SG 021/25
Several states in the United States (US) have introduced bills to regulate PFAS in a range of consumer products. The scope of products and their requirements are dependent on the jurisdiction.
Per- and polyfluoroalkyl substances (PFAS), which include perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), are a diverse group of synthetic chemicals that have been widely used in industry and consumer goods for many years. Their properties and functions to repel water, grease, oil and/or dirt enable them to be used in the manufacture of a wide range of everyday consumer goods, including after treatments, apparel, carpets and rugs, cosmetics, firefighting foam, food contact materials and articles, non-stick cookware, ski wax and upholstered furniture.
Over the years, PFAS have increasingly been regulated due to their toxic effects and negative impacts on the environment. In the US, a host of jurisdictions across the nation have implemented measures to regulate PFAS chemicals in consumer goods. These include, but are not limited to, California, Colorado, Connecticut, Hawaii, Indiana, Maine, Maryland, Massachusetts, Minnesota, New Hampshire, New York, San Francisco, Santa Rosa, Rhode Island, Vermont and Washington. Moreover, the scope of regulated products and their requirements for PFAS are jurisdiction dependent.
Since the beginning of 2025, several bills have been introduced at the state level to restrict/prohibit PFAS in a range of products. Highlights of these bills are summarized in Table 1.
| Jurisdiction (Bill) | Scope | Unless otherwise stated, requirement for PFAS | Proposed effective date |
| Connecticut (HB 887) |
| Exempts polymer-coated cookware authorized by the Food and Drug Administration (FDA) from statutory requirements | - |
| Connecticut (HB 5914) |
| Prohibited | - |
| Hawaii (HB 644 / SB 1020) |
| Prohibited for businesses where food or beverages are packaged and sold on the premises if either: 1) intentionally added for a functional or technical effect, or 2) ≥ 100 ppm as total organic fluorine (TOF) | January 1, 2026 |
| Hawaii (SB 683) |
| Prohibited if intentionally added | January 1, 2028 |
| Illinois (HB 1295) |
| Reporting required with potential fees if product contains intentionally added PFAS | On or before January 1, 2027 |
| Prohibited if intentionally added | January 1, 2026 (additional products may be identified and prohibited no earlier than January 1, 2026, but no later than January 1, 2033) | |
| Prohibited if intentionally added, unless determined by rule that the use of PFAS is currently unavoidable | January 1, 2033 | |
| Illinois (SB 117) |
| Prohibited if intentionally added | January 1, 2026 |
| Illinois (SB 167) |
| Prohibited if intentionally added | January 1, 2026 |
| Kentucky (HB 102) |
| Reporting required if product contains intentionally added PFAS | January 1, 2026, and every January 1 thereafter |
| Minnesota (HF 303) |
| Warning label requirement replacing current prohibition | Day after enactment |
| Montana (HB 290) |
| Prohibited if intentionally added | January 1, 2028 |
| Prohibited if intentionally added unless a notice with the state fire marshal has been filed | January 1, 2028 | |
| New Hampshire (HB 167) |
| Prohibited if intentionally added | January 1, 2027 |
| New Jersey (A 5195) |
| Manufacturer to provide notice to purchaser that FPPE contains PFAS | Six months after effective date of the public law (P.L.) |
| Prohibited if intentionally added | Two years after effective date of the P.L. | ||
| New York (S 187) |
| Prohibited if either: 1) intentionally added, or 2) at or greater than a TOF level to be established by regulation | January 1, 2027 |
| New York (A 1430) |
| Prohibited if intentionally added | December 31, 2026 |
| New York (S 1464) |
| Prohibited if intentionally added2 | Three years after promulgation of rules and regulations under this law |
| Prohibited at a level to be established by regulation2 | Five years after promulgation of rules and regulations under this law | |
| Rhode Island (HB 5019) |
| Prohibited if intentionally added | January 1, 2027 |
| ¹Designed for single use for or alongside prepared foods 2Prohibition also includes ortho-phthalates, bisphenols, heavy metals and compounds, including lead, hexavalent chromium, cadmium, and mercury (excluding copper phthalocyanine), benzophenone and its derivatives, halogenated flame retardants, perchlorate, formaldehyde, toluene, antimony and compounds, UV 328 (2-(2H-benzotriazol-2-yl)-4,6-di-tert-pentylphenol), polyvinyl chloride (including polyvinylidene chloride), polystyrene (excluding EPS (expanded polystyrene)) or polycarbonate | |||
Table 1
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