As 2024 is now closed and we head into the new year, here is a summary of updates and important reminders related to PFAS in North America.
State Requirements Now Effective
As of January 1, 2025, the following state PFAS laws are now in effect including inventory:
- California Apparel and Textile Articles Law (AB1817) – in scope products and their components sold or distributed cannot have intentionally added PFAS or be under the 100 ppm Total Organic Fluorine limit. DTSC was recently named as enforcement body but has until 2027 and 2029 to provide certain information and guidance.
- Colorado PFAS in products – Cosmetics, indoor upholstered furniture and indoor textile furnishings cannot be sold with intentionally added PFAS
- Labeling of outdoor apparel for severe wet weather conditions starts for products sold in California and Colorado.
- New York State Apparel – wearing apparel (outdoor wear and general use) sold or distributed cannot contain intentionally added PFAS.
- Minnesota PFAS in Products (Amara’s Law) – Various products including carpets and rugs, juvenile products, cookware, cosmetics, and others cannot be sold or distributed with intentionally added PFAS. For additional guidance, definitions and FAQ: https://www.pca.state.mn.us/air-water-land-climate/2025-pfas-prohibitions
- Washington State Safer Products Cycle 1 – Aftermarket fabric treatments and carpets and rugs containing intentionally added PFAS cannot be sold or distributed. Reporting of leather and textile furnishings and upholstered furniture for outdoor use sold in 2024 is required by January 31, 2025.
State Rulemaking Efforts
Several states have been involved with draft rulemaking activities.
- Minnesota – Working on rulemaking for 2026 reporting requirements. In draft and comment period closed on Dec 19, 2024. https://www.pca.state.mn.us/getengaged/pfas-in-products-reporting-and-fees
Maine – Working on draft rulemaking for currently unavoidable use (CUU)
determinations. Draft is out for public comment until January 28, 2025
https://www.maine.gov/dep/spills/topics/pfas/PFAS-products/cuu.html
https://www.maine.gov/dep/rules/index.html#13139124- Washington State – Working on draft rulemaking associated with Cycle 1.5, PFAS, restrictions and reporting assessments including effective dates and scope guidance. Products such as cleaning products, apparel, gear, cookware and kitchen utensils, waxes and polishes, and hard surface sealants. Comments have been collected and are being assessed for the final rulemaking due out in December 2025.
https://ecology.wa.gov/regulations-permits/laws-rules-rulemaking/rulemaking/wac-173337-nov2023
Reporting Reminders
- US EPA PFAS Reporting under Toxic Substances Control Act (TSCA) – Reporting on any imported goods containing PFAS sold between 2011-2022 is still in place. Reminder that the reporting start date has been moved to July 11, 2025. Manufacturers have 6 months from this date to report with exceptions for small businesses.
https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/tsca-section-8a7-reporting-and-recordkeeping - Canada PFAS Reporting Rule – Manufacturers and importers have until January 29, 2025 to report certain product types that contain PFAS which were sold in 2023. Product scope, dates and data to report can be found in this link for their Guidance Manual
https://www.canada.ca/en/environment-climate-change/services/evaluating-existingsubstances/pfas-s71-guidance-manual.html
For more information, see links to previous bulletins:
- California AB1817: https://www.cps.bureauveritas.com/newsroom/california-signs-pfas-textilearticles-bill-ab-1817
- Colorado PFAS in Products: https://www.cps.bureauveritas.com/newsroom/colorado-governorsigns-pfas-bill-law
- NY PFAS in Apparel as amended: https://www.cps.bureauveritas.com/newsroom/amendmentnew-yorks-law-prohibiting-pfas-apparel-and-outdoor-apparel-severe-wet-conditions
- Minnesota PFAS in Products ban: https://www.cps.bureauveritas.com/newsroom/minnesotasigns-pfas-bill-law
- Washington Safer Products, Cycle 1 Assessment:
https://www.cps.bureauveritas.com/newsroom/washington-state-finalizes-cycle-one-saferproducts-restrictions-and-reporting - Washington Safer Products, Cycle 1.5 Assessment:
https://www.cps.bureauveritas.com/newsroom/washington-state-pfas-priority-products-law - PFAS Testing for US and EU Consumer Products: https://www.cps.bureauveritas.com/needs/pfas-testingfor-us-and-eu-consumer-products
How Does this Impact You? Contact Us to Discuss
If you have any questions, please contact your customer service representative or email: info@us.bureauveritas.com
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