Connecticut Publishes Additional Information Regarding PFAS in Consumer Products Law

Beginning July 1, 2026, Connecticut prohibits the manufacture, sale, and distribution of certain consumer products that contain intentionally added per- and polyfluoroalkyl substances (PFAS) unless the manufacturer provides prior notification to the Connecticut Department of Energy and Environmental Protection (DEEP) and labels the specified products. The notification and labeling requirements apply only to apparel; carpets or rugs; cleaning products; cookware; cosmetic products; dental floss; fabric treatments; children’s products; menstruation products; textile furnishings; ski wax; or upholstered furniture. DEEP’s website includes a list of approved words and symbols for labeling. In September 2026, DEEP updated this list to include the label required by New Mexico’s May 2026 rule, an Erlenmeyer flask with the word “PFAS” inside. DEEP also approved the following new words for labeling to inform the purchaser that an intentionally added PFAS is present in the product: “Contains PFAS in packaging components.” Connecticut General Statutes Section 22a-903c on intentionally added PFAS in consumer products does not prohibit PFAS in packaging. Section 22a-903c(e) states that “if a cosmetic product made through manufacturing processes intended to comply with this section contains an unavoidable trace quantity of PFAS that is attributable to impurities of natural or synthetic ingredients, the manufacturing process, storage or migration from packaging, such unavoidable trace quantity shall not cause the cosmetic product to be in violation of this section.”

In September 2026, DEEP also posted a document entitled “Connecticut’s PFAS in Consumer Products Law” that provides information regarding certain provisions of the PFAS in Consumer Products Law. According to the document, DEEP does not apply the exemption in Section 22a-903c(j)(6) for “any product manufactured prior to any prohibition imposed by the provisions of this section” to the July 1, 2026, notification and labeling provisions of the statute “because those are requirements, not prohibitions.” Under the statute, beginning January 1, 2028, the following products are prohibited if the product contains 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. The document clarifies the labeling requirement, stating that “[i]f information about the product is contained in a catalog, webpage, or other methods of marketing, the label information must be included where a prospective purchaser is educated prior to purchase. This means that the disclosure must be on the same webpage as the product, without requiring the consumer to click to another webpage.” DEEP notes that it is not issuing extensions to comply with the notice and labeling requirements and asks manufacturers to “submit the notification and begin labeling products immediately.”