How to Request PFAS Compliance Documentation from Your Supplier

Why Documentation Matters

Compliance without documentation is, from a practical standpoint, no compliance at all. If a regulator, auditor, or customer asks whether your food packaging is PFAS-free, a verbal claim from your supplier is not sufficient proof. You need written records that demonstrate your packaging has been tested and meets applicable regulatory requirements.

This is true in every state with PFAS food packaging regulations, but it is especially critical in states where food service operators bear direct liability. In Minnesota, for example, restaurants and food trucks are themselves liable for using non-compliant packaging — not just the manufacturer or distributor. If your business operates in a user-liable state, your compliance documentation is your primary defense.

Even in states where manufacturers bear primary liability, maintaining your own records protects your business in several ways. It demonstrates due diligence if questions arise. It creates a paper trail if you need to make a claim against a supplier who provided non-compliant products. And it gives you a baseline for monitoring ongoing compliance as regulations evolve and your suppliers change.

What to Request

When reaching out to your food packaging supplier about PFAS compliance, request the following five items. Not every supplier will be able to provide all five, but a well-documented supplier should be able to provide at least the first three.

1. Certificate of Analysis (COA) with TOF testing results. This is the most important document. A COA from an accredited laboratory should show the results of total organic fluorine (TOF) testing on the specific product you purchase. The COA should include the test method used, the laboratory name, the date of testing, and the result in parts per million (ppm). For California compliance, the result should be below 100 ppm TOF.
2. Letter of Compliance stating the product is PFAS-free. This is a written statement from the manufacturer or supplier affirming that the product does not contain intentionally added PFAS and meets the requirements of specific named regulations. A good Letter of Compliance references the applicable laws by name (e.g., California AB 1200, New York Senate Bill S4246) rather than making vague general claims.
3. Material Safety Data Sheet (SDS) for the packaging. The SDS provides detailed information about the chemical composition of the product. While an SDS alone is not sufficient proof of PFAS compliance, it provides useful context and may list chemicals used in the manufacturing process. Reviewing the SDS can help identify potential concerns that warrant further investigation.
4. Supply chain traceability information. Understanding where your packaging is manufactured and what materials go into it helps you assess the reliability of compliance claims. A supplier who can tell you the name and location of the manufacturing facility, the source of raw materials, and the production process is more credible than one who cannot.
5. Testing laboratory name and accreditation. The COA should identify the testing laboratory and its accreditation status. Look for laboratories accredited under ISO/IEC 17025, which is the international standard for testing and calibration laboratories. Results from an accredited laboratory carry more weight than results from an unaccredited or in-house facility.

Template Letter

The following template can be adapted for your own use when contacting food packaging suppliers about PFAS compliance. Customize the bracketed sections with your specific information.

Subject: PFAS Compliance Documentation Request — [Your Business Name]

Dear [Supplier Name / Contact Person],

I am writing to request PFAS compliance documentation for the food packaging products we purchase from your company. As you may be aware, multiple U.S. states have enacted laws restricting the use of PFAS (per- and polyfluoroalkyl substances) in food-contact packaging, and we are working to verify compliance across our packaging inventory.

Specifically, we purchase the following items from your company and would appreciate documentation for each:

1. [Product name / SKU — e.g., "9-inch molded fiber clamshell, item #12345"]
2. [Product name / SKU]
3. [Product name / SKU]

For each product listed above, we are requesting:

• A current Certificate of Analysis (COA) from an accredited testing laboratory, showing total organic fluorine (TOF) test results in parts per million (ppm)
• The name and accreditation status of the testing laboratory
• The test method used (e.g., combustion ion chromatography per EPA Modified Method 537.1, or equivalent)
• A Letter of Compliance confirming the products do not contain intentionally added PFAS and meet applicable state regulations
• A Material Safety Data Sheet (SDS) for each product, if available

We would also appreciate knowing whether your company has a process for notifying customers of any changes to product formulation or PFAS testing status. As regulations continue to evolve, staying informed about changes in our supply chain is important for maintaining compliance.

If you have any questions about this request, please do not hesitate to reach out. We value our business relationship with your company and want to ensure we have the documentation needed to meet current regulatory requirements.

Thank you for your prompt attention to this matter.

Sincerely,
[Your Name]
[Your Title]
[Your Business Name]
[Phone / Email]

Feel free to adjust this template based on your specific situation. If you operate in a particular state, you may want to reference that state's regulation by name. If you have upcoming deadlines (such as a compliance audit), mentioning the timeline can help prioritize the response.

Understanding the Response

Once your supplier responds, evaluating the quality of their documentation is just as important as having requested it. Not all responses are created equal.

If a supplier's response falls into the red-flag category, that does not necessarily mean their products contain PFAS. It may simply mean their documentation practices need improvement. However, it does mean you cannot currently verify their compliance claims, which is a risk for your business. Consider following up with a specific, time-bound request for the missing documentation, and begin investigating alternative suppliers in parallel.

Maintaining Records

Once you begin collecting PFAS compliance documentation from your suppliers, organizing and maintaining those records is essential. Documentation is only useful if you can find it when you need it. The following structure has worked well for food businesses managing PFAS compliance:

• Organize by supplier. Create a folder or digital directory for each supplier. Within each supplier folder, store all COAs, Letters of Compliance, SDS documents, and correspondence.
• Cross-reference by packaging type. Maintain a spreadsheet or inventory list that maps each packaging item (by SKU or description) to the corresponding supplier, COA document, test date, and TOF result. This makes it easy to quickly identify the compliance status of any item in your inventory.
• Track document dates. COAs and compliance letters have a limited useful life. Testing results from two or three years ago may not reflect the current formulation of a product. Set calendar reminders to request updated documentation annually, or whenever you learn that a supplier has changed their manufacturing process or sourcing.
• Store securely with backups. Paper documents can be lost to water damage, fire, or simple disorganization. Digital storage (cloud-based, with backups) ensures your records survive. If you handle compliance documentation digitally, make sure your files are named consistently and backed up regularly.

PFAS Packaging Check's document storage feature, available on the Pro tier, provides a structured way to store and organize PFAS compliance documentation. You can upload COAs, compliance letters, and SDS documents, associate them with specific suppliers and packaging items, and receive reminders when documentation is approaching its refresh date. Access your stored documents anytime through the documents section of your PFAS Packaging Check account.

What If Your Supplier Cannot Provide Documentation?

If your supplier is unable or unwilling to provide PFAS compliance documentation after a reasonable request, you have several options to consider.

• Give a clear deadline. Some suppliers, particularly smaller ones, may simply not have organized their PFAS documentation yet. A polite but firm follow-up with a specific date by which you need the information ("We need this documentation by [date] to maintain our compliance records") can sometimes prompt action.
• Commission independent testing. If you need to continue using a supplier's product in the short term while you evaluate alternatives, you can send a sample to an accredited laboratory for TOF testing yourself. Testing typically costs $100 to $500 per sample and takes one to three weeks. This gives you a definitive answer about that specific product.
• Switch suppliers. If a supplier cannot document that their products are PFAS-free, switching to one that can is often the most straightforward path to compliance. The short-term inconvenience of changing suppliers is typically less costly than the risk of using undocumented packaging in a regulated state.
• Use the PFAS Packaging Check supplier directory. Our supplier directory highlights which distributors and manufacturers provide full PFAS compliance documentation, including COAs and Letters of Compliance. Filtering for documented suppliers can save you time when evaluating alternatives.