Beyond PFAS Bans: Which U.S. States Require Product Reporting

This blog was originally posted on 30th June, 2026. Further regulatory developments may have occurred after publication. To keep up-to-date with the latest compliance news, sign up to our newsletter.

AUTHORED BY LUISA TORO CORREA, REGULATORY COMPLIANCE SPECIALIST, ADHERENT

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Key Insight

PFAS compliance is not only about bans, phase-outs, and labeling. For many companies, the first major challenge is product reporting: identifying intentionally added PFAS, collecting supplier data, and submitting required information to state agencies. This article focuses on enacted U.S. state PFAS requirements involving reporting, notification, registration, or chemical disclosure for consumer products.

Table of Contents

• Why PFAS Reporting Needs Its Own Focus
• Broad PFAS Product Reporting States
• Which States Require Category-Specific Notification or Registration?
• How Can Children’s Product Chemical Disclosure Laws Capture PFAS?
• Which States Fall Outside the Reporting-Only Scope?
• Final Thoughts: What Should Companies Do Next?
• Frequently Asked Questions

Why PFAS Reporting Needs Its Own Focus

PFAS regulation in the United States is often discussed in terms of bans, phase-outs, and labeling. However, for many companies, the first practical compliance challenge is reporting: determining whether products contain intentionally added PFAS, collecting supplier data, and submitting required information to state agencies.

PFAS rules can be complex, so this Blog focuses on enacted U.S. state requirements that involve reporting, notification, registration, or chemical disclosure for consumer products. It does not cover proposed bills, federal TSCA reporting, drinking-water rules, or state laws that focus solely on bans, labeling, testing, or certificates of compliance.

For more on PFAS, read our guide ‘Forever Chemicals, Finite Timelines: Managing PFAS Reporting and Compliance Across Borders‘.

Broad PFAS Product Reporting States

Minnesota

Minnesota’s Amara’s Law creates one of the broadest enacted PFAS product reporting programs in the United States. Manufacturers or groups of manufacturers of products sold, offered for sale, or distributed in Minnesota that contain intentionally added PFAS must submit product information to the Minnesota Pollution Control Agency. Initial reports are due by September 15, 2026, with later reports generally due by February 1 each year. Required information includes the product or product category, PFAS chemicals used, PFAS concentration, the function of PFAS in the product or component, manufacturer information, and authorized representative contact information.

Manufacturers must also maintain supporting records, making Minnesota an important driver for supplier outreach and internal PFAS data management. Companies that cannot meet the initial deadline may request a one-time 90-day extension, provided the request is submitted by the applicable deadline. 

New Mexico

New Mexico’s PFAS reporting framework is based on the PFAS Protection Act, House Bill 212, and the implementing rule, 20.13.2 NMAC, Toxic PFAS in Consumer Products. The rule establishes requirements for reporting, labeling, testing, fees, currently unavoidable use, and phased restrictions.

Manufacturers must submit reports to the New Mexico Environment Department for products or components containing intentionally added PFAS. Reports are due no later than January 1, 2027, and must be submitted in the prescribed format with verification that the data is accurate. New Mexico also requires supporting documentation and includes reporting fees and late fees.

Which States Require Category-Specific Notification or Registration?

Connecticut

Connecticut’s Senate Bill 292, enacted as Public Act 24-59, An Act Concerning the Use of PFAS in Certain Products, establishes prior notification requirements for certain products containing intentionally added PFAS.

Beginning July 1, 2026, manufacturers may not manufacture, sell, offer for sale, or distribute specified PFAS-containing products in Connecticut unless prior written notification is provided to the Department of Energy and Environmental Protection. Covered categories include apparel, carpets or rugs, cleaning products, cookware, cosmetics, dental floss, fabric treatments, children’s products, menstruation products, textile furnishings, ski wax, and upholstered furniture. The notification must include product descriptions, PFAS identity information, PFAS amounts or ranges, PFAS functions, and manufacturer contact information.

Washington

Washington has two relevant reporting pathways. The first is the Safer Products for Washington framework under Chapter 70A.350 RCW, Pollution from Toxic Chemicals in Consumer Products, implemented through Chapter 173-337 WAC, Safer Products Restrictions and Reporting. These rules require reporting for certain priority chemical-product combinations, including intentionally added PFAS in specified leather and textile furniture and furnishings.

The second pathway is Washington’s Children’s Safe Products Act, Chapter 70A.430 RCW, implemented through Chapter 173-334 WAC, Children’s Safe Products Reporting Rule. This program requires reporting on children’s products that contain listed Chemicals of High Concern to Children, including certain PFAS.

Maine

Maine has been included with a caveat. The relevant statute is 38 M.R.S. § 1614, Products containing PFAS, originally enacted through L.D. 1503, An Act To Stop Perfluoroalkyl and Polyfluoroalkyl Substances Pollution. The implementing rule is 06-096 C.M.R. ch. 90, Products Containing Perfluoroalkyl and Polyfluoroalkyl Substances.

Maine no longer operates as a broad “report every PFAS product” program. Current notification duties are narrower and are mainly tied to products containing intentionally added PFAS where the Department has determined that the use is a currently unavoidable use.

California

California also makes the list with a caveat. Assembly Bill 347, Chapter 932, Statutes of 2024, Household product safety: toxic substances: testing and enforcement, adds Chapter 3, commencing with Health and Safety Code § 108075.

AB 347 is not a broad PFAS content reporting law. However, it creates a registration and compliance-submission framework for covered products subject to California PFAS restrictions, including juvenile products, textile articles, and food packaging. By July 1, 2029, manufacturers of covered products must register with the California Department of Toxic Substances Control (DTSC), pay the applicable fee, and submit a statement of compliance. DTSC may also request technical documentation, including analytical test results.

How Can Children’s Product Chemical Disclosure Laws Capture PFAS?

Oregon, Vermont, and Washington are included because their children’s product chemical disclosure programs can capture certain PFAS when those substances appear on state chemical lists, even though these programs are not comprehensive PFAS-only reporting laws.

Oregon

Oregon’s Toxic-Free Kids Act requires manufacturers to report children’s products sold or offered for sale in Oregon that contain High Priority Chemicals of Concern for Children at or above reportable levels. Because Oregon’s list includes certain PFAS, children’s products containing those listed PFAS may trigger reporting. 

Vermont

Vermont’s Chemical Disclosure Program for Children’s Products requires manufacturers to report children’s products containing listed Chemicals of High Concern to Children. Vermont’s list includes certain PFAS, so children’s products containing those substances may be subject to disclosure reporting. 

Which States Fall Outside the Reporting-Only Scope?

Several states have enacted PFAS laws that are important but are not primarily product-reporting programs. For example, Colorado, New Hampshire, New Jersey, New York, Rhode Island, and Michigan may focus on product bans, labeling, consumer disclosure, certificates of compliance upon request, testing, firefighting foam, or food packaging restrictions. These states should still be monitored, but they should be treated separately from a reporting-only analysis.

Final Thoughts: What Should Companies Do Next?

The enacted state PFAS reporting landscape may be narrower than the broader PFAS regulatory landscape, but it should not be treated as a future concern. Reporting obligations are already creating immediate data challenges for companies that sell consumer products across the United States and are quickly becoming a core part of chemical management programs. 

Manufacturers should prioritize PFAS data collection for Minnesota, New Mexico, Connecticut, Washington, Maine, California, Oregon, and Vermont, while continuing to monitor states advancing bans, labeling, testing, and certification requirements. The companies best positioned for compliance will be those that start early: engaging suppliers, screening products, documenting PFAS use, and building chemical management systems that can support both today’s reporting obligations and tomorrow’s restrictions.

Want to stay ahead of US Product Compliance in 2026? Watch our webinar-on-demand.

Frequently Asked Questions

• Which states have broad PFAS product reporting requirements?
  Minnesota and New Mexico are discussed as broad PFAS product reporting states.
• Which states have category-specific PFAS notification or registration requirements?
  Connecticut, Washington, Maine, and California are discussed as states with category-specific notification, reporting, registration, or compliance-submission frameworks.
• Can children’s product chemical disclosure laws capture PFAS?
  Yes. Oregon, Vermont, and Washington are included because their children’s product chemical disclosure programs can capture certain PFAS when those substances appear on state chemical lists.
• Which states should be treated separately from a reporting-only analysis?
  Colorado, New Hampshire, New Jersey, New York, Rhode Island, and Michigan should still be monitored, but they should be treated separately from a reporting-only analysis because their PFAS laws may focus on bans, labeling, consumer disclosure, certificates of compliance upon request, testing, firefighting foam, or food packaging restrictions.

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