In April 2022, NRDC, Fashion FWD, and US PIRG Education Fund released the first industry scorecard grading apparel brands on their PFAS commitments. The grades for outdoor brands were not subtle. Columbia Sportswear received an F. REI received an F. The North Face received a D.
Four years later, those same brands now market PFAS-free outdoor gear. The question a brand founder should ask: did these companies lead, or did regulation force their hand?
What did the NRDC PFAS scorecard actually measure?
The NRDC PFAS scorecard graded brands on four criteria: timeline for PFAS phaseout, range of products covered by the policy, public availability of PFAS commitments, and labeling and testing protocols.
The majority of brands surveyed earned a D or lower. Only one brand earned an A+: Levi Strauss. Patagonia, the highest-scoring outdoor brand, earned a B. The reasoning: Patagonia was the only outdoor brand with a commitment to phase out all PFAS in all products by 2024.
Columbia and REI failed because their commitments were incomplete. They had not committed to phase out PFAS across all products. They had not published testing protocols. They had not set public deadlines.
What REI and Columbia said at the time
REI's initial response to the F grade was to expand its commitment. The company announced it would ban PFAS in all textiles by 2024 and all remaining products by 2026. Toxic-Free Future noted that REI's updated commitment would improve its score on the next scorecard.
Columbia Sportswear faced more sustained pressure. NRDC and US PIRG Education Fund launched a petition campaign that collected more than 48,000 signatures demanding the company remove PFAS from its supply chain by 2024. At Columbia's 2022 Annual Meeting of Shareholders, CEO Tim Boyle said the company had "been focused on reducing our use of PFAS and ultimately phasing them out." But Columbia did not set a public deadline.
What Columbia's product pages say now
Columbia now states it has removed all intentionally added PFAS from all products as of January 31, 2026. The company's Omni-Tech technology page promotes waterproof, breathable fabrics. The new Omni-Tech Eco fabric, which uses recycled coffee grounds, is marketed as both sustainable and PFAS-free.
Good On You, an independent sustainability rating platform, still rates Columbia's environmental performance as "Not Good Enough." The reasons: Columbia uses few lower-impact materials, has not set a target to manage water use in its supply chain, has not committed to eliminating all hazardous chemicals in manufacturing, and does not report results from its clothing recycling program.
The gap is instructive. Eliminating intentionally added PFAS is not the same as eliminating all hazardous chemicals. A brand can be PFAS-free and still use chemicals of concern in dyeing, finishing, or processing.
What Patagonia did differently
Patagonia reached 100% PFAS-free products in Spring 2025, ahead of most state deadlines. The company had already achieved 98% by 2023. Patagonia publishes its materials science work, including technical explanations of how it reformulated DWR finishes without sacrificing performance.
The difference is transparency. Patagonia made its PFAS phaseout timeline public years before regulations required it. The company's product pages list fiber content and treatment details. When Patagonia says a garment is made without PFAS, it means the membrane, the DWR finish, and the entire supply chain have been audited.
Columbia's language is more careful. "Removed all intentionally added PFAS" leaves open the possibility of contamination through processing aids, supply chain cross-contact, or components from subcontractors. Without published test reports, a brand founder has no way to verify the claim.
What the Gore-Tex lawsuit reveals about supply chain complexity
In February 2025, three law firms filed a class action lawsuit against W.L. Gore & Associates, the maker of Gore-Tex fabric. The lawsuit alleges Gore marketed its products as "non-toxic," "environmentally sound," and "committed to sustainability" while continuing to manufacture waterproof gear using PFAS.
Gore released PFAS-free jackets in 2021. But according to the lawsuit, the company failed to disclose which of its other products still contained PFAS. A consumer buying a Gore-Tex jacket had no way to know whether it was part of the PFAS-free line or the legacy line.
Testing by Toxic-Free Future found mixed results across North Face products. Some jackets tested below the screening level for fluorine. Others, like the North Face Alta Vista, have a PFAS-free DWR finish but a membrane that still contains PFAS.
This is the complexity a brand founder inherits when sourcing outdoor fabrics. A supplier may claim PFAS-free, but the claim may refer only to the finish, not the membrane. Or only to intentionally added chemicals, not contaminants.
What changed: regulation, not leadership
The timeline tells the story. California banned PFAS in textile products effective January 2025. New York followed with its own restrictions. Maine, Vermont, and Connecticut enacted bans or reporting requirements. France and Denmark did the same in Europe.
NRDC testing of 115 products purchased in California and New York in 2025 found that major outdoor brands reduced PFAS levels by 97 to 99.99 percent after state regulations took effect. The report, titled "No PFAS No Problem," confirmed that regulatory pressure, not voluntary commitment, drove the reformulation.
California and New York account for a massive share of the outdoor gear market. Any brand that wanted to sell in those states had to reformulate. The F-grade brands did not lead. They responded to a market condition.
Patagonia and Levi Strauss, by contrast, began phaseouts before regulations required it. Their scorecard grades reflected commitments already in progress, not promises made under pressure.
What a PFAS-free claim actually requires
A credible PFAS-free claim requires third-party testing, not just supplier attestation. Bluesign recommends total organic fluorine testing, which measures all fluorinated compounds in a sample. This catches PFAS that may not be on a supplier's restricted substances list.
Testing costs $150 to $500 per sample through labs like SGS, Intertek, or Bureau Veritas. A brand founder sourcing PFAS-free fabric should ask the supplier for:
- Total organic fluorine test results, not just an attestation of "no intentionally added PFAS"
- Test reports covering both the membrane and the DWR finish
- Chain of custody documentation showing which mill and finishing house handled the fabric
- A commitment to annual re-testing, since supply chain changes can reintroduce contamination
The ChemFORWARD SAFER program goes further, using third-party toxicology firms to verify that alternatives are actually safer, not just PFAS-free. A paraffin wax finish might be PFAS-free but still pose environmental concerns.
What the disclosure floor looks like
Connecticut's PFAS disclosure requirements for outdoor apparel took effect January 2026. Washington's reporting requirements launched the same month, with initial reports due July 2026. Minnesota's PRISM system requires manufacturers to report PFAS content in textiles.
These disclosure rules do not require PFAS elimination. They require transparency. A brand selling in these states must be able to document what chemicals are in its products and where they came from.
For a brand founder, this means supply chain traceability is no longer optional. If your supplier cannot tell you what finishing chemistry they used, you cannot file an accurate disclosure report. And filing an inaccurate report creates regulatory exposure.
What a brand founder should ask before sourcing
If you are building a PFAS-free clothing line, here are the questions to put to your fabric supplier:
- Do you have total organic fluorine test results for this fabric, not just an attestation?
- Does the test cover both the membrane and the DWR finish?
- Which lab performed the test, and can I see the certificate?
- What finishing chemistry do you use as an alternative to PFAS?
- Has that alternative been evaluated for toxicity, or just for the absence of PFAS?
- How do you prevent cross-contamination from other orders processed on the same lines?
- Will you commit to annual re-testing?
A supplier that cannot answer these questions may be making a marketing claim, not a technical one.
"The majority of America's favorite apparel brands surveyed earned a D or lower for weak PFAS commitments.", NRDC, Fashion FWD, US PIRG Education Fund, April 2022
Where this leaves the category
The outdoor apparel industry is in transition. Brands that received F grades four years ago now claim PFAS-free status. But the transition was driven by regulation, not leadership. And the claims vary in their rigor.
Patagonia publishes test reports and technical documentation. Levi Strauss earned the only A+ by committing early and across all product categories. Columbia and REI responded to public pressure and regulatory deadlines.
For a brand founder entering this market, the lesson is clear. A PFAS-free claim is only as strong as the documentation behind it. If you want to compete with brands that have real test reports, you need your own. If you are sourcing from OHZEHN-TEX(TM) or any other supplier, ask for the lab results before you print the hang tag.
The regulatory floor is rising. The disclosure requirements are expanding. The brands that will survive are the ones that can prove their claims, not just state them.
For a deeper look at how the plastic-free activewear category is evolving, see the plastic-free activewear guide.
Sources
https://www.nrdc.org/press-releases/new-pfas-scorecard-popular-apparel-brands-levi-strauss-earns-outdoor-brands-fail https://www.rei.com/ https://www.thenorthface.com/ https://toxicfreefuture.org/press-room/rei-announces-it-will-ban-pfas-in-all-textiles/ https://www.nrdc.org/bio/sujatha-bergen/petitioners-demand-columbia-sportswear-remove-pfas https://www.columbia.com/c/technology-omnitech/ https://www.columbia.com/t/responsibility/ https://directory.goodonyou.eco/brand/columbia https://www.patagonia.com/our-footprint/pfas.html https://www.patagonia.com/stories/culture/design/a-strong-finish/story-133800.html https://www.hbsslaw.com/cases/pfas-gore-tex-greenwashing https://toxicfreefuture.org/research/pfas-in-stain-water-resistant-products-study/results/ https://www.nrdc.org/press-releases/forever-chemicals-levels-drop-after-state-laws-phase-out-pfas-textiles https://www.bluesign.com/pfas-in-clothing https://www.levistrauss.com/sustainability/planet/chemicals/ https://ohzehn-tex.com/plastic-free-activewear/