Recent federal action has eased the immediate pressure of the U.S. Environmental Protection Agency’s one-time PFAS reporting obligation under the Toxic Substances Control Act (TSCA). In a May 2025 interim final rule, EPA extended the reporting submission window, pushing the first compliance deadline into 2026. At the same time, a fast-moving patchwork of state “market access” requirements (many already effective as of January 1, 2025, and January 1, 2026) is driving real-time product stewardship decisions for manufacturers, importers, brands, retailers, and distributors. These regulations range from product prohibitions to establishing labeling, notification, and reporting requirements. For companies selling products into multiple states, noncompliance is no longer just a reporting risk but can mean loss of market access, supply-chain disruption, and potential enforcement exposure.

Key Takeaways

• EPA extended the TSCA PFAS Reporting Rule submission window; it now opens April 13, 2026, and closes October 13, 2026 (with an alternate deadline of April 13, 2027, for certain small manufacturers reporting exclusively as article importers).
• Despite this extension, state restrictions and disclosure obligations are already shaping product formulation, sourcing, contracting, labeling, and documentation across a widening range of regulated product categories. While many early compliance efforts have focused on textiles and furnishings, newer laws and pending proposals also target product lines common in industrial and commercial supply chains, including coatings and architectural paints, cleaning and floor maintenance products (including certain automotive products), cookware and food-contact surfaces, cosmetics and personal care, carpets and other floor coverings, and certain PPE and performance-treated goods.
• Companies selling into California, Minnesota, and Colorado have been operating under new PFAS-related prohibitions since January 1, 2025.
• Additional prohibitions and compliance obligations take effect January 1, 2026 (notably in Vermont and Maine) and throughout 2026 in several jurisdictions (including Connecticut’s labeling/notification program and Washington’s reporting requirements under its Safer Products rules).
• Minnesota’s “Amara’s Law” also includes a statewide reporting obligation for intentionally added PFAS in products sold in Minnesota, regardless of product category. The Minnesota Pollution Control Agency has extended the reporting due date to July 1, 2026, making supply-chain data collection and internal product mapping an immediate priority for many manufacturers and distributors.

Federal Update: TSCA PFAS Reporting Rule Deadlines Extended

The EPA finalized the TSCA PFAS Reporting Rule in October 2023, creating a one-time reporting obligation for entities that manufactured or imported PFAS in any year from 2011 through 2022.

In May 2025, EPA issued an interim final rule extending the submission period. The reporting window now begins April 13, 2026, and ends October 13, 2026, for most manufacturers, with small manufacturers reporting exclusively as article importers receiving an alternate end date of April 13, 2027.

The EPA has also signaled that it may pursue additional changes to the TSCA reporting framework. The EPA’s TSCA PFAS reporting page describes a November 2025 proposal that would reduce reporting in certain circumstances (including potential exemptions tied to low concentrations, imported articles, and other categories). However, state product requirements will continue to operate independently and on faster timelines, regardless of if the final federal approach changes.

Not all state PFAS obligations are tied to a single product category. Several states are increasingly relying on cross-cutting tools (such as product reporting platforms, manufacturer-to-retailer notifications, and labeling/certification mechanisms) that can apply to products moving through industrial and commercial distribution channels, including private-label and component-containing goods.

Why State Laws Are Driving Compliance Right Now

For many companies, PFAS obligations are now less about a single federal reporting event and more about managing continuous “market access” across multiple states. The state frameworks typically turn on some combination of (1) prohibitions on sale/distribution of products containing “intentionally added” PFAS (or PFAS above certain screening thresholds), and (2) documentation, labeling, and/or reporting requirements that can extend through the supply chain. The following tables are non-exhaustive but provide a sense for how disparate the state approaches can be.

Selected state product-category restrictions effective in 2025

Textiles and furnishings are a leading focus in the early wave of state restrictions, but the overall trend is toward broader “covered product” lists that capture a wide range of manufactured goods and distribution models.

State	Product Categories Covered	Substantive Requirements	Effective Dates
California	Textile articles (broadly defined; includes many consumer and commercial textile goods)	Beginning January 1, 2025, California prohibits manufacturing, selling, or offering for sale most new textile articles that contain “regulated PFAS,” a definition that includes intentionally added PFAS and PFAS present at or above specified total organic fluorine thresholds (100 ppm starting January 1, 2025; 50 ppm starting January 1, 2027). The law also requires manufacturers to provide a certificate of compliance to downstream sellers and distributors, and it imposes a disclosure requirement for “outdoor apparel for severe wet conditions” beginning January 1, 2025.	Jan. 1, 2025 (100 ppm) Jan. 1, 2027 (50 ppm)
Minnesota	Eleven product categories: carpets or rugs; cleaning products; cookware; cosmetics; dental floss; fabric treatments; juvenile products; menstruation products; textile furnishings; ski wax; upholstered furniture (and certain packaging associated with these products)	Minnesota’s "Amara’s Law" prohibits the sale or distribution of products in the listed categories if they contain intentionally added PFAS beginning January 1, 2025 (with certain packaging also covered). The statute also includes a broader future prohibition beginning January 1, 2032 for any product containing intentionally added PFAS unless the use is designated "currently unavoidable."	Jan. 1, 2025 (11 categories) Jan. 1, 2032 (broader prohibition)
Colorado	Cosmetics; indoor textile furnishings; indoor upholstered furniture (with separate later effective dates for certain outdoor textile furnishings and outdoor upholstered furniture)	Colorado prohibits the sale or distribution of products in the listed categories if they contain intentionally added PFAS beginning January 1, 2025. The statute phases in additional category restrictions on later dates (including certain outdoor furnishing categories) and includes separate provisions affecting certain PFAS-related marketing/labeling for cookware.	Jan. 1, 2025 (indoor categories)
New Mexico	Juvenile products, cookware, food packaging, dental floss, firefighting foam, carpets, cleaning items, cosmetics, fabrics, textiles, feminine hygiene products, ski wax, and upholstered furniture	New Mexico’s PFAS Protection Act phases out consumer products containing intentionally added PFAS on a staged schedule. The first set of product bans begins January 1, 2027, followed by an expanded set of product bans beginning January 1, 2028. The Act also contemplates a broader future phaseout for most remaining non-exempt products unless a "currently unavoidable use" determination applies. The Act exempts certain fluoropolymers, specifically polymeric substances with specified fluorinated backbones that are solid at standard temperature and pressure. This carve-out is significant because fluoropolymers are widely used in textiles and performance materials, narrowing the practical scope of the ban compared to broader PFAS restrictions adopted in other states. Following enactment of the Act, New Mexico Legislature adopted HJM 3, requesting that the Department of Environment evaluate the public health, environmental, and economic risks of the Act’s exemptions, including the fluoropolymer exemption, and recommend whether those exemptions should be continued, modified, or removed.	Jan. 1, 2027 (cookware; food packaging; dental floss; juvenile products; firefighting foam) Jan. 1, 2028 (carpets or rugs; cleaning products; cosmetics; fabric treatments; feminine hygiene products; textiles; textile furnishings; ski wax; upholstered furniture)

 

Selected state product-category restrictions effective in 2026 (and other 2026 milestones)

State	Product Categories Covered	Substantive Requirements	Effective Dates
Vermont	Textile articles	Vermont prohibits ‘regulated PFAS’ in textile articles beginning January 1, 2026, using a total organic fluorine threshold approach that becomes more stringent in 2027.	Jan. 1, 2026 (threshold tightens in 2027)
Maine	Cleaning products, cookware, cosmetics, dental floss, juvenile products, feminine hygiene products, ski wax, upholstered furniture, and textile articles (with certain statutory exceptions)	Maine's PFAS statute prohibits the sale, offering for sale, or distribution of the listed product categories if they contain intentionally added PFAS beginning January 1, 2026, with additional categories scheduled on later dates.	Jan. 1, 2026
Connecticut	Apparel, carpets or rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children’s products, feminine hygiene products, ski wax, textile furnishings, and upholstered furniture	Beginning July 1, 2026, covered products containing intentionally added PFAS may not be manufactured, sold, or distributed in Connecticut unless the manufacturer provides prior notice to the state Department of Energy and Environmental Protection (DEEP) and labels the product using DEEP-approved words and symbols. Beginning January 1, 2028, Connecticut bans manufacturing, selling, or distributing covered products containing intentionally added PFAS.	July 1, 2026 (notice and labeling) Jan. 1, 2028 (prohibitions)
Washington	Apparel and accessories, footwear, recreational and travel gear, extreme/extended-use apparel, automotive washes, automotive waxes, air care products, general cleaning products, cookware and kitchen supplies, firefighting PPE, floor waxes and polishes, hard surface sealers, ski wax	Washington's Safer Products rules adopted amendments impose (i) restrictions for certain categories and (ii) reporting for additional categories. The rule took effect December 21, 2025; manufacturers must identify and track products with new reporting requirements beginning January 1, 2026; new restrictions take effect January 1, 2027; and reports are due January 31, 2027 and annually thereafter.	Reporting effective Jan. 1, 2026 Notifications beginning 2027

 

Additional state developments expanding the patchwork (2026–2027)

States continue to expand PFAS requirements by adding covered product categories and cross-cutting compliance tools, even where federal programs remain in flux. The following states are examples:

State	Developments
New Jersey	New Jersey’s S.1042 (“Protecting Against Forever Chemicals Act”), signed in January 2026, restricts intentionally added PFAS in select product categories on a delayed implementation schedule and adds cookware labeling requirements.
New York	New York also presents meaningful near-term dates for manufacturers and distributors. Under New York’s carpet extended producer responsibility framework, carpets sold or offered for sale in New York may not contain or be treated with PFAS substances on and after December 31, 2026. The New York Senate has also advanced S.9073A, which would define "covered products" to include architectural paint, cleaning products (including air care products, automotive products, general cleaning products, and polish floor maintenance products), cookware, fabric treatments, rugs, ski wax, and textile articles (including certain non-wearable textile goods, outdoor apparel, and PPE).
Illinois	Illinois expanded its PFAS Reduction Act through amendments that became effective August 15, 2025 (Public Act 104-0231). Beginning January 1, 2032, Illinois will prohibit the sale, offering for sale, or distribution of certain products including juvenile products (such as car seats, crib mattresses, strollers, pillows and similar items for children under 12) and intimate apparel (garments intended to be worn under clothes with direct skin contact, including sleepwear, socks, and similar items) if they contain intentionally added PFAS. Illinois defines “Intentionally added PFAS” as PFAS that are deliberately added during the manufacture of a product if the continued presence of the PFAS is desired in the final product or its components to perform a specific function.

 

With hundreds of PFAS bills introduced across the states each year, companies with multi-state footprints should anticipate continued expansion of both “market access” prohibitions and cross-cutting reporting, notice, and labeling programs.

A Phased Compliance Strategy for Companies Selling into These States

This overview is non-exhaustive but provides a sense for how disparate the state approaches can be. To address the wide range of product- and state-specific requirements, companies should consider adopting a phased plan that aligns legal requirements with product development, sourcing, and quality systems. A phased strategy may include (1) building a defensible product inventory and PFAS knowledge base, (2) prioritizing and addressing market access restrictions, and (3) integrating and prioritizing federal TSCA reporting, and state reporting data set, based on industry.

How We Can Help

We regularly assist companies with PFAS compliance strategies that span product stewardship, supply-chain contracting, disclosure, and reporting readiness across multiple jurisdictions. If you would like help triaging product categories by state, designing a phased compliance roadmap, or evaluating testing/certification approaches, please contact a member of Godfrey & Kahn’s Environmental team.

---

Technical Sidebar

We are also pleased to share a related technical sidebar authored by Nick Nigro, PFAS Product Manager at Pace^® Analytical Services, which provides practical insight into Total Organic Fluorine (TOF) testing, an analytical threshold referenced in California and other state PFAS restrictions. The sidebar explains common testing methodologies and the “sum-parameter” approach used to estimate organically bound fluorine in consumer products. Read the full technical sidebar.