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The Connecticut Department of Energy and Environmental Protection (DEEP) released a document with additional information about the state’s PFAS in Consumer Products Law. The document — “Connecticut’s PFAS in Consumer Products Law” — provides information to manufacturers, distributors, retailers and others about certain provisions of the law.
Enacted in 2024, the act addresses the use and sale of PFAS in certain consumer products across 12 identified categories.
The document outlines exemptions based on manufacturing date; labeling exemptions for product labels regulated under federal law; clarifications to labeling requirements; retailer obligations; and extension requests for compliance.
Exemptions based on manufacturing date
Exemptions to the law include an exemption based on a product’s manufacturing date. According to the law’s language, “any product manufactured prior to any prohibition imposed by the provisions of this section” may be exempt.
DEEP has emphasized that this exemption does not apply to the statute’s labeling provisions, which went into effect July 1, as they are requirements, not prohibitions. The labeling provisions require several products manufactured, sold, offered or distributed for sale in the state to include a warning label if they contain intentionally added PFAS
However, if products remain on retailer shelves, they can still be sold so long as they are appropriately labeled.
Labeling exemptions for product labels regulated under federal law
The document states that products subject to federal labeling requirements, such as those regulated by the U.S. Environmental Protection Agency under the Federal Insecticide, Fungicide, and Rodenticide Act, are not subject to the state’s labeling provisions.
Clarifications to labeling requirements
DEEP also clarified labeling requirements, including:
(3) All labels shall be clearly visible prior to sale and shall inform the purchaser, using words or symbols approved by the department, that PFAS is present in the product.
Information about a product in a “catalog, webpage, or other forms of marketing” must include the label information prior to the consumer purchasing it, with the information visible on the same webpage as the product, without requiring consumers to click to a different webpage.
(4) Labels affixed to any such product shall be constructed of materials that are sufficiently durable to remain legible for the useful life of the product.
The department specified that labels may be affixed to a product’s packaging or the product itself, so long as the label is clearly visible prior to sale.
Retailer obligations
Retailers are required to stop offering any product that DEEP determines to be noncompliant for sale in Connecticut.
Extension requests for labeling compliance
DEEP is not issuing extensions for compliance with these provisions. Products that are out of compliance must submit notifications and begin labeling the products immediately.
Warning label requirements
Connecticut’s warning label requirements for several products containing intentionally added PFAS manufactured, sold, offered or distributed for sale went into effect July 1. Products that must be labeled include apparel, carpets or rugs, fabric treatments, textile furnishings, upholstered furniture, dental floss, cleaning products, cookware, cosmetic products, juvenile products, menstruation products and ski wax.
Each label must be clearly visible before the sale; inform the purchaser, using words or symbols DEEP approves, that PFAS are present in the product; and labels affixed to products must be constructed of sufficiently durable materials that will remain legible for the product’s life.
The state approved the following words for use in labels:
- Contains PFAS
- Made with PFAS
- Made with PFAS chemicals
- Made with intentionally added PFAS
- This product contains PFAS
- Contains PFAS in Internal Components
Approved symbols include an outline of an Erlenmeyer flask with both the word PFAS and an exclamation point inside the flask or an outline of an Erlenmeyer flask with only the word PFAS inside the flask.
A full ban on products manufactured, sold, offered or distributed for sale containing intentionally added PFAS begins Jan. 1, 2028, and applies to the following: 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; and outdoor apparel for severe wet conditions.
More information
For more information about Connecticut labeling requirements, click here.
For questions, contact DEEP.PFASInProduct@ct.gov.
For more information about PFAS regulations in the U.S., visit Advanced Textiles Association’s PFAS Resource Center at textiles.org/education/pfas-resource-center.