A wellness-focused activewear brand says it does not use PFAS in its products. A state attorney general says he wants proof. This is the gap we are examining: the space between a corporate statement and a verifiable public test report for PFAS-free clothing.
The claim
On April 13, 2026, Texas Attorney General Ken Paxton issued a Civil Investigative Demand to Lululemon USA Inc. According to the Texas Attorney General's Office, the investigation will examine whether Lululemon's athletic apparel contains PFAS "that their health-conscious customers would not expect based on the brand's marketing."
Three days later, Lululemon published a page titled "Created without PFAS: What to know about lululemon's products." According to Bergeson & Campbell, the company stated it does not use PFAS in products today, and its "ongoing focus is to help prevent the unintentional reintroduction of PFAS into our products through ongoing testing, monitoring, and collaboration with suppliers and third parties."
The company responded to the investigation with a clear denial. According to ESG Dive, a Lululemon spokesperson stated: "Lululemon does not use PFAS in its products." The company added that it "phased out" the use of PFAS in fiscal year 2023, prior to which it had been "used in durable water repellent products, a small percentage of our assortment."
The product page
Lululemon's Align leggings are among the brand's best-selling items. The Align line is made of Nulu fabric, a blend of 81% nylon and 19% Lycra elastane. Nylon is a synthetic fiber. The question is not about fiber type. The question is whether those fibers, or the finishes applied to them, contain PFAS.
According to PFAS Observer, Lululemon maintains a Restricted Substances List consistent with the AFIRM Group and caps total organic fluorine at 50 ppm. The company says it "takes steps" to enforce these standards through vendor testing.
We could not find a public test report from Lululemon demonstrating that current products are PFAS-free. The company states that it requires vendors to conduct third-party testing, but those test results have not been published.
The gap
The Texas AG's investigation centers on whether Lululemon has misled consumers about the safety and health impacts of its products. According to the official announcement, the inquiry will "review the company's Restricted Substances List, testing protocols, and supply chain practices to determine whether Lululemon's products comply with its stated safety standards."
The gap is specific. A brand can state it does not use PFAS. A brand can state it has phased out PFAS. A brand can state it has a Restricted Substances List. What a brand has not done, in this case, is publish a test report from an independent laboratory confirming the absence of PFAS in current products.
This matters because prior testing has found PFAS indicators in Lululemon products. In 2021, Mamavation, an environmental wellness blog, sent Lululemon athletic pants to an EPA-certified laboratory for fluorine testing. The testing was conducted from the crotch area, which is a common area where PFAS concentrations are found in activewear. The Mamavation investigation noted that because contamination was detected at levels high enough to measure, the site "cannot recommend this brand."
According to Environmental Health News, partnering with Mamavation on activewear testing, the study "found levels of fluorine ranging from 10 parts per million (ppm) up to 284 ppm in eight pairs of leggings and pants, out of 32 tested." The highest concentrations were in other brands, but Lululemon was among those flagged.
Lululemon says it phased out PFAS in fiscal year 2023. The Mamavation testing was conducted in 2021. There is no publicly available follow-up test from an independent lab confirming that current Lululemon products are now PFAS-free. This is the gap the Texas investigation may address.
What other brands in the category are doing
Some apparel brands have chosen to publish PFAS-related data or earn third-party certifications.
According to the NRDC, Levi Strauss & Co. earned the highest mark on a PFAS scorecard "for already eliminating PFAS from its supply chain." The NRDC, Fashion FWD, and U.S. PIRG Education Fund released this scorecard rating apparel brands on their PFAS policy commitments.
The same scorecard gave poor grades to several outdoor brands. According to the NRDC, "Columbia Sportswear, REI, Wolverine Worldwide (parent company of Wolverine and Merrell), and others received 'F's." Patagonia earned a B, "the highest score in the sector, as the only outdoor brand with a commitment to phase out all PFAS in all products by 2024."
Lululemon was not among the 30 brands explicitly graded in the NRDC scorecard, which focused primarily on outdoor and general retail brands. However, the framework the NRDC used offers a template for what a strong PFAS commitment looks like: a time-bound phaseout across all products, public disclosure of testing protocols, and third-party verification.
The microfiber question
PFAS is not the only material concern facing Lululemon. Shareholders have also raised questions about microfiber shedding from the brand's synthetic garments.
In December 2025, the shareholder advocacy group As You Sow filed a resolution requesting that Lululemon "issue a report, at reasonable expense and excluding proprietary information, evaluating whether opportunities to reduce microfiber pollution from its garments will strengthen the Company's long-term value and mitigate emerging material risk." The As You Sow resolution notes that "as a global apparel brand, Lululemon has significant exposure to synthetic fibers and microfiber shedding."
According to ICCR, during production and wear, "an estimated 200,000 to 500,000 total tons of plastic microfibers from textiles enter the world's oceans annually." The resolution asks Lululemon to evaluate ways to make its fiber shedding data publicly available, discuss manufacturing treatment technologies to minimize shedding, and disclose planned capital expenditures to control microfiber shedding.
This is relevant because Lululemon's core product line is made of nylon and polyester: synthetic fibers that shed microplastics during washing and wear. A brand that markets itself as wellness-focused may face questions about whether wellness includes the environmental and health impacts of microplastic pollution.
According to Raymond James, in 2024, As You Sow proposed that Lululemon explore the impact of microfiber shedding on waterways. Following that resolution, "the company is now reporting on product shedding and solutions and researching a new microfiber shedding reduction goal."
The greenwashing lawsuit
In July 2024, a Florida resident named Amandeep Gyani filed a proposed class action lawsuit against Lululemon, alleging that the company's "Be Planet" marketing campaign was misleading. According to Top Class Actions, the complaint argued that experts "do not consider these products to be a truly sustainable alternative as they are energy intensive to manufacture, do not biodegrade and still release microplastics."
The lawsuit was dismissed. According to ArentFox Schiff, "In 2024, Lululemon Athletica Inc. and Lululemon USA Inc. were on the receiving end of such a lawsuit, but they recently prevailed on a motion to dismiss." On February 18, 2025, Judge Beth Bloom granted Lululemon's motion, finding that the plaintiffs failed to adequately link the company's environmental statements to any economic injury.
The dismissal was procedural, not substantive. The court did not rule on whether Lululemon's marketing claims were accurate. It ruled that the plaintiffs had not demonstrated the required legal standing to pursue the case. According to the National Law Review, the court held that "blanket assertions are insufficient to constitute an economic injury."
What a brand founder should ask
A sourcing lead or brand founder reviewing their own activewear line's PFAS exposure should consider the following questions for their suppliers:
- Does your factory use PFAS in any water-repellent finishes or treatments? If so, which products?
- What is your total organic fluorine threshold? Is it 50 ppm, 100 ppm, or zero intentional addition?
- Can you provide third-party test results from an EPA-certified or ISO-accredited laboratory confirming PFAS levels in finished garments?
- Do you use any cleaning agents, lubricants, or equipment that may contain PFAS and could cross-contaminate products during manufacturing?
- Are you compliant with California AB652 or other state-level PFAS restrictions that may affect market access?
- What is your timeline for eliminating all PFAS, including PTFE and other fluoropolymers, from all products?
- Will you publish your test results or certifications publicly so that consumers and retailers can verify compliance?
For brands seeking guidance on PFAS-free sourcing, the plastic-free activewear guide provides a framework for evaluating natural fiber alternatives.
OHZEHN-TEX™ materials are designed to meet the demand for synthetic-free performance fabrics, though this audit focuses solely on Lululemon's public claims and the available evidence.
What happens next
The Texas investigation is ongoing. According to The Conversation, "Lululemon has denied the claims. It says it phased out PFAS in 2023 and that these chemicals had only ever been used in a small number of water-repellent items. No wrongdoing has been found."
If the investigation produces test data, that data may resolve the gap between claim and verification. Until then, consumers and sourcing professionals looking for PFAS-free clothing are left with corporate statements unsupported by published independent test results.
Sources
https://www.texasattorneygeneral.gov/news/releases/attorney-general-ken-paxton-launches-investigation-lululemon-over-potential-presence-toxic-forever https://pfas.pillsburylaw.com/texas-ag-investigate-pfas-lululemon/ https://www.lawbc.com/texas-ag-investigates-lululemon-for-potential-presence-of-pfas-in-activewear/ https://www.esgdive.com/news/texas-ag-probes-lululemon-over-alleged-use-of-pfas-in-activewear/817720/ https://mamavation.com/brands/toxic-pfas-forever-chemicals-in-my-lululemon-activewear-pants.html https://www.ehn.org/pfas-clothing https://www.nrdc.org/press-releases/new-pfas-scorecard-popular-apparel-brands-levi-strauss-earns-outdoor-brands-fail https://www.asyousow.org/resolutions/2025/12/24-lululemon-reduce-plastic-microfiber-shedding https://www.iccr.org/resolutions/reduce-microfiber-pollution/ https://www.raymondjames.com/villages-branch/commentary-and-insights/2025/01/22/prepare-for-proxy-voting-season https://topclassactions.com/lawsuit-settlements/lawsuit-news/lululemon-class-action-claims-greenwashing-ads-lie-about-sustainability/ https://www.afslaw.com/perspectives/the-fine-print/going-green-lessons-lululemons-defense-greenwashing-class-action https://natlawreview.com/article/greenwashing-lawsuit-against-lululemon-dismissed-federal-court https://theconversation.com/a-probe-into-forever-chemicals-in-activewear-lays-bare-fashions-greenwashing-problem-281146 https://ohzehn-tex.com/plastic-free-activewear/