion. Further, FTOHs are readily washed from garments during laundering. From there, they enter wastewater treatment plants, where they break down further into persistent PFAAs, ultimately appearing in effluent, recycled water and biosolids and presenting potential risk to environmental receptors, as well as resource recovery (organics and water circular economies). At end of life, when articles are discarded to landfill, FTOHs contribute to PFAS present in leachate, which then requires active management. Recent studies have also shown FTOHs present in landfill gas (Del la Cruz et al., 2025). Beyond environmental pathways, the presence of high-FTOH textiles raises major questions about the viability of textile circularity: garments containing hundreds of mg/kg of volatile PFAS cannot simply be reused, shredded, composted, or recycled without carrying the contamination forward.

Some of the challenge around identification of these PFAS species is associated with analytical techniques, where traditional PFAS analytical suites offered by most laboratories do not include key precursor families such as FTOHs. These compounds are neutral, semi-volatile and thermally stable, and therefore ionise poorly under standard liquid chromatography tandem mass spectrometer (LC-MS/MS) conditions. In contrast, Gas Chromatography (GC) provides substantially stronger and cleaner analytical signals, with characteristic fluorinated fragments that enable greater selectivity and lower limits of reporting. Recent methodological advances in GC-MS/MS have demonstrated reliable ultra-trace detection of FTOHs (Mok et al., 2023). These methods support exploratory research; however more robust and commercially available/accessible laboratory methods are needed to enable routine precursor screening in articles and consumer goods to strengthen our understanding and hence ability to control PFAS mass loads entering Australia as FTOH and other precursor species.

To improve this regrettable situation, several steps are needed, some of which are already underway but face significant logistical or scientific challenges. Specifically, options may include:

  • Government to work with industry representative bodies to raise awareness of PFAS – already occurring in Australia via industry bodies such as the Australian Packaging Covenant Organisation (APCO), action plan available here: https://apco.org.au/news/20Y9e00000001N7EAI. Awareness must be broadened to understand that foreign exporters to Australia may have a poor understanding of PFAS in their products and articles.
  • Introduce import controls and screening for high-risk consumer goods (textiles, footwear, cosmetics, food-packaging). This is challenged by existing analytical techniques that are typically expensive and time-consuming and require sophisticated labs and trained operators. Non-specific analyses such as variants of Total Organic Fluorine may play a role. Ultimately, rapid surface scanning mass spectrometry methods and rapid sensors may be needed—but these are still in development.
  • Mandate supplier disclosure of PFAS use in treatments such as durable water repellents and stain-resistant coatings. This may not always be possible to enforce in a global economy.
  • Safeguard textile recycling using TOF/precursor thresholds to prevent contaminated feedstock from entering circular economy pathways.
  • Promote research to better understand PFAS in wastewater, recycled water and landfill leachate, with specific inclusion of volatile and semi-volatile precursors such as FTOHs. This will help enable full lifecycle product stewardship programs for problematic materials.
  • Invest in national testing capability and research, including precursor analytics, laundering release studies and development of more rapid and deployable analytical methods.
Epic environmental

Australian Government. (2022). Industrial Chemicals Environmental Management (Register) Instrument 2022 (IChEMS). Department of Climate Change, Energy, the Environment and Water (DCCEEW). https://www.dcceew.gov.au/environment/protection/industrial-chemicals/environmental-management

Australian Packaging Covenant Organisation. (2022). Action Plan to Phase Out PFAS in Fibre-Based Food Contact Packaging.

De la Cruz, F., Barlaz, M., & others. (2025). Nationwide estimate of volatile per- and polyfluoroalkyl substance (PFAS) emissions from U.S. landfills via landfill gas. Environmental Science & Technology Letters. Advance publication. https://doi.org/10.1021/acs.est.5c08763

Dewapriya, P., Chadwick, L., Ghorbani Gorji, S., Schulze, B., Valsecchi, S., Samanipour, S., Thomas, K. V., & Kaserzon, S. L. (2023). Per- and polyfluoroalkyl substances (PFAS) in consumer products: Current knowledge and research gaps. Heliyon – Environmental Science, 4, 100086. https://doi.org/10.1016/j.hazl.2023.100086

Kookana, R. S., Sha, B., Baluyot, J. C., Bowles, K. C., Kah, M., Padhye, L. P., Ying, G. G., Navarro, D., Velarde, M. C., Higgins, C. P., & Cousins, I. T. (2025). Human exposure to per- and poly-fluoroalkyl substances (PFAS) in Asia and contributing factors, with a focus on East Asia. Environmental Science: Processes & Impacts, 27, 2614–2635. https://doi.org/10.1039/D5EM00396B

Mok, S., Lee, S., Choi, J., Jeon, J., Hee Kim, Y., & Moon, H.-B. (2023). Target and non-target analyses of neutral per- and polyfluoroalkyl substances from fluorochemical industries using GC-MS/MS and GC-TOF: Insights on their environmental fate. Environment International, 182, 108311. https://doi.org/10.1016/j.envint.2023.108311

Disclaimer

The views and information in this publication are those of the author and not the Australasian Land & Groundwater Association Ltd (ALGA), which acts solely as publisher. This publication does not constitute legal advice, and no warranty is given as to its accuracy or completeness. To the extent permitted by law, ALGA and the author accept no liability. Readers should seek independent professional advice if required.