January 1, 2026 was the effective date for a number of state law provisions relating to intentionally added PFAS in certain categories of products.  July 1, 2026 will be the effective date for several more.  As we have discussed in this blog, many states have restrictions that went into effect before 2026, and several have enacted statutes, and in some cases have promulgated regulations, with restrictions that will not go into effect until 2027 or later.  Here is a brief overview of newly effective state law provisions as of January 1, 2026, followed by a summary of those that are set to go into effect on July 1, 2026:

Newly effective, as of January 1, 2026:

  • Colorado’s sales ban on products with intentionally added PFAS in the following categories: most cleaning products; cookware; dental floss; menstruation products; and ski wax.
  • Maine’s sales ban on products with intentionally added PFAS in the following categories: cleaning products; cookware products; cosmetic products; dental floss; juvenile products; menstruation products; textile articles (but not including outdoor apparel for severe wet conditions or textile articles that are component parts of a watercraft, aircraft or motor vehicle); ski wax; upholstered furniture; and products in the above listed categories that do not contain intentionally added PFAS but are sold, offered for sale, or distributed for sale in a fluorinated container or in a container that otherwise contains intentionally added PFAS.
  • Vermont’s sales ban on products with intentionally added PFAS in the following categories: cosmetics and menstrual products; food packaging; aftermarket stain and water-resistant treatments; artificial turf; dental floss; incontinency protection products; juvenile products; residential rugs and carpets; ski wax; and a sales ban on textiles or textile articles (but not including textile articles that are component parts of a watercraft, aircraft or motor vehicle) to which “regulated PFAS” have been intentionally added – for purposes of the definition of “regulated PFAS,” Vermont has set a threshold at or above 100 parts per million of total organic fluorine, which is due to decrease as of July 1, 2027 to 50 parts per million..
  • Washington state’s sales ban on leather and textile furniture and furnishings intended for indoor use with intentionally added PFAS.
  • Washington state’s trigger date for upcoming reporting requirements; that is, any products with intentionally added PFAS that are sold or distributed in Washington from January 1, 2026 forward are subject to the state’s reporting requirement for products in the following categories:  apparel intended for extreme and extended use; footwear made from leather, natural textiles, synthetic textiles, or technical textiles; gear for recreation and travel made from leather, natural textiles, synthetic textiles, or technical textiles; automotive waxes; cookware and kitchen supplies; firefighting personal protective equipment; floor waxes and polishes; hard surface sealers; and ski waxes.
    • First annual reporting deadline is January 31, 2027 (to include any covered products that were on sale as of January 1, 2026)

July 1, 2026 effective date:

  • Connecticut’s labeling and notification requirements, with conditional sales ban
    • Beginning July 1, 2026, Connecticut’s law allows the manufacturing, selling, offering or distributing for sale of apparel, carpets or rugs, cleaning products, cookware, cosmetic products, dental floss, fabric treatments, juvenile products, menstruation products, textile furnishings, ski wax, or upholstered furniture if they contain intentionally added PFAS only if the manufacturer labels the products in accordance with the statute and implementing regulations.
    • Moreover, beginning July 1, 2026, manufacturers must provide prior notification to the Connecticut Department of Energy and Environmental Protection for such covered products containing intentionally added PFAS that are manufactured, sold, or offered or distributed for sale in the state 
    • Note that Connecticut’s labeling and notification requirements are transitional in nature.  On January 1, 2028, the labeling and notification requirements will yield to an unconditional ban on the manufacture, sale, offering for sale or distributing for sale in Connecticut any of the following products containing intentionally added PFAS: apparel; turnout gear; carpets or rugs; cleaning products; cookware; cosmetic products; dental floss; fabric treatments; juvenile products; menstruation products; textile furnishings; ski wax; upholstered furniture; or outdoor apparel for severe wet conditions.
  • Minnesota’s reporting requirement, which applies to all products with intentionally added PFAS that are sold, offered for sale, or distributed for sale in the state.  The requirement extends to intentionally added PFAS in components of products; the regulatory definition of “component” includes packaging that is integral to or inseparable from the product’s containment, dispensing, or preservation. The state’s electronic reporting system, known as PRISM (PFAS Reporting and Information System for Manufacturers), opened to all manufacturers on January 30, 2026 for the initial July 1, 2026 reporting due date.
    • Any requests for waivers from the reporting requirement are due at least 30 days before the reporting due date (that is, no later than June 1, 2026).  Similarly, any requests for extension of the reporting due date are also due at least 30 days before the reporting due date (that is, no later than June 1, 2026). 

As Colorado, Maine, Vermont, Washington, Connecticut and Minnesota begin their full implementation of the above requirements in 2026, keep in mind that different exclusions or exemptions may apply (now or in the future) in these states. As of the date of this post, for example, Minnesota is still working on draft regulations to implement its Currently Unavoidable Use exemption, and is hosting a webinar on February 26, 2026 to update the public on its progress. 

Stay tuned for more updates.