43% of companies cannot describe the full chemical composition of their products. 

That number comes from our own research, and it points to a specific type of compliance failure. Not a failure in monitoring or regulatory tracking, but one that shows up when a regulatory development lands, and a team realizes it cannot answer the most basic question: do we have this substance in our products or processes?  

The EPA’s expanding PFAS reporting requirements under TSCA Section 8(a)(7) caught many teams in exactly that position. 

The visibility problem

Not knowing what chemicals you’re working with creates a specific problem: it makes applicability impossible to do properly. 

For compliance teams, applicability is the operational discipline of asking: what applies to us? It’s how teams avoid treating every regulatory development as equally urgent. Done well, it helps teams focus on what requires attention. Done on incomplete information, it creates a false sense of coverage. 

In chemical compliance, that information starts with your chemicals. Mapping them means building a reliable picture of what substances are present in your products and processes, including what enters through the supply chain. Not just what’s been declared, but what’s actually there. 

Finished product testing sometimes reveals what supplier declarations don’t. For an apparel company we worked with, PFAS showed up in a finished product test even though none of their suppliers had declared it. It came from somewhere in the supply chain. It just hadn’t been mapped. 

A regulation changes, a restriction list gets reviewed, a supplier declaration gets checked, and the applicability check gets made. It looks complete. But if the picture of what’s really present was incomplete before that process started, the assessment has a gap in it — and obligations that should have triggered a review don’t.

PFAS is a case in point

Regulatory activity around PFAS illustrates the problem clearly. There are more than 1,200 initiatives globally, including restrictions, disclosure requirements, and phase-out timelines. These are across multiple jurisdictions, use different definitions, and cover different substances and uses on different timelines. 

Deadlines that compliance might once have managed sequentially are now arriving in the same window, affecting organizations in different ways depending on where they operate and what they make. 

None of that tells you which ones apply to you. That question can only be answered by knowing what PFAS compounds are present in your products and processes, at what concentrations, and where in your formulations or supply chain they’re coming from. It depends entirely on how well you’ve mapped your chemicals. 

For companies without that picture, those 1,200 initiatives are effectively unfiltered. The regulatory tracking exists. The chemical knowledge to apply it against doesn’t. 

This isn't a new problem. It's an urgent one.

Regrettable substitutions are one consequence. When a company phases out a restricted substance, selects a replacement only to later find that alternative restricted too, it’s usually because the replacement was never fully evaluated. It’s a symptom of a deeper strategic risk: not knowing the full chemical picture of products and processes. 

The legal and supply chain dimensions of incomplete chemical visibility are not new. Previous discussions around chemical transparency in supply chains and the growing challenge of chemical disclosures have pointed to the same conclusion: chemical visibility is a strategic requirement, not just a compliance exercise. 

What’s newer is the regulatory pressure making the cost of not knowing far harder to absorb. The next generation of disclosure requirements isn’t coming for what companies have declared. It’s coming for what’s actually there. For organizations that haven’t mapped their chemicals, that creates a different kind of exposure – and a narrowing window to get ahead of it. 

You cannot manage what you cannot see. And you cannot determine what applies if you don’t know what you have.