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  • Case Study 17 – The Tea on TEA – What the Themed Entertainment Association Doesn’t Know About PFAS — And Why It Can’t Afford Not To

    Case Study 17 – The Tea on TEA – What the Themed Entertainment Association Doesn’t Know About PFAS — And Why It Can’t Afford Not To

    CASE STUDY 17

    The Themed Entertainment Industry’s Invisible PFAS Crisis

    Published by PFAS PASS Compliance Systems | PFASPASS.com

    OVERVIEW

    The Themed Entertainment Association (TEA) — headquartered at 303 N. Glenoaks Blvd, Suite 200, Burbank, California — represents 1,500+ members worldwide engaged in the visitor attractions industry: theme parks, museums, casinos, corporate visitor centers, heritage centers, retail, hospitality, resorts and more. Its membership roster reads as a who’s-who of large-scale entertainment production: Universal Creative, Walt Disney Imagineering, Weta Workshop, and Huitt-Zollars among them. TeaconnectLinkedIn

    A search of TEA’s own website for “PFAS” returns zero results.

    This is not a minor gap. It is a systemic compliance blind spot with active legal, occupational health, and ethical dimensions — operating in plain sight, in a state that has already passed some of the strictest PFAS textile legislation in the country.

    THE REGULATORY REALITY TEA’S MEMBERS ARE ALREADY SUBJECT TO

    California is not waiting. California AB-1817 prohibits, beginning January 1, 2025, any person from manufacturing, distributing, selling, or offering for sale in the state any new textile articles that contain regulated PFAS. The statute’s definition of “textile articles” is expansive and directly applicable to the themed entertainment industry. The law explicitly names costumes, dancewear, sports uniforms, and everyday uniforms for workwear as covered categories — the exact garment types that define character costume departments, performer wardrobe, and park staff uniforms at every major theme park operation in California and beyond. CACA

    The compliance thresholds are already tightening: as of January 1, 2025, the threshold is set at or above 100 parts per million total organic fluorine within the product or product components, with that limit dropping to 50 ppm by January 1, 2027. And documentation is not optional: manufacturers are required to provide distributors or sellers in the state with certificates of compliance stating that the textile articles do not contain any regulated PFAS. Morgan LewisMorgan Lewis

    Enforcement authority is expanding in parallel. California’s AB 347 gave the Department of Toxic Substances Control (DTSC) the authority to enforce some of California’s existing PFAS laws, with DTSC enforcement beginning July 1, 2030, including minimum penalties of $10,000 for the first violation. BCLPIntertek

    THE THEMED ENTERTAINMENT PFAS EXPOSURE MAP

    Theme parks are, at their operational core, large-scale textile and costume manufacturing and deployment environments. When examined through a PFAS compliance lens, the exposure pathways are both numerous and largely undocumented:

    Character Costumes & Performer Suits — Full-body character suits worn in outdoor park environments are routinely treated for moisture, stain, and soil resistance. Workers wearing these suits for multiple hours per shift experience sustained dermal contact with potentially PFAS-treated fabrics — a documented occupational exposure pathway. California law now explicitly covers these garments, yet no industry-wide audit or guidance has been issued.

    Park Staff & Operational Uniforms — At parks the scale of Disneyland, Universal Studios Hollywood, or Knott’s Berry Farm, uniforms are procured and distributed at industrial scale. Everyday uniforms for workwear are explicitly named in AB-1817. Do these parks currently hold certificates of compliance from their uniform manufacturers? Has TEA asked that question of its member operators? CA

    Scenic Fabrication & Upholstery — Ride seat upholstery, queue furniture, and soft scenic elements are treated for durability and weather resistance. These are high-traffic guest contact surfaces with no current industry standard for PFAS content disclosure.

    Food & Beverage Packaging — Beginning January 1, 2023, the State of California prohibited the distribution and sale of food packaging containing regulated PFAS chemicals, including food and beverage containers, take-out food containers, wrappers, utensils, straws, and disposable tableware. Theme park food operations — operating at enormous volume — were subject to this law over two years ago. Has compliance been audited? Coastkeeper

    The Guest-Facing Dimension — Children interact directly with character performers wearing potentially PFAS-treated costumes. This is not a theoretical concern; it is a documented, unexamined public exposure pathway in an industry that brands itself on family safety and trust.

    THE CALIFORNIA NEXUS AND THE CROSS-STATE PROBLEM

    TEA is incorporated and headquartered in California — a state that has established a PFAS Action Plan that outlines strategies for monitoring, remediation, and public outreach, and has intensified its efforts to limit PFAS exposure, adding several PFAS chemicals to its Proposition 65 list, requiring businesses to provide warnings about significant exposures. Partner Engineering and Science

    This creates an ethical and legal question that TEA has not yet publicly addressed: if its California-based member parks are subject to AB-1817 textile compliance requirements — including certificates of compliance for costumes and uniforms — what guidance has TEA provided to those members? And critically, what guidance has it provided to member parks operating in other states, where the same supply chains and the same PFAS-treated textiles are deployed, even without the same legal mandate?

    The costumes shipped from a California fabrication house to an Orlando theme park do not shed their PFAS content at the state line. The occupational exposure experienced by a character performer in Anaheim is the same exposure experienced by a performer in Orlando, Singapore, or Paris. The regulatory trigger may currently be geographic, but the health liability is universal.

    This is the ethical gap. TEA has the convening power, the member trust, and the industry reach to lead on this. Currently, it is not.

    THE OSHA DIMENSION

    PFAS exposure in occupational settings is an emerging OSHA-level concern. Workers in costume departments, scenic fabrication shops, and wardrobe facilities handle PFAS-treated materials regularly, often without hazard disclosure. The themed entertainment industry employs thousands of such workers. Under General Duty Clause obligations, employers are required to provide workplaces free from recognized hazards — and PFAS in occupational textile settings is now a recognized hazard class. The absence of any TEA guidance on this is not a neutral position. It is a documented gap in duty of care to member organizations and their employees.

    THE THREE PILLARS OF PFAS PASS COMPLIANCE SYSTEMS

    PFAS PASS Compliance Systems, developed and authored by Gina Wilson and available in full at PFASPASS.com, offers the themed entertainment industry a structured, actionable compliance pathway built on three foundational pillars:

    PILLAR ONE: PFAS PASS LIBRARY Eleven standalone, version-controlled compliance documents (Docs 1–11), freely accessible, covering PFAS identification, supply chain documentation, certificate of compliance frameworks, occupational exposure mapping, and litigation reference standards. Doc 11 serves as the Litigation Reference document — directly applicable to industries now facing regulatory and legal exposure. The Library translates complex regulatory language into operational guidance usable by costume departments, procurement teams, and facilities managers without requiring legal expertise.

    PILLAR TWO: PFAS PASS COMPLIANCE SYSTEMS A Proof-of-Concept production standard — now emerging as the industry model for PFAS-compliant textile and costume manufacturing. This systems architecture addresses the full supply chain lifecycle: from raw material sourcing through fabrication, procurement documentation, certificate of compliance verification, worker safety protocols, and ongoing audit readiness. It is designed to be implementable by large-scale operators, production houses, and industry associations as an adoptable standard — not a one-time audit but a living compliance infrastructure.

    PILLAR THREE: PFAS PASS VERIFIED The verification and credentialing layer. PFAS PASS VERIFIED provides the evidentiary documentation framework that member organizations need to demonstrate compliance to regulators, insurers, and the public. In an era where DTSC enforcement is expanding and Proposition 65 exposure warnings attach to PFAS-containing products, PFAS PASS VERIFIED gives organizations a defensible, documented compliance record — and gives associations like TEA a standard they can recommend, endorse, and build programming around.

    CONCLUSION

    The Themed Entertainment Association arrives in Orlando for Theme Park Central with zero published guidance on PFAS — in costumes, uniforms, fabrication materials, food packaging, or worker safety. This is not a criticism. It is an opportunity.

    The regulatory clock in California is already running. The ethical obligation to member workers and guests does not wait for enforcement timelines. And the industry’s reputation for safety, imagination, and trust demands that it lead on this issue rather than react to it.

    PFAS PASS Compliance Systems is ready to help TEA lead.

    If you have any suggestions on what we should cover next, comment below.

  • Case Study 16: The Industry Platform Blind Spot — MAGIC (SOURCING by Informa) and the Complete Absence of PFAS Compliance in Fashion’s Most Influential Trade Ecosystem

    Case Study 16: The Industry Platform Blind Spot — MAGIC (SOURCING by Informa) and the Complete Absence of PFAS Compliance in Fashion’s Most Influential Trade Ecosystem

    PFAS PASS Investigation Series

    The Organization

    MAGIC — formally operating as SOURCING by Informa under the Fashion by Informa / MMGNET Group umbrella — is the most recognized and attended fashion trade show ecosystem in the United States.

    Produced by Informa PLC, one of the world’s largest events and publishing companies, MAGIC and its co-located shows draw tens of thousands of industry professionals to the Las Vegas Convention Center biannually, and operate additional marquee events at the Jacob K. Javits Convention Center in New York City.

    The scale is not incidental to this case study. It is central to it.

    MAGIC connects:

    • Global manufacturers and fabric suppliers
    • Trim, component, and notions vendors
    • Apparel brands and private label buyers
    • Sourcing executives and production managers
    • Fashion technology and compliance solution providers
    • Designers, retailers, and merchandising teams

    By their own figures: 36,000+ attendees. 3,500+ exhibitors. 26+ countries represented.

    This is not a niche platform. This is the infrastructure of the U.S. fashion supply chain — assembled twice a year in one place.

    The Regulatory Position of This Organization

    This is where the facts become impossible to ignore.

    MAGIC’s organizer is headquartered in Santa Monica, California. California is a regulated state. As of January 1, 2025, California prohibits the manufacture, distribution, or sale of any textile article containing intentionally added PFAS or total organic fluorine exceeding 100 ppm. By January 1, 2027, that threshold drops to 50 ppm. Manufacturers are required by law to provide certificates of compliance to sellers and distributors.

    MAGIC stages events at the Jacob K. Javits Convention Center in New York City. New York is a regulated state. As of January 1, 2025, New York prohibits the sale of any apparel containing PFAS as intentionally added chemicals. By January 1, 2028, the ban extends to outdoor apparel for severe wet conditions. Compliance certification requirements apply to anyone selling or offering apparel for sale in the state.

    To be precise:

    • The organization that runs MAGIC is based in a regulated state
    • The trade show floor where MAGIC physically operates in New York is located in a regulated state
    • The brands, buyers, and sourcing teams attending MAGIC are selling into regulated states
    • The suppliers exhibiting at MAGIC are supplying into regulated states

    Every party in this ecosystem is inside the regulatory perimeter.

    None of them are being informed of it by the platform that convenes them.

    The Investigation

    A full audit of the publicly accessible content on sourcingatmagic.com was conducted — including the Resources section, the Editorial library, and all published Fashion Technology Foundations reports — to determine whether PFAS compliance is addressed anywhere within their content infrastructure.

    The result is unambiguous:

    The word “PFAS” does not appear anywhere in the publicly accessible content on sourcingatmagic.com.

    Not once.

    Not in the Regulations, Compliance & Disclosure report. Not in the Sustainability report. Not in the 2025 Fashion Sustainability Report. Not in the editorial archive covering sourcing strategy, supply chain resilience, sustainability policy, or business planning. Not in trend forecasting. Not in country and region guides. Not anywhere.

    What Was Found

    SOURCING by Informa has invested significantly in compliance-adjacent content. Their Fashion Technology Foundations: Regulations, Compliance & Disclosure guide explicitly addresses:

    • EU Digital Product Passport requirements
    • U.S. traceability regulations
    • Supply chain disclosure frameworks
    • Cross-border compliance preparation

    Their Fashion Technology Foundations: Sustainability report addresses:

    • Environmental impact of the textile industry
    • Legislative regulation of supply chains
    • Greenwashing and unsubstantiated sustainability claims
    • Design-to-impact and circularity frameworks

    Their 2025 Fashion Sustainability Report addresses shifting policy agendas, innovation momentum, and consumer demand.

    All of this is exactly the context in which PFAS compliance belongs.

    None of it mentions PFAS.

    The organization is publishing compliance content. It is publishing sustainability content. It is publishing regulatory content. And it is doing so with a blind spot so complete that the most actively enforced chemical regulation in U.S. textile history does not appear in a single sentence.

    The Gap in Numbers

    This is not abstract. The regulatory calendar is set.

    • January 1, 2025 — California and New York PFAS apparel restrictions in force
    • January 1, 2027 — California threshold tightens from 100 ppm to 50 ppm total organic fluorine
    • January 1, 2028 — New York ban extends to outdoor apparel for severe wet conditions
    • Ongoing — EU REACH restriction proposal covering all PFAS under active consideration

    Violations of California’s regulations carry civil penalties of up to $10,000 per violation per day.

    The exhibitors on the MAGIC trade floor are not being told this. The buyers writing orders at MAGIC are not being told this. The sourcing teams building supply chains through MAGIC are not being told this.

    The Pattern

    This follows the identical structure documented across every prior PFAS PASS case study:

    1. An industry-leading organization operates in direct proximity to the compliance gap
    2. Regulatory and sustainability content is produced — but stops short of chemical transparency
    3. PFAS is not named, mapped, or addressed as a compliance category
    4. The audience continues operating without the framework they are legally required to have
    5. Liability remains with the designer, brand, buyer, or production team downstream

    What makes this case study different from prior investigations is the scale.

    A single supplier failing to provide PFAS documentation affects the brands sourcing from them. A single trade show failing to address PFAS affects an entire industry — tens of thousands of professionals, across thousands of supply chain relationships, across dozens of countries — all operating under the assumption that if it mattered, someone would have said something.

    Someone should have said something.

    No one has.

    Why This Matters Beyond MAGIC

    MAGIC is not uniquely negligent. That is precisely the point.

    The fashion industry’s most influential platforms — its trade shows, content networks, education systems, and sourcing infrastructure — have collectively failed to integrate PFAS as a compliance category. When the industry’s premier sourcing platform does not address a regulatory requirement, it signals to tens of thousands of professionals that the topic is either not yet relevant or not yet actionable.

    Both conclusions are wrong.

    The regulations are active. The enforcement mechanisms are in place. The penalties are real. And the supply chain that runs through MAGIC’s trade floor has no current mechanism — offered by the platform, by exhibitors, or by buyers — to verify PFAS compliance at the material, component, or finished product level.

    This is not a gap at the edges of the industry. It is a gap at the center of it.

    From Investigation to Infrastructure

    PFAS PASS was not built to document the problem alone. It was built to solve it.

    Pillar 1 — PFAS Compliance Playbook Series

    The Playbook Series translates regulatory pressure into practical execution:

    • Fabric, footwear, and component-level breakdowns
    • Construction system risk identification
    • Real-world sourcing and decision frameworks
    • Step-by-step compliance evaluation guidance

    For every sourcing professional leaving a MAGIC trade floor with a new supplier relationship and zero PFAS documentation: this is where to start.

    This is where the industry moves from confusion → to clarity.

    Pillar 2 — PFAS PASS Compliance Systems™

    Our Compliance Systems establish a structured approach to:

    • Full-system garment review
    • Component-level risk mapping
    • Construction pathway analysis
    • Pre-production compliance decision making

    For the brands, manufacturers, and sourcing teams building or rebuilding supply chains through MAGIC’s exhibitor network: this shifts the industry from assumption-based sourcing to system-based compliance strategy.

    Pillar 3 — PFAS PASS Verification System™

    The missing layer in the current market is verification.

    PFAS PASS provides:

    • Controlled document submission pathways
    • Review of supplier-provided lab documentation
    • Structured verification criteria
    • Buyer-facing transparency through the PFAS PASS VERIFIED framework

    For every buyer writing orders at MAGIC into California and New York markets: this creates a traceable, defensible compliance position where none currently exists.

    Closing Position

    MAGIC convenes the fashion supply chain at scale — twice a year, in Las Vegas and New York, in two of the most aggressively regulated states in the country.

    Its organizer is headquartered in California. Its New York events are staged inside New York. Its attendees are selling into both.

    The regulations are not coming. They are here.

    And the platform that has the greatest reach, the greatest influence, and the greatest responsibility to inform this industry has not said the word “PFAS” once.

    That is not a content gap. That is a system-wide failure — documented, dated, and on the record.

    PFAS PASS exists to bridge that gap. Not through claims. But through systems, documentation, and verification pathways.

    PFAS PASS Investigation Series | Case Study 16 pfaspass.com

    If you have a suggestion on what we should cover next, comment below.

  • Case Study 03: Knix Was Required to Remove “PFAS-Free” Claims, Then Confirmed Sales Into NY and CA Without PFAS-Verified Products

    Case Study 03: Knix Was Required to Remove “PFAS-Free” Claims, Then Confirmed Sales Into NY and CA Without PFAS-Verified Products

    PFAS PASS — Compliance Watch / Case Study Series

    This case study documents a direct inquiry into PFAS compliance with Knix, a major brand in the leakproof underwear category. The exchange establishes a clear record of what the company claims, what it confirms and what it does not provide in relation to PFAS compliance in regulated markets.

    Knix previously marketed its products using terms such as “PFAS-free,” “toxic chemical-free” and “fluorine-free.” These claims became the subject of a federal class action lawsuit, Spencer v. Knix Wear Inc., which resulted in a $1.4 million settlement. As part of that settlement, Knix agreed to remove those claims from its marketing.

    In current communications, Knix uses revised language including:

    • “PFAS are not intentionally added”
    • “Not detected at testing limits”
    • References to internal testing programs and sample disclosures

    These statements are materially different from the claims they were required to remove.

    Initial Response: Limited Disclosure Framework

    In its initial reply, Knix outlined a three-part approach to PFAS:

    • Design: PFAS are “not intentionally added”
    • Monitor: Testing conducted on fabrics and finished products
    • Share: Sample test results published on their blog

    They cited detection limits ranging from 0.01 to 1 parts per million and positioned this as transparency.

    No full lab reports, compliance thresholds or product-level verification were provided.

    Regulatory Inquiry: Direct Compliance Questions

    A follow-up inquiry focused specifically on regulatory compliance in active PFAS jurisdictions, asking:

    • Whether Knix is selling into New York and California
    • What standards are used to evaluate compliance
    • Whether product-level documentation exists sufficient for regulatory review

    Knix provided the following confirmed responses:

    • They have customers in New York and California
    • They evaluate their testing program against:
      • California AB 1817
      • California AB 2515
      • New York S.1548 / A.1502
      • New York S.1322
    • Their testing includes:
      • Targeted PFAS analysis
      • Total Organic Fluorine (TOF) screening
    • They maintain product-level documentation
    • Testing occurs at both material/input level and finished garment level

    Verification Status: Not Publicly Demonstrated

    Despite confirming sales into regulated markets and referencing applicable laws, Knix does not publicly provide:

    • PFAS Verified product status
    • Product-level compliance documentation
    • Full, unredacted third-party lab reports
    • Defined compliance thresholds aligned to cited laws
    • Pass/fail criteria for PFAS or TOF testing
    • Independent third-party compliance certification

    Knix states that documentation exists but does not make that documentation available for external verification.

    Compliance Position

    Based on documented responses:

    • Knix confirms active sales into regulated PFAS markets
    • Knix confirms internal testing and documentation systems
    • Knix references applicable regulatory frameworks

    However:

    • PFAS compliance is not publicly verified at the product level
    • Compliance thresholds and validation criteria are not disclosed
    • Verification remains internal rather than externally demonstrable

    Why This Matters

    New York and California have active PFAS restrictions governing textiles and related product categories.

    In regulated markets, compliance is not defined by general claims or partial disclosures. It is defined by documentation that can be substantiated against regulatory standards.

    Knix asserts that such documentation exists. It is not publicly available or independently verifiable.

    Conclusion

    Knix was required to remove “PFAS-free” and similar claims following a federal class action settlement. In subsequent communications, the company relies on revised language and internal testing descriptions.

    At the same time, Knix confirms it continues to sell products into regulated markets including New York and California and maintains internal compliance documentation.

    However, Knix does not publicly provide PFAS Verified product status or verifiable compliance documentation.

    This case highlights a broader issue within the apparel industry: the distinction between internal compliance claims and externally verified compliance.

    When products are sold into regulated markets, compliance is not defined by what is stated. It is defined by what can be verified.

    Series Note

    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 PASS\xe2\x84\xa2
    Founder, PFAS PASS

    PFAS compliance in textiles is not being clearly communicated at the point of sale. That changes through documentation.

    If you have supplier responses, share them, comment below.
    If you want a supplier investigated, name them, comment below.

    This series will continue.