ARTICLE
27 February 2026

Precision Matters: What The Olympic "PFAS Ban" Gets Right — And Wrong

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Bergeson & Campbell

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Bergeson & Campbell, P.C. is a Washington D.C. law firm focusing on chemical product approval and regulation, product defense, and associated business issues. The Acta Group, B&C's scientific and regulatory consulting affiliate provides strategic, comprehensive support for global chemical registration, regulation, and sustained compliance. Together, we help companies that make and use chemicals commercialize their products, maintain compliance, and gain competitive advantage as they market their products globally.
Recent headlines have declared that the Olympics have "banned PFAS," with athletes reportedly disqualified after testing revealed the presence of so-called "forever chemicals" on their equipment.
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Recent headlines have declared that the Olympics have "banned PFAS," with athletes reportedly disqualified after testing revealed the presence of so-called "forever chemicals" on their equipment. The reality is more nuanced, and that nuance matters.

The policy at issue does not originate with the International Olympic Committee (IOC), but with the International Ski Federation (FIS), which governs ski and snowboard competitions under its International Competition Rules (ICR). FIS has prohibited the use of fluorinated ski wax and tuning products in competition. Enforcement relies on testing for the presence of fluorine on the base of skis. That distinction — fluorinated wax versus "PFAS" — is not semantic nitpicking. It is the core issue.

PFAS (per- and polyfluoroalkyl substances) are a class of organofluoride compounds characterized by specific carbon-fluorine bonding structures. There are even debates regarding what chemical compounds constitute PFAS chemicals. The European Union classifies over 13,000 chemicals as PFAS, using the Organisation for Economic Co-operation and Development (OECD) definition, while the United States has no single definition for PFAS. Federal agencies embrace various definitions and while most states use the OECD definition, a few others use their own definition. Canada recently issued a reporting requirement listing 312 PFAS substances. There has long been a debate regarding the bio persistence of a PFAS based on the number of fluorinated carbon atoms it may possess. PFOS and PFOA are eight-chain fluorinated hydrocarbons, thought to be more toxic and persistent than two- or four-chain fluorinated carbon atoms. By contrast, total organic fluorine (TOF) testing detects the presence of the element fluorine itself. It does not identify a particular molecule, distinguish among types of fluorinated substances, or confirm whether a substance meets any given statutory or regulatory definition of PFAS. In other words, the Olympic testing regime screens for fluorine as a proxy indicator. It does not test for specific PFAS compounds.

From a competition standpoint, this may be entirely defensible. Fluorinated waxes historically provided measurable glide advantages and contributed to localized environmental contamination at race venues. Screening for fluorine is rapid, field-deployable, and enforceable. Arguably, most importantly, the rules do not state that there is a PFAS ban, but that there is a fluorine ban, meaning that any athlete found with high enough levels of fluorine present on competition equipment will be banned. This construct is far more expansive than simply banning "PFAS" waxes.

But when media coverage translates a fluorine detection into "PFAS use," the regulatory story shifts. Precision matters, especially in a policy space as charged as PFAS.

An obvious question arises: if the concern is PFAS, why focus on ski wax while permitting fluorinated coatings in winter jackets, gloves, or boots? The answer likely lies in function and exposure. Fluorinated ski wax is:

  • Applied directly to the base of skis;
  • Heated and scraped during preparation;
  • In direct and repeated contact with snow and runoff; and
  • Used to enhance competitive performance.

Outerwear coatings, by contrast, are not applied at race venues, do not alter competitive glide, and do not generate the same localized release during competition. States that have implemented PFAS regulations or bans have been quick to target ski wax for similar reasons.

Targeting wax is therefore a pragmatic decision tied to competitive fairness and environmental release at sporting events. It is not a comprehensive PFAS elimination policy.

Yet public framing often suggests otherwise. PFAS regulation globally is increasingly grappling with definitional scope. U.S. state reporting laws, federal Toxic Substances Control Act actions, and the European Union's proposed universal PFAS restriction all reflect ongoing debates about whether PFAS should be regulated molecule-by-molecule or as a broad chemical class.

When high-profile institutions use imprecise language — or when coverage conflates fluorine detection with confirmed PFAS presence — it reinforces a broader narrative that "fluorinated" equals "PFAS" equals "forever chemical."

For companies navigating complex PFAS compliance landscapes, that conflation carries reputational risk. A brand associated with a fluorinated ski wax disqualification may find itself publicly linked to "PFAS contamination," even though the enforcement mechanism did not identify a specific regulated PFAS compound. This is not an argument against the fluorinated wax ban. It is an argument for accuracy in describing it.

The FIS testing protocol reportedly relies on field-based fluorine detection technologies (e.g., spectroscopic methods) to determine whether skis exceed established fluorine thresholds. Such tools are efficient and suitable for sport governance, where rapid determinations are essential. But screening is not speciation. In regulatory contexts, decisions based on proxy indicators raise familiar questions:

  • What threshold triggers a violation?
  • How were those thresholds validated?
  • What is the false positive rate?
  • Is confirmatory laboratory testing available?
  • What due process protections exist for athletes and sponsors?

These are not criticisms unique to sports. They mirror broader policy debates about regulating PFAS by TOF, total fluorine, or structural definition. The Olympic wax ban may, in this sense, offer a preview of where PFAS governance is heading: enforceable, class-based, and sometimes an instrument of blunt force.

The most important takeaway is not whether fluorinated ski wax should be permitted. It is that language and analytical precision matter.

As PFAS regulation accelerates worldwide, institutions, public and private, will continue to face pressure to act quickly and visibly. Screening tools will be favored over molecule-specific analysis. Class-based prohibitions will gain traction over substance-by-substance risk assessments.

Those approaches may sometimes be justified. But clarity about what is being regulated – fluorinated materials, specific PFAS compounds, TOF, or something else – is essential to maintaining credibility.

The Olympic fluorinated wax ban illustrates both the appeal and the pitfalls of broad chemical narratives. If the goal is sound environmental and chemical governance, precision should not be sacrificed for headlines.

In PFAS policy, details are not a distraction. They are the point.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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