“PFC-free” isn’t the same as “PFAS-free”
Supplier labels like PFC-free, PFOA-free and C6 each describe one part of the chemistry. State PFAS laws cover the whole family. Here’s how the terms line up, and what to ask instead.
What the labels usually mean
These are trade terms, not legal ones. They come from water-repellent finishes, where the number refers to how many carbon atoms sit in the fluorinated chain. The state laws use one word, PFAS, and define it broadly.
| Term | What it usually means | PFAS under the state laws? |
|---|---|---|
| C8 | An older finish built on eight-carbon fluorinated chains, linked to PFOA | Yes |
| C6 | A finish built on six-carbon fluorinated chains, the common replacement for C8 | Yes |
| PFOA-free | Free of PFOA, one specific PFAS. A C6 finish can be PFOA-free. | Can still contain PFAS |
| PFC-free | An older term. Some suppliers mean no fluorinated chemistry at all; others mean only no long-chain chemistry. | Depends on who wrote it |
| C0 | A finish with no fluorinated chain | Not if nothing else in the material is fluorinated |
| PFAS-free | No intentionally added PFAS | No, and it’s the claim to get in writing |
Why the laws reach further
PFAS means “a class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.”
Washington’s statute uses the same words (RCW 70A.350.010(10)).
One fully fluorinated carbon is enough. A C6 finish has several, so it’s PFAS. So are fluoropolymers like PTFE, the nonstick coating, and ePTFE, the waterproof membrane in many rain shells.
- Minnesota has no fluoropolymer carve-out and no minimum amount, so PTFE and ePTFE are reported like any other PFAS (Minn. Stat. 116.943).
- Connecticut has no fluoropolymer exemption either (CT DEEP).
- Washington presumes PFAS was added on purpose when a test finds total fluorine above 50 ppm (WAC 173-337-110).
New Mexico’s exception for solid fluoropolymers
New Mexico exempts, from both reporting and its sales bans, products containing fluoropolymers that are solid at standard temperature and pressure (HB 212, sec. 3; NMED). In practice that means PTFE nonstick coatings and ePTFE membranes.
It doesn’t cover the rest of the family. Side-chain fluorinated water repellents, the C6 and C8 finishes, and fluorinated ski waxes aren’t fluoropolymers under that definition, so they’re reported in New Mexico. Whether a jacket with both an ePTFE membrane and a fluorinated finish is fully exempt is an open question with the state.
What to ask your suppliers
Don’t ask “is it PFC-free?” A yes doesn’t tell you what the state wants to know. Ask instead:
- Is any PFAS intentionally added to this material, meaning any chemical with at least one fully fluorinated carbon atom, including C6 finishes and fluoropolymers like PTFE?
- If yes: the chemical name and CAS number, what it does, and its concentration or a range.
- If it’s a fluoropolymer: is it a solid, like a PTFE coating or ePTFE membrane? That answer matters in New Mexico.
A “PFC-free” hang tag or a marketing sheet isn’t a declaration. Get a signed answer for each material. Our free supplier declaration template asks exactly these questions.
If the answer is still unclear
A total fluorine test catches the whole family, whatever the label says. It’s also the measure some states use: Washington’s 50 ppm presumption and Vermont’s total organic fluorine limit for textiles (100 ppm, then 50 ppm from July 1, 2027; 9 V.S.A. 2494f). See every state we track, or check your products in the scope checker.
Sources: Minn. Stat. 116.943, RCW 70A.350.010, WAC 173-337-110, NM HB 212 (2025), CT DEEP: PFAS in products, 9 V.S.A. 2494f.
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