PFAS in Consumer Products: New Year = New Limits on Intentionally Added PFAS  

As the new year begins, consumer product manufacturers are facing a fresh wave of PFAS regulations, including new bans, reporting obligations, and labeling requirements. In this post, I’ll outline the key restrictions taking effect in 2026 and preview additional rules slated for 2027.  

2026 RESTRICTIONS ON PFAS IN CONSUMER PRODUCTS 

Beginning January 1, 2026, five states—Colorado, Connecticut, Maine, Vermont, and Washington—will enforce new restrictions on PFAS in consumer products. While all four states share a common goal of limiting intentionally added PFAS, the scope and stringency of their bans differ significantly. Below is an overview of what manufacturers and retailers selling in these states need to know to ensure compliance. 

Colorado 
As enacted in Senate Bill 24-081, a person may not sell, offer for sale, distribute for sale, or distribute for use in Colorado any products containing intentionally added PFAS as of January 1, 2026, in the following categories:   

• Cleaning products, except floor maintenance products used in hospital or medical settings 
• Cookware  
• Dental floss  
• Menstruation products  
• Ski wax  
• Textiles 

Artificial turf containing intentionally added PFAS may not be installed on any portion of a property in the state, starting January 1, 2026. However, existing artificial turf may continue to be maintained. 

Connecticut 
Beginning January 1, 2026, Connecticut law allows the distribution, sale, or offering for sale of new outdoor apparel for severe wet conditions that contain PFAS only if the product and any online listing for it is accompanied by a legible and easily discernible disclosure stating: “Made with PFAS chemicals.” 

Additionally, anyone manufacturing or selling turnout gear must provide written notice to the purchaser at the time of sale that indicates the turnout gear includes intentionally added PFAS and the reason PFAS has been added. 

Maine 
As codified in 38 M.R.S. §1614: Consumer Products Affecting the Environment, effective January 1, 2026, the following products with intentionally added PFAS are prohibited from sale or distribution in Maine: 

• Cleaning products, subject to defined category descriptions and potential exemptions 
• Cookware  
• Cosmetics  
• Juvenile products 
• Menstruation products  
• Most textile articles, not including outdoor apparel for severe wet conditions or components of vehicles, aircraft, or watercraft 
• Ski wax  
• Upholstered furniture 

Refer to Maine’s PFAS in Products page for more information about the product categories in which intentionally added PFAS have been banned. 

Vermont 
Enacted in 2024, Vermont S.25 prohibits the manufacture, sale, or distribution of cosmetics and menstrual products containing intentionally added PFAS beginning January 1, 2026. For other consumer products, such as textiles and apparel, the definition of regulated PFAS also includes any PFAS present at or above 100 parts per million (PPM), as measured in total organic fluorine, as of January 1, 2026. 

A ban on intentionally added PFAS in cookware, juvenile products, cleaning products, dental floss, and fluorinated containers was also slated to take effect on January 1, 2026, but H.238, passed in 2025, extended the timeline for certain categories of products to give manufacturers more time to identify and develop suitable alternatives. These categories include: 

• Cleaning products: effective July 1, 2027. 
• Dental floss: effective July 1, 2027. 
• Cookware: effective July 1, 2028. 
• Fluorine treated containers (for otherwise PFAS‑free listed products): effective July 1, 2027. 
• All fluorine-treated containers: effective January 1, 2032. 

Washington 
Companies offering certain PFAS‑containing consumer products in Washington State must start tracking those items as of January 1, 2026, to comply with the Safer Products Restrictions and Reporting requirements. Reporting obligations apply to products containing intentionally added PFAS in several product categories, such as extreme or extended‑use apparel, footwear, outdoor and travel gear, automotive waxes, cookware and related kitchen products, firefighting PPE, floor waxes and polishes, hard surface sealers, and ski waxes. Initial reports are due January 31, 2027. 

It’s important to remember that this rule includes a compliance trigger of 50 ppm total fluorine. Any listed product above this level is treated as if it contains intentionally added PFAS. While there is no explicit requirement to proactively test every product for total fluorine, proactive testing can help manufacturers verify their status, respond to inquiries, and reduce the risk of unexpected compliance or supply‑chain disruptions. 

MID-YEAR PFAS RESTRICTIONS AND REQUIREMENTS 

 Legislatures tend to favor January 1 as the starting date for PFAS bans, but as usual, a couple of restrictions will also take effect mid-year. This year’s mid-year restrictions focus on labeling and reporting. 

Connecticut 
As of July 1, 2026, product labeling requirements in Connecticut expand to cover several additional product categories, including:  

• Apparel 
• Carpets and rugs 
• Cleaning products 
• Cookware 
• Cosmetics 
• Dental floss 
• Fabric treatments 
• Children’s products 
• Menstruation products 
• Textile furnishings 
• Ski wax 
• Upholstered furniture 

Manufacturers of these products must also give prior notification to the Connecticut Department of Energy and Environmental (DEEP).  

Minnesota 
July 1, 2026, is the initial reporting deadline for products sold or distributed in Minnesota that contain intentionally added PFAS. Manufacturers must report specified product and chemical information to the Minnesota Pollution Control Agency. 

LOOKING AHEAD TO 2027 

 Next year looks to be equally eventful, with several state bans on intentionally added PFAS set to begin. 

New Hampshire  
Effective January 1, 2027, New Hampshire’s HB 1649-FN bans the manufacture and sale of products with intentionally added PFAS in eight categories: 

• Carpets and rugs 
• Cosmetics 
• Textile treatments 
• Feminine hygiene products 
• Food packaging and containers 
• Juvenile products 
• Upholstered furniture 
• Textiles 

This legislation has a couple of provisions that go beyond those frequently included in state bans on intentionally added PFAS. Products with at least 85% recycled content are excluded. Upon request, manufacturers must also supply certificates of compliance (CoC) to the New Hampshire Department of Environmental Services (DES). While the legislation itself does not explicitly require the inclusion of test results, it implies that manufacturers might need to substantiate compliance claims with relevant data, which can include test results. 

To learn more about testing PFAS in consumer products watch: Quantifying PFAS in Consumer and Related Products. 

New Mexico  
New Mexico’s PFAS Protection Act prohibits intentionally added PFAS starting on January 1, 2027, in:  

• Cookware 
• Food packaging 
• Dental floss 
• Juvenile products 
• Firefighting foam  

Uniquely, the New Mexico law exempts fluoropolymers, such as PTFE, used in non-stick coatings, distinguishing it from stricter regulations in other states.  

Manufacturers must also report information about products containing PFAS to the New Mexico Environmental Department (NMED) by January 1, 2027. This information includes product description, purpose of PFAS in the product, and amount of each PFAS compound. Although testing is not explicitly mandated in the law, NMED has the authority to require testing to ensure compliance. 

New York  
On or after December 31, 2026, no carpet sold or offered for sale in New York may contain or be treated with PFAS for any purpose, with handmade rugs, area rugs, and mats excluded. 

While intentionally added PFAS in apparel were banned after January 1, 2025, the same law requires the New York State Department of Environmental Conservation (DEC) to set a threshold level for PFAS, intentionally added or not, in new apparel by January 1, 2027. 

As currently proposed, NY S187 would add a ban on PFAS, starting January 1, 2027, in several additional product categories: 

• Textiles 
• Rugs 
• Fabric treatments 
• Cookware 
• Ski waxes 
• Architectural paints 
• Cleaning products 
• Dental floss 

If this bill is enacted, New York will join Vermont and California as one of only three states to define “regulated PFAS” as PFAS that are intentionally added or present at or above a threshold value measured as total organic fluorine. The New York Department of Environmental Conservation is required to set this value at the lowest feasible level and review it at least every five years. 

Like other states, New York’s law would require manufacturers to provide retailers with a signed certificate of compliance and make it a violation to knowingly sell noncompliant products. Product testing is not required, but DEC can demand independent test results and stop sales of the product if the agency believes there is a violation of the law.  

Vermont  
As mentioned earlier, Vermont H 238 extended the timeline for the ban on intentionally added PFAS in several product categories. As of July 1, 2027, intentionally added PFAS are prohibited in three additional product categories: 

• Dental floss 
• Cleaning products 
• Fluorinated containers used for consumer products 

Additionally, the threshold for regulated PFAS (measured as total organic fluorine) drops from 100 ppm to 50 ppm on July 1, 2027. 

Washington 
Starting January 1, 2027, the amended Chapter 173-337 WAC Safer Products Rule makes it unlawful for manufacturers, distributors, and retailers to intentionally add PFAS to apparel and accessories, automotive washes, and cleaning products sold in Washington, including those sold online into the state. As described above products with more than 50 ppm total fluorine are presumed to contain intentionally added PFAS unless the manufacturer can prove otherwise.  

In addition, by January 31, 2027, manufacturers of specified PFAS‑containing products—such as apparel intended for extreme or extended use, footwear, recreation and travel gear, automotive waxes, cookware and kitchen supplies, firefighting PPE, floor waxes and polishes, hard surface sealers, and ski waxes—must submit PFAS reporting to the Department of Ecology and continue doing so every year by January 31 thereafter. 

NAVIGATE 2026 WITH CONFIDENCE 

 As we move into 2026, the PFAS regulatory landscape will, no doubt, continue to shift. New state proposals, as well as federal legislation, are on the horizon, and existing legislation is always subject to amendment as legislatures reconvene and respond to constituent feedback. As always, we will continue to monitor these developments and provide updates as the year progresses. If you have questions about how analyzing PFAS in your products can help you comply with new restrictions and rules, reach out to us—we’re here to help. 

Additional Resources: 

On-Demand Webinar: Quantifying PFAS in Consumer Products