PFAS PASS Investigation Series
In 2024, I designed, sourced and fabricated a large-scale costume system for a major entertainment production in California. The show was successfully deployed that year.
In 2025, after California’s PFAS textile regulations went into effect in January, that same costume system was redeployed in California.
I was not contacted to audit, verify or reassess the materials used in the original build against the new regulatory framework.
This is not an isolated case.
Between 2022 and 2023, I designed and developed a large-scale costume systems for another major production, totaling:
- Hundreds of costumes
- Hundreds of footwear units
- Internationally sourced materials and components
Those systems were also redeployed in California in 2025.
Again:
- No material-level re-verification was conducted on my end
- No request was made for sourcing documentation review
- No audit was initiated with the original designer and fabric sourcing authority
The Core Issue
These productions were built under a pre-regulation system.
They are now being reused in a post-regulation environment.
There is currently no standard industry process requiring:
- Re-verification of materials at the point of redeployment
- Supplier compliance confirmation
- Documentation of PFAS status at the garment level
This creates a structural gap:
Costume systems designed before regulation are being operated after regulation without a built-in compliance layer.
What This Means in Practice
From a material standpoint, many entertainment costume systems include:
- Synthetic fabrics, fur and foam
- Fused interlinings
- Synthetic footwear
- Velcro and plastic zippers
- Coated textiles
- Performance finishes (water resistance, stain resistance, durability treatments)
These are known HIGH RISK categories for PFAS presence.
Without:
- Verified supplier documentation
- Material testing
- Or a formal audit process
There is no way to:
- Confirm compliance
- Or confidently state material status
The Transparency Gap
Over the past several weeks, I have contacted multiple suppliers and industry contacts to request:
- PFAS compliance documentation
- Material disclosures
- Verification of claims
In EVERY single case:
- No documentation was provided
- No definitive answers were given
- Or responses were ignored, incomplete or unclear
This includes:
- Domestic suppliers
- International suppliers
- Fabric and component sources
At this time, there is no consistent, verifiable SUPPLY CHAIN standard being presented to designers or builders.
Why This Matters
This is not about a single show.
This is about:
- A production system that was never designed to track chemical compliance
- Being asked to operate under new regulatory conditions
- Without the infrastructure to support that shift
The Reality
Designers and builders are being held to a standard that:
- Did not exist when these systems were created
- Is not yet supported by the supply chain
- And is not clearly operationalized at the production level
The Missing Layer
What does not exist (yet) is a bridge system between:
- Design and fabrication
- Material sourcing
- Regulatory compliance
That is the gap.
The Path Forward
Until the supply chain becomes fully verifiable, the only viable path is:
- Structured material traceability
- Risk classification based on known material categories
- Supplier representation documentation
- Client-level risk acknowledgment and sign-off
- Clear decision frameworks for reuse, replacement, or removal
This is the foundation of the PFAS PASS Audit System™ and the PFAS PASS Design & Build System™ currently in development.
Closing
This is not a callout.
This is a documentation of what is actually happening on the ground:
- Legacy costume systems are being reused in regulated markets
- Without material re-verification
- Without consistent supplier transparency
- And without a standardized compliance process
That is not a failure of individual companies.
It is a failure of infrastructure.
And it is now visible.
This report is part of the PFAS PASS Investigation Series, an ongoing documentation effort examining real-world supplier responses, material transparency, and compliance readiness within the textile and garment industry.
PFAS compliance in textiles is not being clearly communicated at the point of sale. That changes through documentation.
This series will continue.